Customer Privacy Notice

This Notice explains how we use information we collect, when it's shared, and your consumer rights.

The Clear Group is made up of subsidiary companies involved in the arrangement of commercial and consumer general insurance policies. Group companies include the following subsidiaries and trading names which are all covered by this statement:

Clear Insurance Management Limited
Arborplan
Marketline
John Ansell
CLEAR MPW
PI Property Insurance
Techinsure
PPAW
Lawsure
Clear Wholesale
Clear Councils

As an insurance intermediary, we need to collect personal information for a variety of reasons. 

We need contact details (name, address, telephone numbers, email addresses) to communicate with you about your insurance requirements.

We will collect information about you, your assets and potential liabilities to assess your insurance requirements, to approach providers for quotations, to put insurance policies in force and for the ongoing servicing of those policies.

Where appropriate, we may need to collect details to process payments from or to you such as bank account or payment card information.

In the event of a claim we may be required to obtain further personal information so that the matter can be properly considered. This could include information about other parties involved in an incident.

Data protection legislation includes that we are only allowed to collect or use your personal information if the reason to do so meets certain conditions. The exact reason will vary depending on the specific circumstances. The legal bases that we rely on are: 

• For the performance of a contract: Our agreement with you to arrange insurance policies means that we must continue to use personal information. This would include obtaining renewal terms, making changes to your policy, submitting claims or handling any premium adjustments or claims payments.
• Insurance: The Regulations make special provision for the processing of certain ‘special category data’, such as health or criminal conviction data, if the processing is necessary for an insurance purpose.
• To meet a legal obligation: We are required to perform certain checks on customers, such as to confirm their identity or ensure there are no reasons why we should not do business with them. We may also be obliged to provide information to a court or regulatory body.
• Legitimate interests: The law allows us to hold or use personal information if we have a legitimate reason to do so. For example, having arranged your insurance, we will keep records in case any claim or potential dispute arises in the future so that we can establish the circumstances and, where appropriate, defend our position. Also, we may use your contact details to promote our services. Where we rely on this basis, we will balance our interests with your own rights under data protection laws. For example, we will maintain a policy so that we do not keep information longer that is reasonable.
• Consent: If no other legal basis applies, we may rely on your consent to use your personal data, for example to send marketing materials to prospective customers.

In some circumstances we may need to process personal information using automated decision-making by, or at the direction of, product providers. This involves assessment of the information provided to determine whether a product is offered and under what terms.

Automated decision-making could limit the range of products available to you and if you disagree with the result you have the right to request a manual assessment of the information provided. Please contact us if you require this.

Where you provide information about other individuals, such as employees or family members, you are responsible for drawing their attention to this notice.

We may obtain personal information from other sources in relation to your insurance policies. Examples include previous and current insurers or brokers, loss adjustors and loss assessors. We require all such parties to comply with data protection legislation.

If you use our websites we collect information using ‘cookies’. Further information is contained in our Cookie Policy which can be viewed at www.thecleargroup.com/cookies-policy

In the course of arranging and administration of your insurance, there are a number of situations where your personal information will be shared with other parties. These include:

• Where we obtain quotes, amend your policy or make a claim we will forward information to product providers (insurers, managing agents or other intermediaries) 
• Some product providers may appoint another party to administer the policy or respond to claims or complaints on their behalf
• Where you require us to apply to pay your premium in instalments we will share relevant information with credit providers to obtain their terms
• Where we are required or permitted to do so by law or regulation, such as prevention of financial crime
• Where we provide services in partnership with another party
• With third party service parties unrelated to insurance, such as data hosting / storage providers or technology suppliers
• If we undergo a reorganisation, or if some or all of our business or assets change ownership, we may transfer your personal information to the successor company to ensure continuity of service.

Our agreements with third parties include requirements to comply with relevant data protection legislation so that your rights are maintained.

We will not send your personal information outside of the European Economic Area (EEA). However, some insurers may do so and will provide details in their own Privacy Notices.

We will use your contact details to keep you up to date with industry developments and insurance products that may be appropriate for you through our Newsletters. We will only send this where Regulations permit us or where we have your permission to do so.

At any time you can request to no longer receive marketing communications, either by contacting us using the details below or by ‘Unsubscribing’ using the link in any marketing email.

There are a number of reasons why CLEAR will retain personal information, such as legal or statutory obligations, to process claims and to respond to any complaint or dispute.  We are sometimes contractually bound to retain information on behalf of product providers.

For most policies, we will retain records for up to seven years following expiry of the policy or termination of our services.

Some policies can be claimed against long after they have expired. We will retain records of these for longer than seven years based on the likelihood of any claim, complaint or dispute arising.

Where we have obtained your consent to hold personal information, we will retain it for as long as we have your consent, subject to the above timescales.

Data regulations and legislation provide you with certain rights over the personal information we hold.

• You can request details of some or all of the personal information we hold about you. This is often referred to as a Subject Access request. 
• Where you believe personal information is no longer required you can request that it is deleted. However, we may not be able to do so it we still have a legitimate basis for keeping it, such as servicing your policy.
• If you believe that personal information we hold about you is incorrect you can ask us to correct it.
• You can request a copy of personal information to be provided in a portable (electronic) format. We will endeavour to meet such requirements where the format is reasonable and in common use.
• Where you have provided consent to receive marketing communications you can withdraw your consent at any time.

In addition to these, you can ask us to restrict the use of your personal data if any of the above apply, but you do not wish us to delete it.
We aim to meet any requests promptly and as fully as possible. We may contact you to further understand your requirements in order to expedite your request.  In some cases, we may be prevented from completing requests for legal reasons or due to conflicting legitimate interests. If this is the case, we will explain our reasons why.

There is no charge for requests for copies, amendments or deletions of personal information. However, we reserve the right to charge where requests are unreasonably frequent or excessive.

If you have any questions regarding this Privacy Notice or wish to make a request regarding your personal information, please contact:

The Data Protection Manager
Clear Insurance Management Limited
1 Great Tower Street
London
EC3R 5AA

You may also email us at compliance@thecleargroup.com

If you are dissatisfied about the way we have handled your personal information and wish to complain, you should contact the Data Protection Manager using the details above. We will aim to investigate and respond promptly and will provide a written response.

If you remain dissatisfied, or believe that we are not handling personal information in compliance with appropriate laws and regulations, you are entitled to raise your complaint with the Information Commissioner’s Office who can be contacted at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Last updated: 12/09/2023