Fair Processing Notice
The privacy and security of your information is important to us. This notice explains who we are, the types of information we hold, how we use it, who we share it with and how long we keep it.
It also informs you of certain rights you have regarding your personal information under current data protection law. The terms used in this Fair Processing Notice relate to the Information Commissioner’s Office guidance.
Who are we?
GEO Underwriting Services Limited trading as Lutine or Lutine Assurance Company (part of the Ardonagh Group of companies) is the Data Controller of the information you provide us and is registered with the Information Commissioner’s Office for the products and services we provide to you.
You can contact us for general data protection queries by email to MGA.DataProtection@geounderwriting.com or in writing to The Data Protection Officer, care of MGA Compliance, The Ardonagh Group, 2 Minster Court, Mincing Lane, London, EC3R 7PD. Please advise us of as much detail as possible to help us comply with your request.
For further information about the Ardonagh Group of companies please visit http://www.ardonagh.com/.
What information do we collect?
We will collect personal information which may include your name, telephone number, email address, postal address, occupation, date of birth, additional details of risks related to your enquiry or product and payment details (including bank account number and sort code) which we need to offer and provide the service or product or deal with a claim.
We may need to request and collect sensitive personal information such as details of convictions or medical history that are necessary for providing you with the product, service or for processing a claim.
Insurance involves the use and disclosure of your personal data by various insurance market participants such as intermediaries, insurers, and reinsurers. The London Insurance Market Core Uses Information Notice sets out their core necessary personal data uses and disclosures. Please ensure you also review this notice.
We only collect and process sensitive personal data where it is critical for the delivery of a product or service and without which the product or service cannot be provided. We will therefore not seek explicit consent to process this information as the processing is legitimised by its criticality to the service provision. If you object to use of this information, then we will be unable to offer you the product or service requested.
How do we use your personal information?
We will use your personal information to
- assess and provide the products or services that you have requested
- communicate with you
- develop new products and services
- undertake statistical analysis
We may also take the opportunity to
- contact you about products that are closely related to those you already hold with us
- provide additional assistance or tips about these products or services
- notify you of important functionality changes to our websites
We make outbound phone calls for a variety of reasons relating to many of our products or services (for example, to update you on the progress of a claim or to discuss renewal of your insurance contract). We are fully committed to the regulations set out by Ofcom and follow strict processes to ensure we comply with them.
To ensure confidentiality and security of the information we hold, we may need to request personal information and ask security questions to satisfy ourselves that you are who you say you are.
We may aggregate information and statistics on website usage or for developing new and existing products and services, and we may also provide this information to third parties. These statistics will not include information that can be used to identify any individual.
Securing your personal information
We follow strict security procedures in the storage and disclosure of your personal information in line with industry practices, including storage in electronic and paper formats.
We store all the information you provide to us, including information provided via forms you may complete on our websites, and information which we may collect from your browsing (such as clicks and page views on our websites).
Any new information you provide us may be used to update an existing record we hold for you.
When do we share your information?
To help us prevent financial crime, your details may be submitted to fraud prevention agencies and other organisations where your records may be searched, including the Claims and Underwriting Exchange (CUE) and the Motor Insurers Anti-Fraud and Theft Register (MIAFTR).
In addition to companies within the Ardonagh Group, third parties (for example insurers or loss adjustors) deliver some of our products or provide all or part of the service requested by you. In these instances, while the information you provide will be disclosed to these companies, it will only be used for the provision and administration of the service provided (for example verification of any quote given to you or claims processing, underwriting, and pricing purposes or to maintain management information for analysis).
This may also include conducting a search with a credit reference bureau or contacting other firms involved in financial management regarding payment.
The data we collect about you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for us or for one of our suppliers. Such staff may be engaged in, amongst other things, the provision of information you have requested.
If we provide information to a third party, we will require it and any of its agents and/or suppliers to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this fair processing notice.
We may of course be obliged by law to pass on your information to the police or other law enforcement body, statutory or regulatory authority including but not limited to the Employer’s Liability Tracing Office (ELTO) and the Motor Insurance Bureau (MIB).
We may also share your information with anyone you have authorised us to deal with on your behalf.
How long do we keep your information for?
We will not keep your personal information longer than is necessary for the purpose of which it was provided unless we are required by law or have other legitimate reasons to keep it for longer (for example if necessary for any legal proceedings).
We will normally keep information for no more than 6 years after termination or cancellation of a product, contract, or service we provide. In certain cases, we will keep your information for longer, particularly where a product includes liability insurances or types of insurance for which a claim could potentially be made by you or a third party at a future date, even after your contract with us has ended.
Under data protection law you have the right to change or withdraw your consent and to request details of any personal data that we hold about you.
Where we have no legitimate reason to continue to hold your information, you have the right to be forgotten.
We may use automated decision making in processing your personal information for some services and products. You can request a manual review of the accuracy of an automated decision that you are unhappy with.
Further details of your rights can be obtained by visiting the Information Commissioner’s Office website at https://ico.org.uk/.