Fair processing notice
The privacy and security of your information is important to us. This notice explains who we are, the types of information we hold, how we use it, who we share it with and how long we keep it. It also informs you of certain rights you have regarding your personal information under current data protection law. We will update this notice as required and at least annually (every December). Therefore, we suggest you revisit this notice every December to keep yourself informed.
The terms used in this Fair Processing Notice are based on the Information Commissioner’s Office. You can find out more about the ICO here: https://ico.org.uk/.
Who are we?
Health and Protection Solutions Limited, trading as Towergate Health & Protection, (part of The Ardonagh Group of companies) is the Data Controller of the information you provide us and is registered with the Information Commissioner’s Office for the products and services we provide to you. You can contact us for general data protection queries by email to firstname.lastname@example.org, or in writing to:
The Data Protection Officer
Towergate Health & Protection
01206 773 574
For further information about The Ardonagh Group of companies please visit http://www.ardonagh.com/.
What information do we collect?
To enable us to provide you with the right product or service to meet your needs (or to assist with a claim), we will collect personal information which may include your name, telephone number, email address, postal address, occupation, date of birth, additional details of risks related to your enquiry or product and payment details (including bank account number and sort code).
We may need to request and collect sensitive personal information, such as medical history, for us to provide you with the product or service or to assist you with a claim.
We only collect and process sensitive personal data where it is critical for the delivery of a product or service and without which the product or service cannot be provided. We will therefore not seek your explicit consent to process this information as it is required by us to provide the product or service you have requested and is legitimised by its criticality to the service provision. If you object to use of this information then we will be unable to offer you that product or service.
How do we use your personal information?
We will use your personal information to:
- Assess and provide the products or services that you have requested
- Communicate with you
- Develop new and improve existing products and services
- Undertake statistical analysis
We may also take the opportunity to:
- Contact you about products that are closely related to those you already hold with us
- Provide additional assistance or tips about these products or services
- Notify you of important functionality changes to our website
Only where you have provided us with consent to do so, we may also from time to time use your information to provide you with details of marketing or promotional opportunities and offers relating to other products and services from The Ardonagh Group.
From time to time we will need to call you for a variety of reasons relating to your products or service (for example, to update you on the progress of a claim or to discuss renewal of your insurance contract). We are fully committed to Ofcom regulations and have strict processes in place to ensure we comply with them.
To ensure the confidentiality and security of the information we hold, we may need to request personal information and ask security questions to satisfy ourselves that you are who you say you are.
We may aggregate information and statistics on website usage or for developing new and existing products and services, and we may also provide this information to third parties. These statistics will not include information that can be used to identify any individual.
Securing your personal information
We follow strict security procedures in the storage and disclosure of your personal information in line with industry practices, including storage in electronic and paper formats.
We store all the information that you provide to us, including information provided via forms you may complete on our websites, and information which we may collect from your browsing (such as clicks and page views on our websites).
Any new information you provide us may be used to update an existing record we hold for you.
When do we share your information?
To help us prevent financial crime, your details may be submitted to fraud prevention agencies and other organisations where your records may be searched, including the Claims and Underwriting Exchange (CUE).
In addition to companies within the Ardonagh Group, third parties (for example insurers) deliver some of our products or provide all or part of the service requested by you. In these instances, while the information you provide will be disclosed to these companies, it will only be used for the provision and administration of the service provided (for example verification of any quote given to you or claims processing, underwriting and pricing purposes or to maintain management information for analysis).
This may also include conducting a search with a credit reference bureau. We will never make a search that leaves a record on your credit history without informing you first.
We may use firms involved in financial management regarding payment.
We may also share your data with other companies who carry out market research on our behalf and who may contact you for the purposes of obtaining feedback on the products and services we offer.
We will only share your information for any direct marketing of additional services and products within The Ardonagh Group of companies where we have your consent to do so.
The data we collect about you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for us or for one of our suppliers. Such staff may be engaged in, amongst other things, the provision of information you have requested.
If we provide information to a third party we will require it and any of its agents and/or suppliers to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Fair Processing Notice.
We may of course be obliged by law to pass on your information to the police or other law enforcement body, or statutory or regulatory authority.
We may also share your information with anyone you have authorised to deal with us on your behalf.
How long do we keep your information for?
We will not keep your personal information longer than is necessary for the purpose for which it was provided unless we are required by law or have other legitimate reasons to keep it for longer (for example if necessary for any legal proceedings).
We will normally keep information for no more than 7 years and 1 day after termination or cancellation of a product, contract or service we provide. In certain cases, we will keep your information for longer, particularly where a product includes liability insurances or types of insurance for which a claim could potentially be made by you or a third party at a future date, even after your contract with us has ended.
There are a number of rights that you have under data protection law. Commonly exercised rights are:
- Access - You may reasonably request a copy of the information we hold about you. ICO guidance
- Erasure – where we have no legitimate reason to continue to hold your information, you have the right to have your data deleted (sometimes known as the right to be forgotten). ICO guidance
- We may use automated decision making in processing your personal information for some services and products. You can request a manual review of the accuracy of an automated decision if you are unhappy with it. ICO guidance
- Marketing – if you wish to inform of us changes in consent for marketing please contact us at the address or telephone number indicated in any recent correspondence or emails you have received from us.
If you are unhappy about the way we have handled your data or upheld your rights, you can complain to the Information Commissioner’s Office (ICO) at any time.
Further details of your rights can be obtained by visiting the ICO website at https://ico.org.uk/your-data-matters/.