Why should you read this?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
This policy is effective from 01/05/2018.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your Health/Private Medical Insurance, Life Insurance, Income Protection, Critical Illness, Cash Plan, Dental Insurance, Travel Insurance and Business Protection (such as Relevant Life Insurance, Share Holder Protection or Key Man Insurance) requirements Your Personal Data may include but may not be limited to:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
- Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
- Any pre-existing Health/Private Medical Insurance, Life Insurance, Income Protection, Critical Illness, Cash Plan, Dental Insurance, Travel Insurance and Business Protection products and the terms and conditions relating to these
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your Health/Private Medical Insurance, Life Insurance, Income Protection, Critical Illness, Cash Plan, Dental Insurance, Travel Insurance and Business Protection requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from Insurance Providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Personal data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with your insurance needs, for example Health/Private Medical Insurance, Life Insurance, Income Protection, Critical Illness, Cash Plan, Dental Insurance, Travel Insurance and Business Protection we will ask you information about your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance providers in relation to insurance products that may meet your needs and to provide you with advice and guidance regarding the suitability of any product that may be available to you and for purposes relating to the performance of a contract of insurance, such as insurance claims.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use Special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to Health/Private Medical Insurance, Life Insurance, Income Protection, Critical Illness, Cash Plan, Dental Insurance, Travel Insurance and Business Protection. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example information from your employer and searches of information in the public domain such as the government Financial Sanction Lists. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
- Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (CRM system,websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service
- Submit Your Personal Data to Insurance Product providers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that Insurance Product providers may raise.
- Use Your Personal Data for the purposes of responding to any queries or medical insurance claims you may have in relation to any insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Insurance providers
- Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our Compliance Advisers, Product Specialists, Healthcare Providers such as your consultant, therapist, hospital or clinic, providers of Legal services such as estate planners (in each case where we believe this to be required due to your particular circumstances).
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your Health/Private Medical Insurance, Life Insurance, Income Protection, Critical Illness, Cash Plan, Dental Insurance, Travel Insurance and Business Protection enquiry and to provide you with our professional services.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
In certain circumstances, medical claims on International Private Medical Insurance or worldwide Travel Insurance may involve Your Personal Data being shared outside of the European Economic Area in order to complete the performance of a contract of insurance (in each case where we believe this to be required due to your particular circumstances).
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.
Your rights in relation to Your Personal Data
- request copies of Your Personal Data that is under our control
- ask us to further explain how we use Your Personal Data
- ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
- ask us to send an electronic copy of Your Personal Data to another organisation should you wish
- change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact Mr Sherry Saidy, our Managing Director!
Telephone Number: 01273 554066
If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
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Cookies can be used by web servers to identity and track users as they navigate different pages on a website, and to identify users returning to a website.
Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies on this website
We use both session cookies and persistent cookies on this website.
Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies.
We may use the information we obtain from your use of our cookies for the following purposes:
- to recognise your computer when you visit our website;
- to track you as you navigate our website;
- to improve the website’s usability;
- to analyse the use of our website;
- in the administration of this website;
- to personalise our website for you
Third party cookies
When you use our website, you may also be sent third party cookies.
Our service providers may send you cookies. They may use the information they obtain from your use of their cookies:
- to track your browser across multiple websites;
- to build a profile of your web surfing;
- to target advertisements which may be of particular interest to you.
Blocking cookies Most browsers allow you to refuse to accept cookies. For example:
- in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector
- in Firefox you can block all cookies by clicking “Tools”, “Options”, and un-checking “Accept cookies from sites” in the “Privacy” box. Blocking all cookies will, however, have a negative impact upon the usability of many websites.
You can also delete cookies already stored on your computer:
- in Internet Explorer, you must manually delete cookie files;
- in Firefox, you can delete cookies by, first ensuring that cookies are to be deleted when you “clear private data” (this setting can be changed by clicking “Tools”, “Options” and “Settings” in the “Private Data” box) and then clicking “Clear private data” in the “Tools” menu.
Obviously, doing this may have a negative impact on the usability of many websites. Contact us If you have any questions about our cookies or this Cookies Policy, please contact us.