Intermediary Privacy Notice

Your right to privacy is important to us and we are committed to keeping it protected. This Privacy Notice will explain how we use the personal information we collect about you and how you can exercise your data protection rights.

This Privacy Notice will help you understand the following:

How do we collect your personal information?

There are several ways in which we may collect your personal information. Your personal information will usually be provided to us directly by you, however your personal information may also be provided to us on your behalf by:

your employer;

the firm that you are authorised by;

any mortgage club that your firm is associated with;

any intermediary software provider that you may use;

if you are an Appointed Representative, by the Principal of the firm that you are authorised by (your network).

We will only receive personal information from the firms detailed above if there is a contract in place between us and the firm that confirms that the firm has permission to pass your personal information to us. We may collect personal information about you:

via enquiry or registration forms;

via our telephone calls with you, which may be recorded;

via face-to-face meetings, industry roadshows or seminars;

via feedback forms and forums;

when you purchase any of our products or services;

when you fill out a survey, or vote in a poll on our website;

through quotes and application forms;

through management information reports;

from policyholders to whom you have sold a policy;

when you provide your details to us either online or offline; and

through our use of cookies. You can find out more about this in our cookies policy which can be found here.

We may also collect your personal information from:

publicly available sources of information, such as your company website, the FCA register or social media and networking sites;

organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies;

fraud prevention agencies and operators of registers available to the insurance industry to check information and prevent fraud;

third party databases made available to the insurance industry, as well as databases where you have given your permission to share information with a third party like us;

credit reference agencies; and

any other person or firm authorised by you to provide us with your personal information.

What personal information do we collect?

Below are the types of personal information that we may collect about you:

contact details such as your name, email address, postal address and telephone number;

details about your employment, such as your employee name, regulatory status and your role within the company;

identification information such as your date of birth;

financial information such as bank details and information obtained through any credit checks that we may undertake;

information about the nature of your business and commercial assets;

information about the quotes that you have produced, and policies that you have sold, on behalf of your customers;

your marketing preferences; and

any other information that we may ask you or that you provide to us.

In certain circumstances we may also use information about any criminal convictions that you may have, but we will only do this where allowed by law or if you give us your consent.

How do we use your personal information?

We will use your personal information to:

assess your application to open an agency with us;

verify the information provided;

confirm your identity;

assess your financial standing;

prevent fraud;

complying with our legal or regulatory obligations;

allow you access to our systems;

improve our products, services, training and security;

resolve any complaints you may have;

resolve any complaints policyholders may have;

assist you with enquiries relating to policies that you have sold;

maintain our insurance records;

facilitate our quality and compliance monitoring processes;

keep you up to date with changes to our systems, products and proposition; and

inform you other products and services that we offer that you may be interested in.

Legal grounds for processing your personal information

Data protection laws require us to meet certain conditions before we are allowed to use your personal information in the manner described in this Privacy Notice. To use your personal information, we will rely on one or more of the following grounds:

Performance of contract: We need to use your personal information in order to provide you with the policy (which is a contract of insurance between you and us), and perform our obligations under it (such as making payments to you in respect of a claim made under the policy);

Consent: In certain circumstances, we may need your consent unless authorised by law in order to use personal information about you which is classed as “special categories of personal data”;

Necessity to establish, exercise or defend legal claim: If you, or we, bring a legal claim against the other, we may use your information in either establishing our position, or defending ourselves in relation to that legal claim;

Compliance with a legal obligation: Where laws or regulations may require us to use your personal information in certain ways; and

Legitimate Interests: We will also process your personal information where this processing is in our legitimate interests. For example, it is in our legitimate interests to ensure that you are kept up to date with changes to our systems and the products that you offer to your customers.

We will always act reasonably and give full and proper consideration to your interests when relying upon our legitimate interests when processing your data and you will always be given a choice over the use of your data for marketing purposes, which includes the ability to opt-out of certain types of communication.

Automated decision making

Occasionally we may need to undertake activities which involves automated (computer based) decision-making. As an example, when you register with us our system will automatically check your regulatory status on the FCA register before your registration is approved.

The results of these automated decision-making processes may limit the products and services we can offer you. If you do not agree with the result, you have the right to request that we perform a manual reassessment using the same information that you originally provided.

Who may we share your personal information with?

We may share your personal information with:

your employer;

the firm that you are authorised by;

any mortgage club that your firm is associated with;

any intermediary software provider

if you are an Appointed Representative, by the Principal of the firm that you are authorised by (your network).

other insurers, business partners, agents or carefully selected third parties providing a service to us or on our behalf, such as processing our mail, communicating with customers on our behalf, providing IT systems and administrative services, claims handling services and the development and improvement of our internal systems;

organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies;

other organisations where we have a duty to or are permitted to disclose your personal information by law, for example if we received a valid request from the police or other third party organisation in the interest of preventing and detecting crime;

fraud prevention agencies and operators of registers available to the insurance industry to check information and prevent fraud;

credit reference agencies;

third parties we use to recover money you may owe us or to whom we may sell your debt;

another company, if our business or part of it is bought or taken over by that company to make sure your insurance policy can continue to be serviced or as part of preliminary discussions with that company about a possible sale or take over;

other companies or brands within the Uinsure group;

other companies when we are trailing their products and services which we consider may improve our services to you or our business processes; or

other third parties if you have given us your permission to do so, or there is sufficient reason to believe they are acting on your behalf.

Sometimes your personal information may be sent to other parties outside of the European Economic Area (EEA) in connection with the purposes set out above. We will take all reasonable steps to ensure that your personal information is treated securely and in accordance with this Privacy Notice, and in doing so may rely on certain “transfer mechanisms” such as the EU-Us Privacy Shield, and the standard contractual clauses approved by the European Commission. If you would like further information please contact us.

How long will we keep your information?

We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice and in order to comply with our legal and regulatory obligations. The time period we retain your personal information for will differ depending on the nature of the personal information and what we do with it. How long we keep personal information is primarily determined by our legal and regulatory obligations. We typically keep quote information for 3 years, and policy and claims records for up to 7 years from the end of our relationship each policyholder. As such, we will retain your personal information for up to 7 years after the last policy that you sold cancels. In some cases, such as if there is a dispute or a legal action we may be required to keep personal information for longer.

Your rights

You have a number of rights concerning the personal information we use. You may request that we:

provide you with details of the personal information we hold about you.

All requests are free of charge, although for requests for the provision of personal information we hold about you we reserve the right to charge a reasonable administrative fee where, we believe an excessive number of requests are being made. Wherever possible, we will respond within one month from receipt of the request, but if we do not, we will notify you of anticipated timelines ahead of the one month deadline.

Your personal information can be provided in a structured, commonly used, machine readable form when asked;

correct inaccurate or incomplete personal information held about you;

erase your personal information where you believe it is no longer required;

restrict the processing of your personal information. You have the right to ask that suppress processing your personal information. We will continue to store your personal information but will no longer process it;

stop your personal information from being used for profiling, direct marketing or research purpose;

You have rights in relation to automated decision making and profiling, to reduce the risk that a potentially damaging decision is taken without human intervention; and

perform a manual reassessment using the same information that you originally provided if we have used automated decision making and profiling and this is likely to be potentially damaging.

Please note, in some cases even when you make a request concerning your personal information, we may not be required, or may not be able, to honour it, as this may result in us not being able to fulfil our legal and regulatory obligations, or there is a minimum statutory period of time for which we have to keep your information. If this is the case, we will let you know our reasons. To make a request, please write to us at writing to us at Uinsure Limited, PO Box 5524, Manchester, M61 0QR. To ensure that we do not disclose your personal information to someone who is not entitled to it, when you are making the request we may ask you to provide us with your name, address, date of birth, policy number(s) and a copy of your photo identification.

Further information

If you require further information on, or wish to complain about, the way that we use your personal information, please write to us at Uinsure Limited, PO Box 5524, Manchester, M61 0QR.

If you believe we have not complied with our obligations in relation to the handling of your personal information you have a right to submit a complaint to the Information Commissioner. For further information please visit https://ico.org.uk/global/contact-us/

Updates

This Policy was last updated on 1st May 2018.