Privacy Policy

Introduction

Welcome to Eggar Forrester Insurance Limited’s privacy policy.

Eggar Forrester Insurance Limited respects your privacy and is committed to protecting your personal data. This data will be provided by you, or any other person you may appoint to provide us with information. This privacy policy will inform you as to how we look after your personal data when you engage with our business, including when you visit our website (regardless of where you visit it from), and will tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Eggar Forrester Insurance Limited collects and processes your personal data.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them.

Controller

Eggar Forrester Insurance Limited is the controller and responsible for your personal data (collectively referred to as “Eggar Forrester Insurance”, “EFI”, “we”, “us” or “our” in this privacy policy).

We have appointed a Compliance Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Compliance Manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Eggar Forrester Insurance Limited
Name of data privacy manager:  Rakesh Zaveri
Email address: insurance@eggarforrester.com
Postal address: Fifth Floor, 2 London Wall Buildings, London, England, EC2M 5PP
Telephone number: 0207 382 7710

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes
This version was last updated on 25 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes full name, marital status, title, date of birth, civil status, current and or previous occupation, registration number, national insurance number, next of kin information and gender.

Contact Data includes postal address, risk address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of services you have purchased from us, as well as your claims history.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may also collect the following Special Categories of Personal Data about you: your physical or mental health details, religious or other beliefs, racial or ethnic origin, political opinions, sex life or sexual orientation, driving licence origin, UK residency period or  trade union membership.

We request information about criminal convictions and offences as required by insurers to source your insurance policy. We will only collect this information where we are permitted to do so by UK Law.

Although this website is not intended for children, we sometimes collect personal data relating to children under the age of 16, for the purpose of providing travel insurance policies. We will only collect this information with the express consent of the child’s verified parent or guardian and will use the parent or guardian’s Contact Data for all related correspondence.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with insurance or services). In this case, we may have to cancel an insurance policy you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Respond to our direct pre-contractual enquiries;

Contract with us to provide insurance services;

Complete a contact form on our website; or

Complete and return to us an application form.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

Technical Data from analytics providers such as Google based outside the EU;

Identity and Contact Data from the following parties:

third party introducers including but not limited to Coreco Mortgage Brokers, Douglas & Gordon Estate Agents, D&G Block Management, Athena Advisers, Tod Anstee Estate Agents and Hayes Mortgage Advisors based inside the EU;

network contacts such as Child & Child and JLO solicitors based inside the EU; and

if you are an additional named party on an insurance policy, the policy holder.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Where it is necessary for us to comply with legal and regulatory requirements.

Generally we do not rely on consent as a legal basis for processing your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Legal basis for processing including basis of legitimate interest
To provide you with an insurance quote (a) Identity

(b) Contact

(c) Special Category Personal Data

Necessary for our legitimate interests (to grow our business)
To register you as a new customer (a) Identity

(b) Contact

Performance of a contract with you
To deliver services to you, including:

(a) Place you on cover

(b) Manage payments, fees and charges

(c) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To make any alterations to your policy that you may request during the policy term (a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Relevant Special Category Personal Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to keep our records updated)

To manage our relationship with you which will include:

(a) Notifying you about changes to our services, terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our property services)

To make suggestions and recommendations to you about insurance services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

Necessary for our legitimate interests (to develop our services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact and Technical Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Eggar Forrester Insurance for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below, for the purposes listed beside them.

Third Party Purpose for which personal data is shared
Insurers (a) To provide a quotation

(b) To provide insurance cover

(c) To manage and progress claims

Insurance Providers (for example: Placing Brokers, Delegated Authority Schemes and Wholesalers) (a) To provide a quotation

(b) To provide insurance cover

(c) To manage and progress claims

Loss Adjusters To manage and progress claims
Insurance Fraud Bureau To investigate potential policy fraud
Loss Assessor To manage and progress claims
Financial Conduct Authority To comply with regulatory obligations
Financial Services & Compensation Scheme To provide compensation in the event of an insurer failure, if the claiming individual is eligible
Financial Ombudsman Service To deal with unresolved complaints
National Crime Agency To report with suspected criminal or fraudulent activity
HM Treasury Sanctions To check that prospective clients are not on the prohibited list
Premium Finance Company To enable the payment of premiums
Police To comply with legal obligations
Suppliers, including but not limited to Jewellers, Cleaning Companies, Restoration Companies, approved Repairers and Garages, Windscreen Replacement Companies, Plumbers, Builders and Electricians To provide replacement goods or services available to clients under their insurance policies
Claims Management Company To manage and progress claims
Surveyor (a) To provide a risk survey to report upon risk pre-cover.

(b) To provide a survey post-loss

 

Debt Agency To collect unpaid premiums which  have fallen due
IT Providers – Software (a) The provision of collective management information system testing

(b) Responding to system errors

IT Providers – Hardware, Cloud & Systems Management (a) To detect technical issues, and secure and test the system

(b) To provide data backup services

Interested Parties, including but not limited to Mortgage Lender) To provide proof of cover
Third Party Insurers To manage and progress claims
Third Party Assessor To manage and progress claims
Claims Management Company To manage and progress claims
Credit Reference Agencies To obtain competitive premiums
Mylicence (UK) To meet legislative requirements
DVLA To meet legislative requirements
Motor Insurers Database Registering vehicles to meet legislative requirements
Motor Insurers Bureau To meet legislative requirements
Claims Exchange Underwriting To facilitate the sharing of previous claims information between insurers
Employers Liability Tracing Office To provide confirmation of cover being in place
Our own Insurers Where we are required to provide information about you under the terms of our insurance policies
Solicitor To pursue any claims we may bring against our clients or to defend any claims bought against us
Interpreter To manage your policy and claims if there is a langue barrier or if sign language is required

We may also share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require any third parties which we have contracted with to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

At all times we will endeavour to hold your Data on servers within the UK, or within the European Economic Area (EEA). However, some of our external third parties may transfer your personal data outside of the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where we use certain service providers, we may use contracts which give personal data the same protection it has in Europe; and

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.