We understand the Importance of maintaining your privacy, keeping your personal information secure and complying with data protection laws.
We may collect information from you about other people, for example family members or colleagues. If you give us information about another person, it is your responsibility to ensure and confirm that:
- you have told the individual who we are and how we use personal information, as set out in this privacy notice and
- you have permission from the individual to provide that personal information to us and for us to use it, as set out in this privacy notice.
We only collect and store your Information where we have lawful grounds and legitimate reasons to do so.
We collect, use and store your personal information in order to fulfill requests for quotes, products and services as part of our insurance broking, claims handling and risk management business.
It may also be used to verify your identity, to process payments and to enable us to carry out sanction, anti-money laundering and other financial crime checks, as required. If you pay by instalments, your information may also be used to arrange credit.
The use of your data is essential to enable you to enter into an insurance contract and for it to operate, such as in the event of a claim. If you do not provide the information required, we are unlikely to be able to provide accurate advice or arrange your insurances or provide certain other services to you.
We may monitor emails and other communications with you and when you contact us, we will keep a record of that correspondence and any information provided to us in that or subsequent communications.
Under data protection laws, for each purpose we must be able to rely on a legal ground to justify why we are using your (non-sensitive) personal information. The legal grounds that we may rely on are:
|For processing (non sensitive) personal Information|
|Performance of our contract with you||Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract|
|Compliance with a legal obligation||Processing is necessary for compliance with a legal obligation to which we are subject|
|For our legitimate interests where these do not cause you undue harm||Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information.
Our main legitimate interests for using your personal information are:
When we use your sensitive personal information (for example information about your religious beliefs, criminal convictions, political opinions or health) we must be able to rely on an additional legal ground. The additional legal grounds that we may rely on in these instances are:
|For processing sensitive personal Information|
|Substantial public Interest||Processing is necessary for insurance purposes.|
|Your explicit consent||You have given your explicit consent to the processing of your sensitive personal information for one or more specified purposes.
You may withdraw your consent at any time by contacting us. If you do so, you may not be able to receive the benefit of some of our services where in order to provide them, we rely on your explicit consent to process your sensitive personal information.
|For legal claims||Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity|
|You have made this information public||You have made your sensitive personal information manifestly public.|
Personal information is any information that may identify a living individual. We collect personal information such as name, email addresses, telephone numbers, date of birth, financial details, IP addresses, or employment details, depending on the nature of the insurance or service we are arranging.
We may collect, use and store sensitive personal information (so called special categories of data}, such as criminal convictions, medical conditions or information about your religious beliefs (for example, where you have expressed a specific dietary requirement which is indicative of such beliefs) as necessary in relation to insurances or risk management activity. This information may be shared with insurers and other third party service providers. Where necessary we shall obtain your consent to the processing of such information.
We may collect information from:
- Present, past and prospective clients
- Employees of Insurers, partners, associates and other third parties who we work with
- Users of the Hettle Andrews’ website
- Others who have contact with Hettle Andrews
We might collect your personal information if:
- you or your employee asks to be part of a mailing or marketing campaign
- you register (or someone on your behalf registers you) to attend a Hettle Andrews event
- you subscribe (or someone on your behalf subscribes for you) to receive marketing
communications and/or industry updates from us
- you enquire about our products and services but do not become a client
- you approach Hettle Andrews for insurance and/or risk services solutions
- you use our website (for more information please see section 12 on Cookies)
Where you have registered for a Hettle Andrews’ event we will use your personal information to:
- process bookings
- send you the relevant Information pack and to confirm details
- include your name on the delegate list which is available to other delegates (unless you have indicated to us that you do not want your details to appear on such lists) and third parties such as event organisers, exhibitors and speakers
- to produce name badges
- to make necessary security, catering and all other event related arrangements and
for any other necessary purpose related to the running of our events.
We may collect your non-sensitive personal and sensitive personal information:
- face-to-face (directly from you)
- by telephone
- by email
- via direct debit forms
- via our CRM systems
- via the key contact at your organisation
- from individuals or colleagues who have registered you for an event
- from delegate lists obtained from third party events
- from people working on our behalf
- from third parties to verify your Identity and the accuracy of the information you have provided
- from publicly available sources including but not limited to internet search engines, public records and registers and social media (e.g. LinkedIn and Twitter)
- from third parties including but not limited to Industry associations, rradar, Insurers and Loss Adjusters
- Wholesale brokers
- Premium finance providers
- Professional advisers including solicitors, surveyors, loss adjusters and loss assessors
- IT service providers
- Event organisers, event exhibitors and any other such third parties who are involved in
organising or contributing to Hettle Andrews’ events
- Scheme providers
- Survey facilitators
- Providers of accountancy software/system
- Government departments(including the Motor Insurance Database (MID))
- Regulators (including the Financial Conduct Authority)
We may also disclose your personal information to other third parties where:
- the disclosure is required by law or by a regulator with authority over us or you, such as where there is a court order, statutory obligation or FCA request; or
- we believe that such disclosure is necessary in order to assist in the prevention or detection of any criminal action (including fraud) or is otherwise in the overriding public interest.
We never share your information outside our organisation for marketing purposes.
We are committed to only sending you marketing communications that you have expressed an interest in receiving. Emails may include:
- ‘One More’ communications
- Regulation and legislation updates
- Technical updates
- General updates
- Updates on events and products
- Communications from third party providers
Where you have registered for an event, we and/or approved third parties may also send you marketing emails relating to the event that you have registered for, for example providing details of the exhibitors appearing.
You can unsubscribe from such emails at the time of registering for the event or at any time subsequently by clicking the unsubscribe link at the bottom of any email or by contacting us.
Hettle Andrews is committed to keeping your personal information secure. We keep your personal information in a secure server and have appropriate security measures in place in our physical facilities.
Whilst we strive to protect your personal information, due to the nature of the internet we cannot guarantee the security of any information you transmit to us. With this in mind, any transmission is at your own risk and we urge you to take every precaution to protect your personal information while you are online.
We will not transfer your data outside the UK. However, it’s possible your data may be transferred by an insurer or another third party who we share your data with, to countries located outside the UK or European Economic Area (EEA). These countries may not offer the same level of protection for the data as within the EEA, under the European Directive.
As far as possible, we have taken steps to safeguard your personal information.
The right to access your personal Information
Subject to any relevant exemptions, you are entitled to see a copy of the personal information we hold about you and to request details of how we use your personal information including any disclosures made. To exercise your rights to access your personal information, please contact us. There will not usually be a charge for dealing with these requests.
Your personal information will usually be provided to you in writing, or where you have made the request by electronic means, your personal information will be provided to you by electronic means, where possible.
The right to rectification
We take reasonable steps to ensure that the personal information we hold about you is reliable and as accurate and as complete as necessary for its intended use but you are entitled to ask us to update or amend any inaccuracies in the personal information that we hold about you. To request us to update or amend any personal information we hold about you, please contact us.
The right to object to marketing
As set out in section 5, marketing, you are entitled to object to receiving marketing material from us at any time. You can exercise this right by clicking ‘unsubscribe’ on any marketing email you receive from us or by contacting us.
Under certain conditions, you may also have the right to require us to:
- delete any personal information where we no longer have legal grounds to retain it
- where processing is based on consent, to withdraw your consent so that we stop that particular processing
- object to any processing based on the legal ground of legitimate interests unless our reason for undertaking that processing outweighs any prejudice to your data protection rights
- provide you or another provider with a copy of the personal information that you provided us with and
- restrict how we use your personal information whilst a complaint is being investigated
If you contact us to exercise any of these rights we will confirm your right to do so and respond in most cases within 30 days.
If you are not satisfied with our use of your personal information, with our response to any exercise of your rights set out in section 9 or if you believe us to be in breach of our data protection obligations, you have the right to complain to the Information Commissioner’s Office at:
The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire
SK9 SAF. Telephone: 0303 1231113
Our website may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.
The cookies we make use of on the Hettle Andrews’ websites are:
|Hettle Andrews’ Cookies|
|https://hettleandrews.co.uk||Records and tracks recent client hub activity||Up to 3 years|
|https ://widgets.wp.com||Not currently used|
|https://public- api.wordpress.com||Records recent login to the client hub||1 day|
|https://platform.twitter.com||Records interaction with Twitter||30 days|
|https://secure.livechatinc.com||Records whether a user has accepted or declined the live chat feature on our website||30 days|
For further information please visit www.allaboutcookies.org.
You can contact us by email at firstname.lastname@example.org or by writing to us at Hettle Andrews &
Associates Limited, Eleven Brindleyplace, 2 Brunswick Square, Birmingham 81 2LP.
We may update this policy from time to time, to keep it up to date or to comply with legal requirements.