Perry Appleton Private Clients Privacy Notice (non-website)
Privacy Notice (also known as “Fair Processing Notice”)
Perry Appleton Private Clients Ltd. The Elms, 3 Newbold Road, Rugby, CV21 2LQ
Contact for queries:
Kevin Morris, Director
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
GDPR requires that we obtain your consent to obtain, use and retain your personal data. Under the Data Protection Act 2018, insurers and brokers have a legitimate interest for collecting personal data, including ‘special category data’ (see ‘what other types of information do we need?)
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
For what purpose do we need to process your data?
The legal basis for processing your data is that it is necessary for us to do so for the performance of a contract (an insurance policy or contract) – this could be an existing policy, arrangement, contract; or a new policy, arrangement, contract that you are about to enter in to. This is defined in the Data Protection Act, 2018 as a ‘legitimate interest’.
We will not collect any personal data from you we do not need in order to provide and oversee this service to you.
How we will use the information you give us.
We will only use your information on the basis that it is necessary to administer your insurance contract or help you make a claim. Where we need to pass information to other firms, it will only be for that purpose (see Sharing data with Third Parties).
When we contact you, it will either be for the above reason, or because we have a legitimate interest in marketing related products. For any other marketing, it will only be with your consent and you will be able to withdraw your consent or unsubscribe easily at any time.
If we have to transfer information to a third country outside the EEA, we will only do so if a similar level of protection applies. If we need to obtain information which is by nature sensitive, we will only do so on the basis that it is in the public interest - for example, to fight crime, prevent fraud or to make sure insurance is available.
What type of personal information do we need?
- We may need personal details which might include details of members of your family, lifestyle, finances, business or education.
- We will only collect what is necessary and will only keep it for as long as we are required to do in line with our data retention policy. You can ask us for a copy.
What other types of information do we need?
- Under certain circumstances, we may also need to obtain information about Race or Origin, Gender, Religion, Health, Politics, Genetics, Trade Union Membership, Sex or Sexual Orientation. We will only collect what is necessary, in line with the requirements of GDPR and the Data Protection Act 2018 Schedule 1, Part 2, Paragraph 20.
- We might also need details of criminal convictions. We will only collect what is necessary, with your consent, in line with the requirements of GDPR. This information will be retained for a maximum of 5 years.
How do we obtain your information?
- We may gather it from the information you submit to a website, in writing, by telephone, face to face or by email.
- If your information is collected via our website this consist of your contacts details only, via an online contact form.
- We may receive it from insurers, other insurance brokers, firms handling claims, finance providers, credit reference agencies, sanctions checking organisations, the disclosure and barring service and firms that process or store our records.
Sharing data with Third Parties
- We may share your personal data with third parties, as necessary to administer an insurance contract or help you make a claim. This could include insurers, other insurance brokers, firms handling claims, finance providers, credit reference agencies, sanctions checking organisations, the disclosure and barring service and firms that process or store our records.
What are my legal rights?
- You have the right to complain to the Information Commissioner at www.ico.org.uk, Tel 0303 123 11132.
- You can obtain a copy of your personal information from us without charge by contacting us at the address above. This may include the right to transfer information to other providers.
- You have the right to ask us to correct information.
- You have the right to ask us to delete your information or stop using it, unless it is necessary for us to retain it for insurance or financial purposes as set out in our document retention policy.
- You may have the right to object if decisions about you are made solely by a computer.