GDPR: Data Privacy Notice For Clients And Suppliers
FSB Insurance Service Ltd ("We") are committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller - A controller determines the purposes and means of processing personal data.
Data processor - A processor is responsible for processing personal data on behalf of a controller.
Data subject – A living individual to whom personal data relates
Categories of data: Personal data and special categories of personal data
Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified from that data. For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
Ruskin Square is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: 5th Floor, Interchange, 81-85 Station Road, Croydon, CR0 2RD. Our Data Trustee is Andrew Bishop, who can be contacted on 0203 883 7976 or by e-mailing email@example.com
3. Information we may collect from you
We may collect and process the following data about you:
Information you give us. You may give us information about you by filling in forms on our site www.fsb-insurance-service.com (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information
Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
We may also receive your information from the FSB if you’ve registered to become a member of the FSB Insurance Service and have consented to it, either online or through a membership advisor or their Customer Service team.
4. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- Providing it to insurers and service providers in order to get you cover for relevant insurance products
- To inform you of upcoming renewals, loss of cover, products, news and events
- Maintaining our own accounts and records, and to enable us to provide free insurance advice to registered members
5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
In order to enable the quotation of and purchase of a policy for cover we will need to share your information with insurers
Consent of the data subject
Via phone conversation, registering with the insurance service via the FSB, or through our website
Processing is necessary for compliance with a legal obligation
In the event of a claim, complaint or breach your information may be supplied to the regulators in order to assist you
It is in our legitimate interest to do so, and will not be at the expense of the interests, rights or freedoms of the data subject
We have a legitimate business interest to process and store your data in ways which you would reasonably expect
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with selected third parties including:
- Insurers and service providers in order to provide relevant insurance which meets your requirements
- Analytics and search engine providers that assist us in the improvement and optimisation of our site
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you
- Finance providers where you have selected the option to pay in instalments via a credit agreement
- Regulatory authorities, courts and governmental agencies to comply with legal or regulatory requirements
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If FSB Insurance Service Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary in order to make sure we hold adequate records in the event that this information is required.
8. Where we store your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you
- The right to request that we correct any personal data if it is found to be inaccurate or out of date; your request will be actioned within one calendar month
- The right to request your personal data is erased where it is no longer necessary to retain such data
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability), where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
- The right to object to the processing of personal data where applicable (i.e. where processing is based on legitimate interests, the performance of a task in the public interest/exercise of official authority, direct marketing and processing for the purposes of scientific/historical research and statistics). We will respond to requests within 28 days
10. Transfer of Data Abroad
We do not transfer personal data outside the EEA.
11. Automated Decision Making
We do not use any form of Automated Decision Making in our business.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. How to make a complaint
To exercise all relevant rights, queries or complaints regarding data privacy please in the first instance contact our Data Trustee on 020 3883 7976 or firstname.lastname@example.org
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.