This Customer Privacy Notice sets out the basis on which we collect personal data from you and explains how we use this information and who we share it with as well as your rights and how to exercise them.
We are committed to protecting and respecting your privacy. For the purposes of the relevant data protection legislation, the “data controller” who is responsible for this website is R K Henshall & Co Limited (UK Registered Company Number 1285024) of The Grove: Mill Lane: Wheelock: Sandbach: Cheshire: CW11 4RD.
Collecting and processing your personal data
As an insurance intermediary, we need to collect personal information for a variety of reasons.
We need identity and contact details (name, address, telephone numbers, email address) to communicate with you about your insurance needs.
We will collect financial information about you, and your assets and potential liabilities, to assess your insurance needs to enable us to approach providers for quotations, put insurance policies in place and facilitate the ongoing servicing of those policies.
Where appropriate, we may need to collect details to process payments from or to you such as bank account or payment card information.
In the event of a claim, we may be required to obtain additional personal information so that the matter can be properly considered. This could include information about other parties involved in an incident.
We will only use your personal data when the law allows us to. As such, we will only use your personal data in the following circumstances:
- For the performance of a contract: Our agreement with you to arrange insurance policies means that we must continue to use personal information. This includes obtaining renewal terms, making changes to your policy, submitting claims, or handling any premium adjustments or claims payments.
- Insurance: The Regulations allow the processing of certain ‘special category data’, such as health or criminal conviction data, if the processing is necessary for an insurance purpose.
- To meet a legal obligation: We are required to perform certain checks on customers, such as to confirm their identity or ensure there are no reasons why we should not do business with them. We may also be obliged to provide information to a court or regulatory body.
- Legitimate interests: The law allows us to hold or use personal information if we have a legitimate reason to do so. For example, having arranged your insurance, we will keep records in case any claim or potential dispute arises in the future so that we can establish the circumstances and, where appropriate, defend our position. Also, we may use your contact details to promote our services. Where we rely on this basis, we will balance our interests with your own rights under data protection laws. For example, we will maintain a policy so that we do not keep information longer that is reasonable.
- Consent: If no other legal basis applies, we may rely on your consent to use your personal data, for example to send marketing materials.
We may sometimes need to process personal information using automated decision-making by, or at the direction of, product providers. This involves assessment of the information provided to determine whether a product is offered and on what terms.
Automated decision-making could limit the range of products available to you. If you disagree with the outcome, you have the right to request a manual assessment of the information provided. Please contact us if you require this.
Additional personal information you may provide
If you provide information about other individuals, such as employees or family members, it is your responsibility to make them aware of this notice.
Other information we may collect about you
We may obtain personal information from other sources in relation to your insurance policies, for example previous and current insurers or brokers, loss adjustors and loss assessors. We require all such parties to comply with data protection legislation.
Who do we share your information with?
During the course of arranging and administration of your insurance, there are a number of situations where your personal information will be shared with other parties. These include:
- Where we obtain quotes, amend your policy, or make a claim we will forward information to product providers (insurers, managing agents or other intermediaries)
- Some product providers may appoint another party to administer the policy or respond to claims or complaints on their behalf
- Where you require us to apply to pay your premium in instalments, we will share relevant information with credit providers to obtain their terms
- Where we are required or permitted to do so by law or regulation, such as prevention of financial crime
- Where we provide services in partnership with another party
- With third party service parties unrelated to insurance, such as data hosting / storage providers or technology suppliers
- If we undergo a reorganisation, or if some, or all, of our business or assets change ownership, we may transfer your personal information to the successor company to ensure continuity of service.
Our agreements with third parties include requirements to comply with relevant data protection legislation so that your rights are maintained.
We will not send your personal information outside of the European Economic Area (EEA). However, some insurers may do so and will provide details in their own Privacy Notices.
We may use your contact details to keep you up to date with industry developments and insurance products that may be appropriate for you but we will only do this where Regulations permit us or where we have your permission to do so.
How long will we keep hold of your personal data?
We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
For most policies, we will retain records for up to seven years following expiry of the policy or termination of our services.
Some policies can be claimed against long after they have expired. We will retain records of these for longer than seven years based on the likelihood of any claim, complaint or dispute arising.
Where we have obtained your consent to hold personal information, we will retain it for as long as we have your consent, subject to the above timescales.
Data regulations and legislation provide you with certain rights over the personal information we hold.
- You can request that we provide you with a copy of the personal data that we hold about you (“Subject Access Request”).
- Where you believe personal information is no longer required you can request that it is deleted. (“Right to be Forgotten”). If we still have a legitimate basis for keeping it, such as servicing your policy, we may be unable to fulfil this request.
- If you believe that personal information that we hold about you is incorrect you can ask us to correct it (“Right to Rectification”).
- You may be able to request a restriction in the level of processing that we carry out on your data (“Restriction of Processing”). This is not an absolute right and only applies in certain circumstances.
- You can request a copy of personal information to be provided in a portable (electronic) format (“Data Portability”). We will endeavour to meet such requirements where the format is reasonable and in common use.
- You can object to our processing your personal data in certain ways (“Right to Object”).
- Where you have provided consent to receive marketing communications you can withdraw your consent at any time.
We aim to meet any requests promptly and as fully as possible. We may contact you to further understand your requirements in order to expedite your request. In some cases, we may be prevented from completing requests for legal reasons or due to conflicting legitimate interests. If this is the case, we will explain our reasons why.
There is no charge for requests for copies, amendments, or deletions of personal information. However, we reserve the right to charge where requests are unreasonably frequent or excessive.
Changes to this privacy notice & your duty to inform us of changes
This Privacy Notice will be updated from time to time and was last updated on 14th July 2023.023
It is important that personal data we hold about you is accurate and current. Please ensure that you keep us informed if your personal data changes during your relationship with us.
How to contact us
If you have any questions regarding this Privacy Notice or wish to make a request regarding your personal information, please contact:
The Data Protection Manager
R K Henshall & Co Ltd
The Grove Mill Lane
Cheshire CW11 4RD
You can also email us at: firstname.lastname@example.org
If you wish to make a complaint
If you are dissatisfied about the way we have handled your personal information and wish to complain, you should contact the Data Protection Manager using the details above. We will aim to investigate and respond promptly and will provide a written response.
If you remain dissatisfied, or believe that we are not handling your personal information in compliance with appropriate laws and regulations, you are entitled to raise your complaint with the Information Commissioner’s Office who can be contacted at:
Information Commissioner’s Office: Wycliffe House: Water Lane: Wilmslow: Cheshire:
Helpline number: 0303 123 1113 and ICO website: https://www.ico.org.uk