This privacy notice relates to business placed with Victor Millwell Insurance Agency Limited as a sub-agent, on behalf of your client(s).
How we act
We act as the data controller in respect of your clients’ personal information and are committed to protecting your privacy. We will process the details you have given us in line with the UK’s Data Protection laws and any other laws that apply.
Legal basis for processing
The collection of and processing of data connected with the insurance is necessary for the entering into and performance of a contract or contracts and this forms legal basis we have for processing information. We also have legal obligations to perform in which case processing of your information is necessary for compliance with the legal obligations to which we are subject, for example Proceeds of Crime Act 2002.
You have the right to object to us using your clients’ personal information. You can do this at any time by telling us. We will consider your request and either stop using your information or explain why we are not able to. Further details about your rights and how you can contact us are provided below.
Collecting and processing your personal information
For us to provide and administrate insurance quotes, insurance policies, and/or deal with any claims or complaints we need to collect and process information (including personal data) you may disclose. We may also process information classified as “special categories”, which includes details about health and medical conditions, and criminal convictions.
The types of personal data that we process may include but not be limited to:
|Individual details||Such as name, address, contact details, marital status, date and place of birth, nationality, employer, job title, family details|
|Identification details||Identification numbers issued by government bodies or agencies,
including national insurance number, employers reference
number, passport information, tax and driving licence information,
utility bills, certificates of incorporation (for businesses)
|Financial information||Bank account and payment card details, income, expenditure or
other financial information
|Risk information||Information about persons named or eligible to claim benefits under a policy in order to assess the risk to be insured and provide a quote. This might include data relating to health,
criminal convictions or other special categories of personal data.
For certain types of policy, this could include information such
as telematics data.
|Policy information||Information about the quotes you receive and the policies you arrange|
|Credit and anti-fraud data||See the heading “Credit Searches and fraud prevention” below.|
|Previous and current claims||Information about previous and current claims (including unrelated insurances) which may include data about health, criminal convictions or other special categories of personal data. This may also include surveys.|
|Special categories of personal data||Certain categories of personal data have additional protection under data protection laws. 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 orientation. The special categories we collect relate to health and criminal convictions, however it is possible that special categories of data may be collected through our interactions with you, in which case we will ensure we meet the additional levels of protection required under the data protection laws.|
In the event of a claim we may also collect information from third parties (such as the other party involved in the claim), witnesses, experts, loss adjusters, loss assessors, solicitors and claims handlers.
To ensure that your clients’ personal details are protected, you may be asked questions to confirm your identity before we can communicate with you.
We process personal data to provide you with our services, which include:
- Providing quotations and arranging your clients’ insurance cover
- Administering your clients’ insurance policies
- Claims processing or assisting you with your clients’ claim
- Processing renewals and adjustments
- Complying with our legal or regulatory objectives
- Debt collection
- Help improve our customer service
We will disclose your clients’ information to insurers, intermediaries, our service providers, contractors and agents and group companies that perform activities on our behalf for these and other purposes described in this policy.
To help improve customer service and for quality control and training purposes, calls may be recorded and monitored.
Credit searches and fraud prevention
We may exchange your clients’ personal data with or carry out checks with credit reference agencies, fraud prevention agencies, and other public and privately available sources of information. These checks may include electoral roll and credit information (including credit history and credit score), sanctions and details of criminal offences. Insurers may also perform these checks as well. We perform these activities to check identity, assess credit worthiness, help prevent fraud and money laundering.
Insurance credit checks are registered as general insurance searches and may be viewed by other companies when you apply for credit or insurance. These searches should not harm your clients’ credit profile or adversely affect the credit profile.
These checks may be performed at any stage of the quote, purchase process or when the insurance is due for renewal. This may happen regardless of whether you get a quote via the internet or phone.
You should also be aware that some insurance companies exchange information through various databases, including the Claims and Underwriting Exchange (CUE) which holds a record of incidents reported to insurers, which may or may not have given rise to a claim. This exchange of information enables insurance companies to verify the information that is provided during the quote process (including information about any third party who is named on the policy), and also helps to prevent fraudulent claims.
If you deliberately misrepresent or provide false or inaccurate information and we suspect fraud we will record this on our own data bases and may exchange it with fraud prevention agencies or other authorities, for example the Police.
Retention of personal data
We will keep your clients’ personal data for so long as is necessary and for the purpose for which it was collected. In particular, for as long as there is any possibility that either you or we may wish to bring a legal claim or a complaint under your insurance, or where we are required to keep your personal data due to legal or regulatory reasons.
When we pass your clients’ personal data (including special categories of personal data) to insurers, their agents, intermediaries or other service providers you should be aware that they (including their affiliates or sub-contractors) may have offices located outside the European Economic Area (EEA). Transfer of your information should be made in compliance with the applicable data protection laws to ensure your information is properly protected. Your clients’ policy documents will set out how data is used and whether it might be transferred outside the EEA. You should also be aware that those parties and ourselves might use the services of digital storage providers because of the amount of data we collect and process. We ensure that appropriate measures are in place to ensure we only use the services of those providers who meet the standard expected in the applicable data protection laws.
When you visit our website, we may record information about your computer or mobile device, including hardware and software used, general location, when and how you interact with our websites. This information is used to note your interest in our website, improve customer journeys, and for anti-fraud purposes.
Your clients’ rights
Your clients have the right to:
- Object to us using their personal information. We will either agree to stop using it or explain why we are unable to.
- Ask for a copy of the personal information we hold about them (some exemptions apply)
- Ask us to update or correct their personal information to ensure its accuracy
- Ask us to delete their personal information if it is no longer needed for the original purpose
- Ask us to restrict the use of their personal information in certain circumstances
- Ask for a copy of their personal information so they can use it for their own purposes (data portability)
- Complain - if you are concerned about how we have used or processed your information or if you feel your personal information has been mishandled. You can write to us directly at Data Access Team, VM Insurance, Comfort House, 8 Goresbrook Road, Dagenham RM9 6UR or you can complain directly to the Information Commissioner’s Office (ICO), details can be found here (https://ico.org.uk/concerns/handling/)