We at Luker Rowe are committed to maintaining the trust and confidence of our customers and respecting your privacy. We recognise your need for appropriate protection and management of any personally identifiable information (‘Personal Information’) you share with us whether this is when you visit our website or offline via other methods such as telephone, email or letter.
Personal Information means any information that may be used to identify an individual, including, but not limited to, a first and last name, a home or other physical address, an e-mail address or other contact information, whether at work or at home.
Our data protection registration number is Z4816491.
FAIR PROCESSING NOTICE (HOW WE USE PERSONAL INFORMATION)
1. Who we are
When we refer to “we”, “us” and “our” in this notice it means Luker Rowe & Co Limited. It also includes, where relevant to your insurance application, policy or claims the insurer who underwrites your cover.
When we say “you” and “yours” in this notice, we mean anyone whose personal information we may collect, including:
· Anyone seeking an insurance quote from us or whose details are provided during the quotation process policyholders and anyone named on or covered by the policy
· Anyone who may benefit from or be directly involved in the policy or a claim including claimants and witnesses.
2. What data (“personal information”) do we collect?
In order for us to provide insurance quotes, insurance policies, and/or deal with any claims or complaints, we need to collect and process personal data about you. The types of personal data that are processed may include, but are not limited to, the following:
|Individual details||Name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to you|
|Identification details||Identification numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving licence number|
|Financial information||Bank account or payment card details, income or other financial information|
|Risk details||Information about you which we need to collect in order to assess the risk to be insured and provide a quote. This may include data relating to your health, criminal convictions, or other special categories of personal data. For certain types of policy, this could also include telematics data|
|Policy information||Information about the quotes you receive and policies you take out|
|Credit and ant-fraud data||Credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to you|
|Previous and current claims||Information about previous and current claims, (including other unrelated insurances), which may include data relating to your health, criminal convictions, or other special categories of personal data and in some cases, surveillance reports|
|Special categories of personal data||Certain categories of personal data which have additional protection under the GDPR. The categories are health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation|
This data may also relate to other person(s) you require to be included on the policy and in doing so we assume you have obtained their permission for the release of their information to us.
3. Telephone Recording
Telephone calls may be recorded for joint protection, training and/or monitoring purposes.
4. Where we might collect your personal data from
We might collect your personal data from various sources, including:
· your family members, employer or representative;
· other insurance market participants;
· credit reference agencies;
· anti-fraud databases, sanctions lists, court judgements and other databases;
· government agencies such as the DVLA and HMRC;
· open electoral register; or
· in the event of a claim, third parties including the other party to the claim (claimant / defendant), witnesses, experts (including medical experts), loss adjustors, solicitors, and claims handlers
Which of the above sources apply will depend on your particular circumstances.
5. Cookies and Other Tracking Technologies
Some of our web pages utilise ‘cookies’ and other tracking technologies. A ‘cookie’ is a small text file that may be used, for example, to collect information about web site activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a web user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.
You may set most browsers to notify you if you receive a cookie or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the website.
To protect your privacy, we have adopted the following principles:
Where Luker Rowe collects Personal Information on the web, we intend to post a purpose statement that explains why Personal Information will be collected and whether we plan to share such Personal Information outside of Luker Rowe or those working on our behalf. Luker Rowe does not intend to transfer Personal Information without your consent to third parties who are not bound to act on our behalf unless such transfer is legally required.
You may choose whether or not to provide Personal Information to Luker Rowe. The notice we intend to provide where we collect Personal Information on the web or offline should help you to make this choice. If you chose to have a relationship with Luker Rowe, such as a contractual or other business relationship or partnership, we will naturally continue to contact you in connection with that business relationship.
Wherever your Personal Information may be held within Luker Rowe or on its behalf, we intend to take reasonable and appropriate steps to protect the Personal Information that you share with us from unauthorised access or disclosure.
6. How may we use your personal information?
· For the purposes of insurance administration by us in response to your requests for quotations, arranging policies, handling claims, arranging finance and further information.
· We may use profiling and automated decision making, to assess insurance risks, detect fraud, and administer your policy. This helps us decide whether to offer you insurance determine prices and validate claims.
· For legitimate interests e.g. to send you marketing communications about our products.
· To deal with enquiries or complaints made by you relating to our website service.
7. Sharing of personal information
We may also share the information you provide with other organisations that perform activities on our behalf, such as, but not restricted to:
· Insurers their associated companies and agents for the purpose of insurance administration
· Other insurance providers such as Managing General Agencies and Wholesale Brokers
· Loss adjusters and other claims handlers
· Finance companies and credit reference agencies
· Marketing databases
· Software providers
· Fraud prevention and sanction checking agencies
· Regulators, law enforcement and the Financial Ombudsman Service (FOS)
· Prospective buyers in the event that Luker Rowe wishes to sell all or part of its business
8. Know your rights
You have the right to object to us using your personal information. You can do this at any time by telling us and we will consider your request and either stop using your personal information or explain why we are not able to. Our contact details can be found at the end of this statement.
You have a number of rights in relation to the personal information which is held about you including the right to:
• ask for a copy of the personal information we hold about you, subject to certain exemptions (the right of access – a data subject access request)
• ask us to update or correct your personal information to keep it accurate (the right of rectification )
• ask us to delete your personal information from our records if it is no longer needed for the original purpose. There may be legitimate reasons why we may not be able to erase all or part of your data (The right to be forgotten)
• ask us to restrict the use of your personal information in certain circumstances (The right of restriction)
• ask for a copy of the personal information you provided to us. This right allows individuals to obtain and reuse their personal data for their own purposes across different services. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. (The right to data portability)
• object to us using your personal information. We will either agree to stop using it or explain why we are unable to (The right to object)
• complain to the Data Protection Regulator, the Information Commissioner’s Office, which may be contacted at its website http://ico.org.uk or telephone 0303 123 1113 (the right to complain)
• Ask us, at any time, to stop using your personal information, if using it is only based on your consent (the right to withdraw your consent)
As a client, previous client or prospective client of Luker Rowe we may forward you from time to time details about our products, services or other information which we consider may be beneficial to you or your organisation. Our understanding of GDPR regulations is that these will not require your consent as they fall within the regulation definition of legitimate interests. We respect your privacy and you can opt out from these mailings at any time by contacting your account executive or our Data Protection Manager by emailing GDPR@lukerrowe.com.
10. Links to other organisation’s websites
Our website contains links to other websites. We are not responsible for the privacy policies of such other websites and we advise you to read the privacy policies of each website you visit which collects personal data.
11. Changes to our Fair Processing Notice
Occasionally it may be necessary to make changes to this notice. The most recent version will always be available on our website.
12. Contacting our Data Protection Manager