Insurance First Brokers Limited is committed to protecting your privacy
In this Privacy Notice the terms, 'we', 'us' and 'our' are references to Insurance First Brokers Limited (Insurance First), company number 2169477, having a registered address of Floor 2, Gateway 2 Holgate Park Drive, York, England, YO26 4GB. Insurance First is part of the LSL Group of companies of which the ultimate parent company is LSL Property Services plc (LSL Group). Insurance First is also an Appointed Representative of PRIMIS Mortgage Network a trading name of First Complete Limited (Our Network).
This Privacy Notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it, including:
- What information is being collected if you are a prospective or existing customer?
- In what circumstances will your Special Data and Criminal Disclosures be collected?
- The basis upon which we deal with your information
- The basis upon which Our Network will deal with your information
- Use of the information we collect
- What is the source of the information we collect?
- Data retention
- Disclosure of information
- Your rights
Your privacy is important to us, and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws.
If you do not agree with any part of this Privacy Notice, you should not use our services.
We reserve the right to change the contents of this Privacy Notice at any time, by posting such changes on our website (www.insurance-first.co.uk) (Our Site). It is your responsibility to familiarise yourself with the Privacy Notice regularly to ensure that you are aware of any changes. Your continued use of Our Site following the posting of any such changes will constitute your acceptance of the revised Privacy Notice.
WHAT INFORMATION IS BEING COLLECTED IF YOU ARE A PROSPECTIVE OR EXISTING CUSTOMER?
We will collect personal information from you when we provide you with assistance in relation to your insurance requirements, including personal information such as:
- your title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and any other identity documents as are necessary to verify your identity and the results of any identity checks which we carry out;
- employment and remuneration information (including salary/bonus schemes/overtime/sick pay/other benefits) including your employment history;
- bank account details, tax information, loans and credit commitments, personal credit history, national insurance number, sources of income and expenditure, family circumstances and details of dependents;
- confirmation of whether or not you smoke and alcohol consumption levels;
- any pre-existing insurance products and the terms and conditions relating to these; the results of credit reference checks;
- details of the type of protection product you require where you are receiving advice from us;
- details provided to us by the underwriter of your policy relating to any claims made by you once your policy is live. This allows us to monitor claims handling processes and ensure we have the information we need to assist you with the renewal of your policy; and
- responses and feedback which you provide to us in customer surveys, in order that we can monitor the quality of the service we provide and make improvements.
IN WHAT CIRCUMSTANCES WILL YOUR SPECIAL DATA AND CRIMINAL DISCLOSURES BE COLLECTED?
We may collect personal information from you which is of a sensitive nature. Where we do so we treat this information in accordance with the additional protection it is given under data protection laws. Where you ask us to help you with your insurance needs, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (including the health and medical history of your family where appropriate) (Special Data). We will record and use your Special Data in order to make enquiries of insurance providers in relation to insurance products that may meet your needs and to provide you with advice regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 16 it is also very likely that we (and consequently Our Network) will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current driving related criminal convictions or offences (together Criminal Disclosures). This is relevant to insurance related activities such as underwriting, claims and fraud management.
When we process your Special Data and any Criminal Disclosures we do so on the basis that it is in the substantial public interest to be able to provide vital insurance products as permitted by UK data protection related laws and regulations from time to time. Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as us and insurance providers, to enable customers to secure the important insurance protection that they require.
THE BASIS UPON WHICH WE DEAL WITH YOUR INFORMATION
When we speak to you about your insurance requirements we do so on the basis that a contract for the supply of services has been formed between us. In order to perform that contract, and to arrange the products you require, we have the right to use your information for the purposes we set out below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use your information provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from insurance providers and Our Network relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use your information to enable us to meet any contractual responsibilities we may owe Our Network, or for wider compliance with any legal or regulatory obligation to which we might be subject.
THE BASIS UPON WHICH OUR NETWORK WILL DEAL WITH YOUR INFORMATION
Our Network is authorised and regulated by the Financial Conduct Authority (FCA). Our Network is responsible for the quality of the advice that we provide to you in relation to your mortgage, protection and/or insurance products, where those products are regulated by the FCA. In the course of doing so, Our Network will process your information, including your Special Data and Criminal Disclosures.
In the course of handling your information and your Special Data/Criminal Disclosures, Our Network will:
- record and store your information and your Special Data/Criminal Disclosures on Our Network systems run on secure servers. Your information and your Special Data/Criminal Disclosures will be accessed by authorised employees and consultants within, or engaged, by Our Network as necessary for the purposes of supervision, training, quality audits, customer surveys and complaint handling or otherwise to comply with any other legal or regulatory obligation Our Network may have;
- use, and where appropriate transmit, your information and your Special Data/Criminal Disclosures to respond to any request from the FCA, the Financial Ombudsman Service, HMRC, the ICO or any other regulatory, law enforcement or governmental body; and
- need to access and process your information and your Special Data/Criminal Disclosures to deal with enquiries received from insurance providers that relate to the service we have provided to you, including the payment of any commission or fees to us that may be linked to the product you have taken out.
Your information and your Special Data/Criminal Disclosures will be retained by Our Network either electronically or in paper format for a minimum of six years and possibly for a longer period where this is required to enable Our Network to fulfil its legal and regulatory obligations.
USE OF THE INFORMATION WE COLLECT
Your information will be used by us in connection with the following purposes:
Providing You with Services:
- To allow us to provide you with the insurance services which you have asked us to provide, including:
- offering you advice;
- obtaining quotes;
- assisting you with applications for products by submitting your information to product providers both in paper form and online via provider systems in order to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that the providers may raise; and
- keeping you informed of any developments in relation to any product which we help you to take out;
- to keep our client records up to date;
- to improve our services by analysing your personal information so we better understand how you use our services;
Responding to Your queries:
- to help answer any questions which you have asked one of our agents or staff members;
- to provide you with a quote for our services;
Legal and Regulatory Obligations:
- to comply with applicable laws where we are obliged to retain and/or disclose certain information;
- to investigate or address claims or complaints relating to your use of our services;
- to upload your information along with full details of the product, discussed with you or which you have taken out, to the computer systems of Our Network;
- for internal and external auditing purposes;
- to carry out anti-money laundering checks; and
- to transfer information to any entity which may acquire rights in us.
WHAT IS THE SOURCE OF THE INFORMATION WE COLLECT?
The majority of the personal information which we collect will have been voluntarily provided by you, however we may also obtain your personal data from other sources including:
- other LSL Group companies;
- third parties including credit reference agencies and law enforcement/regulatory bodies;
- introducers who have referred you to us for the delivery of services;
- your mortgage advisor, estate agent, solicitor and/or mortgage provider; and
- other publically available sources such as the electoral roll and HM Land Registry.
The personal information that you provide will be retained by us in accordance with applicable laws and our internal Retention Policy. However, we will take reasonable steps to destroy or de-identify personal information we hold if it is no longer needed for the purposes set out above. We will only hold your personal information on our systems for as long as is necessary for the relevant purpose for which it was collected. A copy of our Retention Policy is available on request.
DISCLOSURE OF INFORMATION
The information you provide to us will be held on our computers in the UK and may be accessed by or given to our staff or to any member of the LSL Group for the purposes set out in this Privacy Notice or for other purposes approved by you. We may also provide your personal information to other companies within the LSL Group for the purposes of administering our business or where services are provided by one group company to another pursuant to an intra-company services agreement.
We may also disclose your information to the third parties listed below for the following purposes:
- insurers for the purpose of providing us or you with a quotation and to allow them to process your application;
- law enforcement bodies and/or other regulatory entities in order to comply with any legal obligation or court order;
- third parties and their associated companies and sub-contractors we work with as part of providing our services and performing any administration tasks associated with or incidental to those services, including (but not limited to):
- IT administrators;
- software providers; and
- payment service providers;
- our professional advisers, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
- third parties as necessary in the event of a claim or dispute relating to the use of our services;
- your mortgage advisor, estate agent, solicitor and/or mortgage provider where they referred you to us for insurance services, for the purpose of providing them with progress and/or status updates on the services which we are providing to you and/or to liaise with them on your behalf;
- Our Network to allow them to monitor the advice which we provide to you; and
- entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation.
These parties may be located in the UK or elsewhere in the world where different privacy laws may apply which may not offer the same level of protection as UK law. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country and that the service provider acts at all times in compliance with applicable privacy laws.
We employ security measures which aim to protect the information provided by you from access by unauthorised persons and against unlawful processing, accidental loss, destruction or damage.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is sent to us.
You can request copies of your personal information within our custody and control and details of how we use that information. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You can request an electronic copy of your personal data be sent to you, or to another organisation should you wish. You also have a right to require us to stop processing your personal information and/or to withdraw your agreement to processing based on 'consent', unless we have a legal justification for doing so. If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint.
If you have questions or comments about our Privacy Notice or if you wish to exercise your right to access, correction or erasure mentioned above, please contact our Data Protection Officer by:
Email: firstname.lastname@example.org ;
Post: Data Protection Officer, Newcastle House, Albany Court, Newcastle Business Park, NE4 7YB; or
Telephone: 0191 233 4600.
If you have any concerns or complaints as to how we have handled your personal data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.