Welcome to the privacy notice for Barbican Insurance Group (Barbican).
Barbican respects your privacy and is committed to protecting your personal data. This privacy notice tells you how we look after your personal data, your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy Notice
This privacy notice aims to give you information on how Barbican collects and processes your personal data.
Insurance involves the use and disclosure of your personal information by various insurance market participants such as intermediaries, insurers and reinsurers. The London Insurance Market Core Uses Information Notice sets out those core necessary personal data uses and disclosures. Our core uses and disclosures are consistent with the London Market Core Uses Information Notice. We recommend you review that notice in conjunction with this privacy notice
Barbican Holdings (UK) Limited and its subsidiaries are members of the Barbican Insurance Group of Companies. This privacy notice is issued on behalf of the Barbican Group so references to Barbican, “Company”, “we”, “us” or “our” are references to the company in the Barbican Group responsible for processing your data. Barbican is the controller and responsible for this website.
Our full details are:
Full name of legal entity: Barbican Holdings (UK) Limited
Name and title of Data Protection Officer (DPO): Simon Godsave, Group Head of Compliance and Risk
Email address: email@example.com
Postal address: 33 Gracechurch Street, London, EC3V 0BT
Tel: +44 (0)20 7082 1955
You may make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO.
Changes to this Notice
This version of this notice was last updated in May 2018 and will be kept under review.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Types of Personal Data
We may collect, use, store and transfer the following different kinds of personal data about you:
- Name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to you.
- Identification numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving licence number.
- Bank account or payment card details, income or other financial information.
- Information about you which we need to collect in order to assess the risk to be insured and provide a quote. This may include data relating to your health, criminal convictions, or other special categories of personal data. For certain types of policy, this could also include telematics data.
- Information about the quotes you receive and policies you take out.
- Credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to you.
- Information about previous and current claims, (including other unrelated insurances), which may include data relating to your health, criminal convictions, or other special categories of personal data and in some cases, surveillance reports.
Certain categories of personal data have additional protection under the GDPR. The categories are health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation.
How personal data is collected
We use different methods to collect data from and about you including:
- Through Indirect interactions. Barbican mainly conducts business via brokers so personal data provided to them may be provided to us in order to provide our products
- Through direct interactions for example filling in forms or corresponding with us by post, phone, email or otherwise.
- If you apply for employment, either via the website or other routes;
- If you request marketing material; orIf you give us some feedback.
We may also receive personal data about you from various third parties and public sources such as:
- Other insurance market participants.
- Credit reference agencies.
- Anti-fraud databases, sanctions lists, court judgments and other databases.
- Government agencies.
- Open electoral register.
- In the event of a claim, third parties including the other party to the claim, witnesses, experts (including medical experts), loss adjustors, solicitors and claims handlers
If you do not provide necessary personal data
Where we need to collect personal data by law, or under the terms of a contract (actual or proposed) and you fail to provide that data when requested, we may not be able to perform or enter into the contract. In this case, we may have to cancel or not offer a product or service but we will notify you in that event.
3. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
The table below sets out all the ways we plan to use your personal data, and the legal bases on which we will rely on to do so. We have also identified what our legitimate interests are where appropriate.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new client||(a) Identity|
|Performance of a contract with you|
|To process and deliver our products and services including:|
(a) Manage payments, fees and charges
(b) managing (re)insurance claims, defending or prosecuting claims and investigation or prosecution of suspected or actual fraud
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to ensure only valid claims are paid)
|To manage our relationship with you||(a) Identity|
(d) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To receive and manage expressions of your interest in employment with Barbican||(a) Identity|
|Performance of an employment contract with you|
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact Barbican’s DPO.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us.
Third Party Marketing
We will obtain your express opt-in consent before we share your personal data with any company outside the Barbican group of companies for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us at any time at firstname.lastname@example.org.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Cookies may be used by the Website to allow us to recognise you and your preferred settings e.g. to store your ID and password for future sessions. This saves you from re-entering information on return visits to the Website. You have the option not to use this feature, in which event no cookies will be retained on your computer.
If the site has a secure log-in for our registered users, it may use a temporary ’session cookie’ in order to perform the secure login to our website. This cookie contains no personal information, just a long random number, and is deleted from your web browser when you exit the Website.
Temporary cookies are used in the transactional part of the Website to authenticate you as an authorised user after you have logged in.
Your browser may be capable of being programmed to reject cookies, or to warn you before downloading cookies, and information regarding this may be found in your browser’s ‘help’ facility.
For an explanation of cookies see the All About Cookies website.
Below is a table of all cookies on this website – their name, type and purpose:
|Cookie Type||Cookie Name||Cookie Purpose|
|Session & TYPO3 Content Management Cookie||Session & fe_typo_user||We use session cookies to record an individual users preferences that the user has specified, so that each time the user returns their preferences remain. Commonly this would be language settings, shopping carts, anything where you have indicated a preference. Where forms are used on the site, we hold the information in a session cookie so that we can improve the user experience on the site. Should a user, for example, forget to fill in parts of a form when submitting a form, we can auto-fill the values for those fields that have been filled in, thereby reducing the amount of fields a user needs to amend. This information is stored only in your browser and is destroyed once your browser is closed.|
|Google Analytics||_ga _gat _gid||These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site for you. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.|
|Cookie Preference||cookiePolicy||This cookie is used to remember a user’s choice about cookies on this website. Where users have previously indicated a preference, that user’s preference will be stored in this cookie.|
We use third party companies as suppliers for some of our functions. Their use of the data is controlled by our contract with them and they are only allowed to use the data strictly for the purpose we have stated e.g. the data is not used in connection with data from other companies and we are not tracking user behaviour outside our own sites.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties.
- External Third Parties.
- Specific third parties
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. INTERNATIONAL TRANSFERS
We share your personal data within the Barbican Insurance Group. This may involve transferring your data outside the EEA.
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact Barbican’s DPO if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. DATA RETENTION
We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Where you make an employment enquiry we will generally delete any personal data you provide within 6 months should such an inquiry not result in an employment contract, unless we believe it is reasonably necessary to retain the data for a different period.
10. YOUR RIGHTS
Depending on the information we hold about you, and the reason for holding it, you have certain rights under data protection laws which are set out below:
- Request access to your personal data
You will generally not have to pay a fee to access your personal data unless your request is clearly unfounded, repetitive or excessive, in which case we may charge a reasonable fee or refuse to comply with your request.
- Request correction of your personal data.
You are entitled to have your records amended if the personal data we hold is inaccurate or incomplete.
- Request erasure of your personal data.
You have a right to request your data is deleted in certain circumstances, i.e. where it is no longer needed for the purposes it was collected; the (rare) occasions where consent is relied upon as the lawful basis for processing, it is withdrawn and there is no other lawful basis for our continuing to process it; you object to the processing (see below) and there are no overriding legitimate grounds to continue; where the data has been unlawfully processed; or where it has to be erased for compliance with a legal obligation.
- Object to processing of your personal data.
You may object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights.
- Request restriction of processing your personal data.
You may ask us to restrict how we use your personal data while we investigate a complaint. Request transfer of your personal data.
- Transfer of Data
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent.
Where processing is based on consent, you may withdraw your consent so that we stop that particular processing
If you wish to exercise any of the rights set out above, please contact Barbican’s DPO.
What we may need from you to deal with your request
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We aim to respond to legitimate requests without undue delay, and usually within one month. It may take longer than a month if your request is particularly complex or you have made a number of requests, but in that this case we will notify you.