RCS, Removal Claims Service, Basil Fry & Company – The Removers’ Broker and Basil Fry & Company – Self Storage Risk Solutions are trading names of Basil E. Fry & Co. Ltd. (also referred to as “we”, “us”, or “our”). Basil E. Fry & Co. Ltd. is Authorised and Regulated by the Financial Conduct Authority. Basil E. Fry & Co. Ltd. is a limited company registered in England and Wales. Registered number: 1435130. Registered office: Swan House, Swan Centre, Bridge Street, Leatherhead, Surrey, KT22 8AH.
The purpose of this notice
This Notice is designed to help you understand what kind of information we collect in connection with our claims services and how we will process and use this information. In the course of providing you with our claims services we will collect and process information that is commonly known as personal data.
This Notice describes how we collect, use, share, retain and safeguard personal data.
This Notice sets out your individual rights; we explain these later in the Notice but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
What is personal data?
Personal data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, their gender and contact details.
Personal data may contain information which is known as special categories of personal data. This may be information relating to an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to or sexual orientation. Personal data may also contain data relating to criminal convictions and offences.
For the purposes of safeguarding and processing criminal conviction and offence data responsibly, this data is treated in the same manner as special categories of personal data, where we are legally required to comply with specific data processing requirements.
Personal data we collect
In order for us to handle claims for you we will collect and process personal data about you.
We may also need to collect personal data relating to others in order to arrange and administer insurance, including other owners of your business, employees and, where relevant, associated family members. In most circumstances, you will provide us with this information. Where you disclose the personal data of others, you must ensure you are entitled to do so.
You may provide us with personal data when you contact us via the telephone, when writing to us directly or where we provide you with forms for completion.
We will share your personal data within our firm, including, Accounts and Claims departments. This is normal practice within the insurance industry where it is necessary to share information in order to process claims and administer our business.
We also share personal data with authorised third parties, this is necessary where we are required to do so by law, where we need to administer our business and where necessary to handle your claim. This would include insurers and appointed loss adjusters.
We may collect your personal data when you visit our website, where we will collect your unique online electronic identifier; this is commonly known as an IP address.
We may also collect electronic personal data when you first visit our website where we will place a small text file that is commonly known as a cookie on your computer. Cookies are used to identify visitors and to simplify accessibility, and to monitor visitor behaviour when viewing website content, navigating our website and when using features.
We may record your telephone communications with us Our calls are recorded for training and monitoring purposes throughout our Broking, Accounts and Claims departments, however bank details are not recorded.
Where we collect data directly from you, we are considered to be the controller of that data i.e. we are the data controller. Where we use third parties to process your data, these parties are known as processors of your personal data. Where there are other parties involved in underwriting or administering your insurance they may also process your data in which circumstance we will be a joint data controller of your personal data.
A data ‘controller’ means the individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data. A data ‘processor’ means the individual or organisation which processes personal data on behalf of the controller.
As a provider of insurance services, we will process the following categories of data:
- Personal data such as an individual’s name, address, date of birth, gender, contact details and details of historic claims
- Special categories of personal data such as health and details on historic claims resulting in injury (physical and physiological)
- Data relating to criminal convictions and offences such as details of driving offences or insurance fraud
If you object to the collection, sharing and use of your personal data we may be unable to provide you with our claims services
For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the named territory where the processing of personal data takes place.
If you require more information about our claims processes or further details on how we collect personal data and with whom we share data with, please contact our Data Privacy Representative.
Why do we need your personal data?
We will use your personal data to process claims and to process complaints.
We will use the special category and criminal conviction data we collect about you for the purposes of handling your claim, which is deemed to be necessary for reasons of substantial public interest.
The retaining of data is necessary where required for contractual, legal or regulatory purposes or for our legitimate business interests and product development.
We will retain your personal data for varying periods of time depending on the type of claim the data relates to in line with relevant laws. Where you have submitted a claim, we will usually retain your data for a period of six years. Where you make a complaint, we will retain the data for two years. Where you or law enforcement agencies inform us about any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data.
Sometimes we may need to retain your data for longer, for example if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future claim may occur.
Please contact our Data Privacy Representative if you object to the use of, or you have any questions relating to the use of, your data, the retention of your personal data.
International transfers of personal data
Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.
These rights are known as Individual Rights under the Data Protection Act 2018. The following list details these rights:
- The right to be informedabout the personal data being processed;
- The right of accessto your personal data;
- The right to objectto the processing of your personal data;
- The right to restrictthe processing of your personal data;
- The right to rectification of your personal data;
- The right to erasure of your personal data;
- The right to data portability(to receive an electronic copy of your personal data);
- Rights relating to automated decision-making including profiling.
Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests, however if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.
In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request, for example if you make a request for us to delete all your personal data, we may be required to retain some data for taxation, prevention of crime and for regulatory and other statutory purposes.
You should understand that when exercising your rights, a substantial public or vital interest may take precedence over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health related matters.
The flow of data within the insurance sector is complex and we ask you to keep this in mind when exercising your ‘rights of access’ to your information. Where we may be reliant on other organisations to help satisfy your request this may impact on timescales.
If you require further information on your Individual Rights or you wish to exercise your Individual Rights, please contact our ‘data privacy representative’ using the details provided below.
Protecting your data
We will take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data within our firm and authorised third parties.
Data Privacy Representative
To ensure data privacy and protection has appropriate focus within our organisation we have a Data Privacy Representative who reports to our senior management team. The Data Privacy Representative may be contacted using our usual contact details provided below.
If you are dissatisfied with any aspect of the way in which we process your personal data please contact our Data Privacy Representative. You also have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office (ICO). The ICO may be contacted via its website which is https://ico.org.uk/concerns/, by live chat or by calling their helpline on 0303 123 1113.
How to contact us
If you have any questions regarding this Notice, the use of your data or your Individual Rights please contact our ‘data privacy representative’ using the following details:
Data Privacy Representative, Basil Fry & Company, Swan House, Swan Centre, Leatherhead, Surrey, KT22 8AH, United Kingdom
Telephone: +44 (0) 1372 385 985
Special Insurer Requirements
Lonham Marine Underwriters (Chaucer Syndicate 1084) require us to provide a special notice to all clients, customers and claimants who are protected by policies underwritten by them. This is detailed below. If you are unsure if this applies to you, please contact your usual claims contact or our Data Privacy Representative.
Your personal information notice
Who we are
We are the Lloyd’s underwriting agent identified in the contract of insurance and/or in the certificate of insurance.
We and other insurance market participants collect and use relevant information about you to provide you with your insurance cover or the insurance cover that benefits you, or in connection with a claim and to meet our legal obligations.
This information includes details such as your name, address and contact details and any other information that we collect about you in connection with the insurance cover from which you benefit. This information may include more sensitive details such as information about your health and any criminal convictions you may have.
In certain circumstances, we may need your consent to process certain categories of information about you (including sensitive details such as information about your health and any criminal convictions you may have). Where we need your consent, we will ask you for it separately. You do not have to give your consent and you may withdraw your consent at any time. However, if you do not give your consent, or you withdraw your consent, this may affect our ability to provide the insurance cover from which you benefit and may prevent us from providing cover for you or handling your claims.
The way insurance works means that your information may be shared with, and used by, a number of third parties in the insurance sector for example, insurers, agents or brokers, reinsurers, loss adjusters, sub-contractors, regulators, law enforcement agencies, fraud and crime prevention and detection agencies and compulsory insurance databases. We will only disclose your personal information in connection with the insurance cover that we provide and to the extent required or permitted by law.
Other people’s details you provide to us
Where you provide us or your agent or broker with details about other people, you must provide this notice to them.
Want more details?
For more information about how we use your personal information please see our full privacy notice(s), which is/are available online on our website(s) or in other formats on request.
Contacting us and your rights
You have rights in relation to the information we hold about you, including the right to access your information. If you wish to exercise your rights, discuss how we use your information or request a copy of our full privacy notice(s), please contact us, or the agent or broker that arranged your insurance. Our contact details are:
Diane Stannard, Lonham Group Ltd, 81 Grimwade Street, Ipswich, Suffolk, IP4 1LN. Tel: 01473 216116. Fax: 01473 230063. E-mail: firstname.lastname@example.org
25 April 2018