PRIVACY
NOTICE
ABOUT
US
We, Henderson Insurance
(NE) Limited (also referred to as “we”, “us”, or “our”) are a registered
company in England
(Company no. 7419893). Our registered
address is 36 Blind Lane,
Silksworth, Sunderland, SR3 1AT.
The
PURPOSE OF THIS NOTICE
This Notice is designed to help you understand
what kind of information we collect
in connection with our products and
services and how we will process and
use this information. In the course of providing you with products and services
we will collect and process information
that is commonly known as personal data.
This Notice describes how we collect, use, share, retain and
safeguard personal data.
This Notice sets out your individual
rights; we explain these later in the Notice but in summary these rights
include your right to know what data is held about you, how this data is
processed and how you can place restrictions on the use of your data.
WHAT IS PERSONAL DATA?
Personal
data is information relating to an identified or identifiable natural person.
Examples include an individual’s name, age, address, date of birth, their
gender and contact details.
Personal
data may contain information which is known as special categories of personal data.
This may be information relating to an individual’s health, racial or
ethnic origin, political opinions, religious or philosophical beliefs, trade
union membership, genetic and biometric data, or data relating to or sexual
orientation.
Personal
data may also contain data relating to criminal convictions and offences.
For
the purposes of safeguarding and processing criminal conviction and offence
data responsibly, this data is treated in the same manner as special categories
of personal data, where we are legally required to comply with specific data processing
requirements.
PERSONAL DATA WE COLLECT
In
order for us to arrange and administer insurance for you we will collect and process personal data
about you. We will also
collect your personal data where you request information about our services, customer events,
promotions and campaigns.
We may also need to
collect personal data relating to others in order to arrange and administer
insurance. In most circumstances, you will provide us with this information. Where you disclose the personal data of
others, you must ensure you are entitled to do so.
You may provide us
with personal data when completing online quote or contact forms, when you
contact us via the telephone, when
writing to us directly or where we provide you with paper based forms
for completion or we complete a form in conjunction with you.
We will share your personal
data within our firm and with business
partners. This is normal practice within the insurance industry where it is
necessary to share information in order to place, quantify and underwrite risks,
to assess overall risk exposure and to process claims. It is also necessary to
determine the premium payable and to administer our business.
We also share personal data
with authorised third parties, this is necessary where we are required to do so by law, where we need to administer our
business, to quote for, source, place and administer your insurances, including
arranging insurance premium finance, to perform underwriting activities and to
process claims. Some examples follow:
-
Insurers;
-
Underwriters;
-
Premium
finance providers;
-
Credit
reference agencies;
-
Debt
recovery agencies;
-
Claims
handling companies;
-
Loss
adjusters;
-
Insurance
brokers;
-
Reinsurers;
-
Regulators.
We will collect your personal data when you visit our website, where we will
collect your unique online electronic identifier; this is commonly known as an
IP address.
We will also collect electronic personal data when you first visit our website where we will place a small text file that is commonly known as a cookie
on your computer. Cookies are used to identify visitors and to simplify
accessibility, and to monitor visitor behaviour when viewing website content,
navigating our website and when
using features. For more information
please see our website.
We may record your communications
with us when contacting our customer care, complaints and other
customer focused functions.
Where
we collect data directly from you, we are considered to be the controller
of that data i.e. we are the data
controller. Where we use third
parties to process your data, these parties are known as processors of your
personal data. Where there are other
parties involved in underwriting or administering your insurance they may also
process your data in which circumstance we
will be a joint data controller of your personal data.
A
data ‘controller’ means the individual or organisation which, alone or jointly
with others, determines the purposes and means of the processing of personal
data.
A data
‘processor’ means the individual or organisation which processes personal data
on behalf of the controller.
As
a provider of insurance services, we
will process the following categories of data:
·
Personal
data such as an individual’s name, address, date of birth, gender, contact
details and details of historic claims
·
Special
categories of personal data such as health and details on historic claims
resulting in injury (physical and physiological)
·
Data
relating to criminal convictions and offences such as details of driving
offences or insurance fraud
If
you object to the collection, sharing and use of your personal data we may be unable to provide you with our products and services.
For
the purposes of meeting the Data Protection Act 2018 territorial scope
requirements, the United
Kingdom is identified as the named territory
where the processing of personal data takes place.
If
you require more information about our insurance
processes or further details on how we
collect personal data and with whom we
share data with, please contact our ‘data
privacy representative’ by e-mailing
info@hendersoninsurance.co.uk.
WHY DO WE NEED YOUR PERSONAL DATA?
We will use your personal data for the performance of
our contract with you, to quote for and provide you with insurance products and
services, to process claims and renewals, to administer your policy and our business, to respond to any
requests from you about services we
provide and to process complaints.
We will use the
special category and criminal conviction data we collect about you for the
performance of our contract with you which is deemed to be necessary for
reasons of substantial public interest. This allows us to quote for and provide
you with insurance products and services, to process claims and renewals and to
administer your policy.
In purchasing our products and services you should understand that you are
forming a contract with us. If you
contact us for a quote or request
details on the services we provide, we consider ourselves as having a legitimate
business interest to provide you with further information about our services.
In
some situations we may request your
consent to market our products and
services to you, to share your data or to transfer your data outside the
European Economic Area. Where we
require consent, your rights and what you are consenting to will be clearly
communicated to you. Where you provide consent, you can withdraw this at any
time by contacting our data privacy
representative.
We will retain all your personal data at the
end of any contractual agreement for a period of six years from expiry including special category and criminal conviction data. Where you have submitted a claim, we will retain your data for a period of six years if it is a non-injury claim; where an individual has been injured (physical and physiological), we will retain your data for fifteen years, unless the claim involves a minor whereby we shall follow the Limitation Act. Where you have requested a quote or contacted us for details of our services and products, we will retain your personal data for three years. However if you were a client within the last six years this will be attached to your previous record and the time limit above will apply. Where you make a complaint we will retain the data for six years from closure. Where
you or law enforcement agencies inform us about any active investigation or
potential criminal prosecution, we will comply with legal requirements when
retaining this data.
The retaining of data is necessary where
required for contractual, legal or regulatory purposes or for our legitimate
business interests and marketing
purposes.
Sometimes we may need to retain your data for longer, for example if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future claim may occur.
You should be aware that we use automated decision making (services/tools and techniques) to check for customer suitability to our products, for example we might perform a credit search to check an individual's solvency and credit rating.
Please
contact our data privacy
representative if you object to the use of, or you have any questions relating
to the use of, your data, the retention of your personal data. You can opt out of receiving marketing
services by e-mailing info@hendersoninsurance.co.uk.
YOUR
RIGHTS
Individuals are provided with legal rights
governing the use of their personal data. These grant individuals the right to understand
what personal data relating to them is held, for what purpose, how it is
collected and used, with whom it is shared, where it is located, to object to
its processing, to have the data corrected if inaccurate, to take copies of the
data and to place restrictions on its processing. Individuals can also request
the deletion of their personal data.
These rights are known as Individual Rights
under the Data Protection Act 2018. The following list details these rights:
-
The
right to be informed about the
personal data being processed;
-
The
right of access to your personal
data;
-
The
right to object to the processing of
your personal data;
-
The
right to restrict the processing of
your personal data;
-
The
right to rectification of your
personal data;
-
The
right to erasure of your personal
data;
-
The
right to data portability (to
receive an electronic copy of your personal data);
-
Rights
relating to automated decision making including profiling.
Individuals can exercise
their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests, however if your
request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable
administration fee.
In exercising your Individual
Rights, you should understand that in some situations we may be unable to fully meet your request, for example if you make
a request for us to delete all your
personal data, we may be required to
retain some data for taxation, prevention of crime and for regulatory and other
statutory purposes.
You should understand
that when exercising your rights, a substantial public or vital interest may
take precedence over any request you make. In addition, where these interests
apply, we are required by law to grant access to this data for law enforcement,
legal and/or health related matters.
The
flow of data within the insurance sector is complex and we ask you to keep this in mind when exercising your ‘rights of
access’ to your information. Where we may be reliant on other
organisations to help satisfy your request this may impact on timescales.
If you require further
information on your Individual Rights or you wish to exercise your Individual
Rights, please contact our data
privacy representative by e-mailing info@hendersoninsurance.co.uk
or by writing to 36 Blind Lane,
Sunderland, SR3 1AT.
PROTECTING YOUR DATA
We will take all appropriate technical and
organisational steps to protect the confidentiality, integrity, availability
and authenticity of your data, including when sharing your data within our firm
and authorised third parties.
DATA PRIVACY REPRESENTATIVE
To ensure data privacy and protection has appropriate focus within our
organisation we have a Data Privacy Representative, Peter Adamson, who is also
a director.
COMPLAINTS
If you are dissatisfied with any aspect of the
way in which we process your personal data please contact our data privacy representative.
You also have the right to complain to the UK’s data protection supervisory
authority, the Information Commissioner’s Office (ICO). The ICO may be contacted via its website
which is https://ico.org.uk/concerns/,
by live chat or by calling their helpline on 0303 123 1113.
HOW TO CONTACT US
If you have any
questions regarding this Notice, the use of your data and your Individual Rights
please contact our data privacy
representative at 36 Blind Lane, Sunderland, SR3 1AT or by e-mailing
info@hendersoninsurance.co.uk or by telephoning 0191 5235001.
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