Privacy Policy

Lansdown Insurance Brokers is a broking business which provides advice and offers special insurance products including equestrian insurance. We are a trading name of South Essex Insurance Brokers Ltd, who are part of the Ecclesiastical group of companies.

Providing broking services means that we need to collect and process data so that we can arrange the insurance cover you have asked for, provide you with a quote, assist with any claims made under an insurance policy we have placed and where relevant, handle any complaints that might arise. This makes us a “data controller”

If you are unsure about who the data controller of your personal information is, you can also contact us at any time by e-mailing us at dataprotection@seib.co.uk or by writing to Data Protection Officer at South Essex House, North Road, South Ockendon, Essex, RM15 5BE.

Depending on our relationship with you for example prospective customers/parties covered under an insurance policy or individuals covered under an insurance policy we place including consumers and commercial customers (and third party claims where applicable) and the nature of services we are providing you with such as broking services, we will collect different types of personal information about you and use it for different purposes.

From time to time we may ask you to provide or we may receive your “sensitive personal information” otherwise known in data protection laws as “special categories of personal information” (which is information relating to your health, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership). for example where we arrange travel insurance for you, we may need information about your pre-existing health conditions. In these circumstances we would use your special category data to provide a quote and arrange the placing of your insurance and to assist with any claims you make. We may also need details of any unspent criminal convictions you have for fraud prevention purposes.

Where you provide personal information to us about other individuals for example members of your household or other persons to be named on your insurance policy we will also be data controller of and responsible for their personal information. You should refer them to this notice.

Prospective policyholder or beneficiary under an insurance policy we will be placing

If we have placed an insurance policy for you or if the insurance policy we have placed covers you or if you are a named individual under an insurance policy with us (for example a family member on a travel policy) this section will be applicable to you and will provide key information about how we use your personal information.

What personal information will we collect?

• Your name and title, address, telephone numbers and email addresses, date of birth and gender.
• Where you are not the policyholder, your relationship or connection to the policyholder.
• Identity documents such as passport, driving licence and national insurance number.
• Employment status and related information such as job title, employment history and education.
• Information which is related to the insurance policy we have placed including:
  – details about previous insurance policies you have held and any previous claims you have made;
  – details about your family such as dependants or spouses; and
  – policy specific information. For example, if we will be placing equestrian insurance for you, we will need information about your horse and the riding events you participate in.
• Financial information including:
  – your bank account and payment details;
  – details about your income; and
  – information obtained from checking sanctions lists and credit checks such as bankruptcy orders, individual voluntary arrangements, office disqualifications or county court judgments.
• Information which is relevant to any claims you make under an insurance policy we have placed for you and which we are assisting you with. This could include photographic evidence you provide us with, for example if you make a claim under your travel policy, we will need information about the country you visited.
• Information which is available publically such as internet search engines and social media where we need to investigate fraudulent claims.

What special category personal information will we collect?

• Information about your physical and mental health if relevant to the insurance policy we have placed or any claims you make on an insurance policy we have placed (for example for a travel policy you may need to disclose pre-existing medical conditions).
• Information about any criminal offences you have been convicted for and any related information including about any offences or alleged offences you have committed or any court sentences which you are subject to.
• We may also collect information because it is relevant to your policy or claim, which reveals or is likely to reveal your race or ethnicity, religious or philosophical beliefs; political opinions; trade union membership; or data concerning your sex life or sexual orientation.

How will we collect your personal information?

When you are the policyholder, directly from you:

• when we provide you with a quote;
• when we place an insurance policy for you;
• when you approach us because you want to renew a policy we have placed;
• when you make a claim on your policy; and
• during any communications we have, such as by telephone or email or when you make a complaint or general enquiry.

We will also collect your personal information from:

• The policyholder where you are a beneficiary.
• A third party who has power of attorney over you.
• Third parties who we rely on to administer the placing of your insurance policy and when we assist you with any claims you have such as insurers, third party claimants, defendants, witnesses and our own business partners.
• Third parties involved in a claim you have made under an insurance policy we have placed such as claims handlers, medical experts and medical screening service providers, investigators and loss adjusters.
• Third parties who provide sanctions checking services.
• Insurance industry bodies.
• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks.
• Other companies in the Ecclesiastical Group.
• Public sources such as court judgments, insolvency registers, internet search engines, social media where we need to investigate fraudulent claims and directories of Anglican ministers.
• The Financial Conduct Authority and the Prudential Regulation who are our regulators.

What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a “legal ground” to do so. When using your “personal information”, we will rely on the “legal grounds” set out below:

• We need to use your personal information to enter into or perform our contract with you. We will rely on this legal ground for all activities all activities that we undertake in order to fulfil our contractual obligations and without using your personal information we would be unable to do, such as placing insurance cover for you, administering your application, assessing your application against market offerings, providing you with a quote and assisting with any claims you have.
• We have a legal or regulatory obligation to use your personal information. For example, we have legal obligations to carry out anti-money laundering checks and our regulators require us to maintain records of all dealings with you and to carry out sanctions checks and to comply with our regulatory reporting requirements we may need to send your personal information to our regulators.
• We have a business need to use your personal information. Such needs will include keeping business and accounting records, maintaining management information, statistical analysis, developing and testing our systems, analysing our business and improving the services we offer, carrying out strategic reviews of our business models and will cover all activities which are needed to carry out everyday business activities. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

When we use your “special categories of personal information” (such as information about your health, religion or criminal offences), we need to have an additional “legal ground”. When using your “special categories of personal information”, we will rely on the “legal grounds” set out below:

• We have an insurance purpose to use your special categories of personal information and there is a substantial public interest such as assessing your insurance application, arranging or administering a policy for you, assisting with any claims you have under an insurance policy we have placed.
• It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
• It is in the substantial public interest to prevent or detect unlawful acts and the processing of special categories of personal information is necessary for the purposes of prevention or detection of an unlawful act, for example where we suspect fraud.
• You have clearly made your special categories of personal information public. For example where you are a Bishop of an Anglican Church and you have made your religious beliefs common knowledge.
• We need to use your special categories of personal information to establish, exercise or defend legal rights. This will be applicable where we are involved in legal proceedings, either against us or where we want to instigate them ourselves.
• You have given your consent. There may be some instances where we may need your consent to process special categories of personal information (e.g. health information) and without it we could not place your insurance policy or assist with any claims you have. We will make it clear when these circumstances are and why your consent is necessary.

What is the purpose for using your personal information	Legal grounds for using your personal information	Legal grounds for using your special categories of personal information
To assess your insurance application and obtain appropriate quotes for you	• It is necessary to enter into or perform our contract • We have a business need (to assess all insurance applications against market placement)	• It is necessary for the insurance purpose of administering an insurance policy. • We have your explicit consent. In some circumstances, we will need to obtain your consent before we can place your policy.
To place an insurance policy with appropriate cover	• It is necessary to enter into or perform our contract • We have a business need (to place insurance cover which is in line with market placement)	• It is necessary for the insurance purpose of administering an insurance policy. • We have your explicit consent. In some circumstances, we will need to obtain your consent before we can place your policy.
To assist you with any claims you make under an insurance policy we have placed	• It is necessary to enter into or perform our contract. • We have a business need (to assist all customers with any claims they have).	• It is necessary for the insurance purpose of administering a claim under an insurance policy. • We have your explicit consent. In some circumstances, we will need to obtain your consent before we can assist with any claims you have
To carry out fraud, credit and anti-money laundering checks on you	• It is necessary to enter into or perform our contract. • We have a legal obligation. • We have a business need (to prevent fraud and other financial crime).	• It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). • It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. • We have your explicit consent. • We need to establish, exercise or defend legal rights.
To assist with any renewals or mid-terms adjustments of any insurance policy we have placed and any cancellations	• It is necessary to enter into or perform our contract. • We have a business need (to assist customers and provide adequate broking services including with any renewals, mid-term-adjustments and cancellations)	• It is necessary for the insurance purpose of administering an insurance policy. • We have your explicit consent. In some circumstances, we will need to obtain your consent before we can arrange for any renewals, mid-term adjustments or cancellations.
To comply with our legal or regulatory obligations.	• We have a legal obligation.	• It is necessary for the insurance purpose of administering an insurance policy. • It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. • We have your explicit consent. • We need to establish, exercise or defend legal rights.
To handle any complaints you may have and generally communicate with you.	• It is necessary to enter into or perform our contract. • We have a business need (to respond to all communications and complaints and investigate and resolve complaints).	• We need to establish, exercise or defend legal rights.
To apply for and claim on our own insurance.	• We have a business need (to have our own insurance cover in place)	• It is necessary for the insurance purpose of administering an insurance policy. • We need to establish, exercise or defend legal rights.
For business purposes such as systems development migration of systems and live testing, diagnosing any problems with our servers and website	• We have a business need (to run an efficient business)	• It is necessary for the insurance purpose of administering an insurance policy.
For business purposes such as maintaining management information and carrying out statistical and strategic analysis	• We have a business need (to run an efficient business and improve our business)	• It is necessary for the insurance purpose of administering an insurance policy.
For financial purposes such as maintaining management information and accounting records and carrying out audits	• We have a business need (to maintain appropriate financial records)	• It is necessary for the insurance purpose of administering an insurance policy.
To provide improved quality, training and security (for example, through recorded or monitored phone calls to our contact numbers, or carrying out customer satisfaction surveys).	• We have a business need (to develop and improve the services we offer).	• It is necessary for the insurance purpose of administering an insurance policy.
To contact you to inform you about services we think you might be interested in.	• We have a business need (to inform you about other services we offer).	• You have provided your consent.

Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• The policyholder where you are a beneficiary.
• Third parties who we rely on to administer your insurance policy such as insurers, other insurance intermediaries and insurance distributors and our own business partners.
• Third parties we liaise with when assisting you with a claim such as claims handlers, medical experts and medical screening service providers, surveyors, investigators and loss adjusters.
• Medical screening service providers in relation to travel insurance.
• Third parties who provide sanctions checking services.
• Insurance industry bodies.
• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks.
• Other companies in the Ecclesiastical Group.
• Service providers we have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, marketing mailing providers and business suppliers.
• Any third parties in the event of a sale, merger, reorganisation, transfer or dissolution of our business.
• The Financial Conduct Authority and the Prudential Regulation who are our regulators.
• Law enforcement agencies such as the police, HMRC and taxation authorities.
• Our own insurers and companies who we have appointed to assist with arranging our insurance.

Policyholder or beneficiary under an insurance policy we have placed

If we have placed an insurance policy for you or if the insurance policy we have placed covers you or if you are a named individual under an insurance policy with us (for example a family member on a travel policy) this section will be applicable to you and will provide key information about how we use your personal information.

What personal information will we collect? 

• Your name and title, address, telephone numbers and email addresses, date of birth and gender.
• Where you are not the policyholder, your relationship or connection to the policyholder.
• Identity documents such as passport, driving licence and national insurance number.
• Employment status and related information such as job title, employment history and education.
• Information which is related to the insurance policy we have placed including:
• details about previous insurance policies you have held and any previous claims you have made;
• details about your family such as dependants or spouses; and
• policy specific information. For example, if we will be placing equestrian insurance for you, we will need information about your horse and the riding events you participate in.
• Financial information including:
• your bank account and payment details;
• details about your income; and
• information obtained from checking sanctions lists and credit checks such as bankruptcy orders, individual voluntary arrangements, office disqualifications or county court judgments.
• Information which is relevant to any claims you make under an insurance policy we have placed for you and which we are assisting you with. This could include photographic evidence you provide us with, for example if you make a claim under your travel policy, we will need information about the country you visited.
• Information which is available publically such as internet search engines and social media where we need to investigate fraudulent claims.

What special category personal information will we collect?

• Information about your physical and mental health if relevant to the insurance policy we have placed or any claims you make on an insurance policy we have placed (for example for a travel policy you may need to disclose pre-existing medical conditions).
• Information about any criminal offences you have been convicted for and any related information including about any offences or alleged offences you have committed or any court sentences which you are subject to.
• We may also collect information because it is relevant to your policy or claim, which reveals or is likely to reveal your race or ethnicity, religious or philosophical beliefs; political opinions; trade union membership; or data concerning your sex life or sexual orientation.

How will we collect your personal information?

When you are the policyholder, directly from you:

• when we provide you with a quote;
• when we place an insurance policy for you;
• when you approach us because you want to renew a policy we have placed;
• when you make a claim on your policy; and
• during any communications we have, such as by telephone or email or when you make a complaint or general enquiry.

We will also collect your personal information from:

• The policyholder where you are a beneficiary.
• A third party who has power of attorney over you.
• Third parties who we rely on to administer the placing of your insurance policy and when we assist you with any claims you have such as insurers, third party claimants, defendants, witnesses and our own business partners.
• Third parties involved in a claim you have made under an insurance policy we have placed such as claims handlers, medical experts and medical screening service providers, investigators and loss adjusters.
• Third parties who provide sanctions checking services.
• Insurance industry bodies.
• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks.
• Other companies in the Ecclesiastical Group.
• Public sources such as court judgments, insolvency registers, internet search engines, social media where we need to investigate fraudulent claims and directories of Anglican ministers.
• The Financial Conduct Authority and the Prudential Regulation who are our regulators.

What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a “legal ground” to do so. When using your “personal information”, we will rely on the “legal grounds” set out below:

• We need to use your personal information to enter into or perform our contract with you. We will rely on this legal ground for all activities all activities that we undertake in order to fulfil our contractual obligations and without using your personal information we would be unable to do, such as placing insurance cover for you, administering your application, assessing your application against market offerings, providing you with a quote and assisting with any claims you have.
• We have a legal or regulatory obligation to use your personal information. For example, we have legal obligations to carry out anti-money laundering checks and our regulators require us to maintain records of all dealings with you and to carry out sanctions checks and to comply with our regulatory reporting requirements we may need to send your personal information to our regulators.
• We have a business need to use your personal information. Such needs will include keeping business and accounting records, maintaining management information, statistical analysis, developing and testing our systems, analysing our business and improving the services we offer, carrying out strategic reviews of our business models and will cover all activities which are needed to carry out everyday business activities. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

When we use your “special categories of personal information” (such as information about your health, religion or criminal offences), we need to have an additional “legal ground”. When using your “special categories of personal information”, we will rely on the “legal grounds” set out below:

• We have an insurance purpose to use your special categories of personal information and there is a substantial public interest such as assessing your insurance application, arranging or administering a policy for you, assisting with any claims you have under an insurance policy we have placed.
• It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
• It is in the substantial public interest to prevent or detect unlawful acts and the processing of special categories of personal information is necessary for the purposes of prevention or detection of an unlawful act, for example where we suspect fraud.
• You have clearly made your special categories of personal information public. For example where you are a Bishop of an Anglican Church and you have made your religious beliefs common knowledge.
• We need to use your special categories of personal information to establish, exercise or defend legal rights. This will be applicable where we are involved in legal proceedings, either against us or where we want to instigate them ourselves.
• You have given your consent. There may be some instances where we may need your consent to process special categories of personal information (e.g. health information) and without it we could not place your insurance policy or assist with any claims you have. We will make it clear when these circumstances are and why your consent is necessary.

What is the purpose for using your personal information	Legal grounds for using your personal information	Legal grounds for using your special categories of personal information
To assess your insurance application and obtain appropriate quotes for you	• It is necessary to enter into or perform our contract • We have a business need (to assess all insurance applications against market placement)	• It is necessary for the insurance purpose of administering an insurance policy. • We have your explicit consent. In some circumstances, we will need to obtain your consent before we can place your policy.
To place an insurance policy with appropriate cover	• It is necessary to enter into or perform our contract • We have a business need (to place insurance cover which is in line with market placement)	• It is necessary for the insurance purpose of administering an insurance policy. • We have your explicit consent. In some circumstances, we will need to obtain your consent before we can place your policy.
To assist you with any claims you make under an insurance policy we have placed	• It is necessary to enter into or perform our contract. • We have a business need (to assist all customers with any claims they have).	• It is necessary for the insurance purpose of administering a claim under an insurance policy. • We have your explicit consent. In some circumstances, we will need to obtain your consent before we can assist with any claims you have
To carry out fraud, credit and anti-money laundering checks on you	• It is necessary to enter into or perform our contract. • We have a legal obligation. • We have a business need (to prevent fraud and other financial crime).	• It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). • It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. • We have your explicit consent. • We need to establish, exercise or defend legal rights.
To assist with any renewals or mid-terms adjustments of any insurance policy we have placed and any cancellations	• It is necessary to enter into or perform our contract. • We have a business need (to assist customers and provide adequate broking services including with any renewals, mid-term-adjustments and cancellations)	• It is necessary for the insurance purpose of administering an insurance policy. • We have your explicit consent. In some circumstances, we will need to obtain your consent before we can arrange for any renewals, mid-term adjustments or cancellations.
To comply with our legal or regulatory obligations.	• We have a legal obligation.	• It is necessary for the insurance purpose of administering an insurance policy. • It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. • We have your explicit consent. • We need to establish, exercise or defend legal rights.
To handle any complaints you may have and generally communicate with you.	• It is necessary to enter into or perform our contract. • We have a business need (to respond to all communications and complaints and investigate and resolve complaints).	• We need to establish, exercise or defend legal rights.
To apply for and claim on our own insurance.	• We have a business need (to have our own insurance cover in place)	• It is necessary for the insurance purpose of administering an insurance policy. • We need to establish, exercise or defend legal rights.
For business purposes such as systems development migration of systems and live testing, diagnosing any problems with our servers and website	• We have a business need (to run an efficient business)	• It is necessary for the insurance purpose of administering an insurance policy.
For business purposes such as maintaining management information and carrying out statistical and strategic analysis	• We have a business need (to run an efficient business and improve our business)	• It is necessary for the insurance purpose of administering an insurance policy.
For financial purposes such as maintaining management information and accounting records and carrying out audits	• We have a business need (to maintain appropriate financial records)	• It is necessary for the insurance purpose of administering an insurance policy.
To provide improved quality, training and security (for example, through recorded or monitored phone calls to our contact numbers, or carrying out customer satisfaction surveys).	• We have a business need (to develop and improve the services we offer).	• It is necessary for the insurance purpose of administering an insurance policy.
To contact you to inform you about services we think you might be interested in.	• We have a business need (to inform you about other services we offer).	• You have provided your consent.

Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• The policyholder where you are a beneficiary.
• Third parties who we rely on to administer your insurance policy such as insurers, other insurance intermediaries and insurance distributors and our own business partners.
• Third parties we liaise with when assisting you with a claim such as claims handlers, medical experts and medical screening service providers, surveyors, investigators and loss adjusters.
• Medical screening service providers in relation to travel insurance.
• Third parties who provide sanctions checking services.
• Insurance industry bodies.
• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks.
• Other companies in the Ecclesiastical Group.
• Service providers we have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, marketing mailing providers and business suppliers.
• Any third parties in the event of a sale, merger, reorganisation, transfer or dissolution of our business.
• The Financial Conduct Authority and the Prudential Regulation who are our regulators.
• Law enforcement agencies such as the police, HMRC and taxation authorities.
• Our own insurers and companies who we have appointed to assist with arranging our insurance.

Third party claimant

If you have made a claim against an individual for whom we have placed insurance cover, this section will be applicable to you and will provide key information about how we use your personal information.

What personal information will we collect?

• Your name and title, address, telephone numbers and email addresses, date of birth and gender.
• Identity documents such as passport, driving licence and national insurance number.
• Any information which is related to your claim which could include:
  • your job title and employment if relevant;
  • details about the incident; and
  • photographic evidence.
• Information which is available publically such as internet search engines and social media where we need to investigate fraudulent claims.

What special category information will we collect?

• Information about your physical and mental health if relevant to the claim you are making.
• Information about any criminal offences you have been convicted for and any related information including about any offences or alleged offences you have committed or any court sentences which you are subject to.
• We may also collect information because it is relevant to your claim, which reveals or is likely to reveal your race or ethnicity, religious or philosophical beliefs; political opinions; trade union membership; or data concerning your sex life or sexual orientation. For example motor insurance will require you to disclose any motoring convictions.

How will we collect your personal information?

Directly from you.

We will also collect your personal information from:

• The policyholder who we have placed insurance cover.
• Third parties involved in the insurance and claim process such as insurers, third party claimants, defendants, witnesses and our own business partners.
• Third parties involved in the claim process such as claims handlers, medical experts and medical screening service providers, investigators and loss adjusters lawyers or the Crown Prosecution Service.
• Third parties who provide sanctions checking services.
• Insurance industry bodies.
• Other companies in the Ecclesiastical Group.
• Public sources such as court judgments, insolvency registers, internet search engines, social media
• The Financial Conduct Authority who are our regulators.

What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a “legal ground” to do so. When using your “personal information”, we will rely on the “legal grounds” set out below:

• We have a legal or regulatory obligation to use your personal information. For example, our regulators require us to maintain records of all dealings with you and to comply with our regulatory reporting requirements we may need to send your personal information to our regulators.
• We have a business need to use your personal information. Such needs will include investigating claims, keeping business and accounting records, maintaining management information, statistical analysis, developing and testing our systems, analysing our business and improving the services we offer, carrying out strategic reviews of our business models and will cover all activities which are needed to carry out everyday business activities. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

When we use your “special categories of personal information” (such as information about your health, religion or criminal offences), we need to have an additional “legal ground”. When using your “special categories of personal information”, we will rely on the “legal grounds” set out below:

• We have an insurance purpose to use your special categories of personal information such as assisting with claims.
• We need to use your special categories of personal information to establish, exercise or defend legal rights. This will be applicable where we are involved in legal proceedings, either against us or where we want to instigate them ourselves.
• It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
• It is in the substantial public interest to prevent or detect unlawful acts and the processing of special categories of personal information is necessary for the purposes of prevention or detection of an unlawful act, for example where we suspect fraud.
• You have given your consent.

What is the purpose for using your personal information	Legal grounds for using your personal information	Legal grounds for using your special categories of personal information
To assess your insurance application and obtain appropriate quotes for you	• We have a business need (to assess and investigate your claim and deal with it appropriately). • We have a legal obligation.	• It is necessary for the insurance purpose of handling claims. • We have your explicit consent.
To carry out fraud checks to prevent any fraudulent claims	• We have a business need (to prevent fraud).	• It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). • It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. • We have your explicit consent. • We need to establish, exercise or defend legal rights.
To comply with our legal or regulatory obligations.	• We have a legal obligation.	• It is necessary for the insurance purpose of handling claims. • It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. • We have your explicit consent. • We need to establish, exercise or defend legal rights.
To generally communicate with you.	• We have a business need (to respond to all communications related to an insurance policy we have placed).	• It is necessary for the insurance purpose of handling claims.
For business purposes such as maintaining management information and carrying out statistical and strategic analysis	• We have a business need (to run an efficient business and improve our business)	• It is necessary for the insurance purpose of administering an insurance policy.
For business purposes such as systems development, migration of systems and live testing, diagnosing any problems with our servers and website	• We have a business need (to run an efficient business)	• It is necessary for the insurance purpose of administering an insurance policy.
For financial purposes such as maintaining management information and accounting records and carrying out audits	• We have a business need (to maintain appropriate financial records)	• It is necessary for the insurance purpose of administering an insurance policy.
To provide improved quality, training and security (for example, through recorded or monitored phone calls to our contact numbers).	• We have a business need (to develop and improve the services we offer).	• It is necessary for the insurance purpose of administering an insurance policy.

Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• The policyholder.
• Other insurers involved in your claim.
• Third parties who we rely on when assisting with a claim such as insurers, third party claimants, defendants, witnesses and our own business partners.
• Third parties who have been appointed to assist with a claim and that we need to liaise with when assisting claims made under an insurance policy we have placed such as claims handlers, medical experts and medical screening service providers, surveyors, investigators and loss adjusters.
• Third parties who provide sanctions checking services.
• Insurance industry bodies.
• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks including the Claims Underwriting Exchange (known as “CUE”).
• Other companies in the Ecclesiastical Group.
• Service providers we have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, marketing mailing providers and business suppliers.
• Any third parties in the event of a sale, merger, reorganisation, transfer or dissolution of our business.
• The Financial Conduct Authority who are our regulators.
• Law enforcement agencies such as the police, HMRC and taxation authorities.
• Our own insurers and companies who we have appointed to assist with arranging our insurance.

Witness to an incident 

If you have witnessed an incident which has now become the subject of a claim under an insurance policy we have placed, this section will be applicable to you and will provide key information about how we use your personal information.

What personal information will we collect?

• Your name and title, address, telephone numbers and email addresses, date of birth and gender.
• Any information which is related to the incident you witnessed.

What special category personal information will we collect?

• Information about your physical and mental health if you suffered an injury as a result of the incident you witnessed or where you disclose information for example referring to a disability you have.
• Information about any criminal offences you have been convicted for and any related information including about any offences or alleged offences you have committed or any court sentences which you are subject to.

How will we collect your personal information?

Directly from you when we contact you to discuss the incident you witnessed.

We will also collect your personal information from:

• Those people involved in the witness such as the policyholder, the claimant and other witnesses.
• Other third parties involved in the incident from an insurance administration perspective such as insurers, claims handlers, loss adjusters and business partners.
• Third parties that have been appointed to assist in relation to the incident you witnessed and that we need to liaise with when assisting claims made under an insurance policy we have placed such as medical experts, medical screening service providers and investigators.
• Other companies in the Ecclesiastical Group.
• Public sources such as court judgments, insolvency registers, internet search engines, social media.

What will we use your personal information for? 

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a “legal ground” to do so. When using your “personal information”, we will rely on the “legal grounds” set out below:

• We have a legal or regulatory obligation to use your personal information. For example, our regulators require us to maintain records of all dealings with you and to comply with our regulatory reporting requirements we may need to send your personal information to our regulators.
• We have a business need to use your personal information. Such needs will include investigating claims, keeping business and accounting records, maintaining management information, statistical analysis, developing and testing our systems, analysing our business and improving the services we offer, carrying out strategic reviews of our business models and will cover all activities which are needed to carry out everyday business activities. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

When we use your “special categories of personal information” (such as information about your health, religion or criminal offences), we need to have an additional “legal ground”. When using your “special categories of personal information”, we will rely on the “legal grounds” set out below:

• We have an insurance purpose to use your special categories of personal information and there is a substantial public interest such as assisting with claims.
• It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
• It is in the substantial public interest to prevent or detect unlawful acts and the processing of special categories of personal information is necessary for the purposes of prevention or detection of an unlawful act, for example where we suspect fraud.
• We need to use your special categories of personal information to establish, exercise or defend legal rights. This will be applicable where we are involved in legal proceedings, either against us or where we want to instigate them ourselves.
• You have given your consent.

What is the purpose for using your personal information	Legal grounds for using your personal information	Legal grounds for using your special categories of personal information
To assist with any claims made under an insurance policy we have placed	• We have a business need (to assist with any claims made under an insurance policy we have placed). • We have a legal obligation.	• It is necessary for the insurance purpose of assisting with claims. • We have your explicit consent.
To prevent any fraudulent claims	• We have a business need (to prevent fraud).	• It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). • It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. • We have your explicit consent. • We need to use your information in order to establish, exercise or defend legal rights.
To comply with our legal or regulatory obligations.	• We have a legal obligation.	• We need to establish, exercise or defend legal rights. • It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). • It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. • We have your explicit consent.
For business purposes such as maintaining management information and carrying out statistical and strategic analysis	• We have a business need (to run an efficient business and improve our business)	• It is necessary for the insurance purpose of assisting with claims.
For financial purposes such as maintaining management information and accounting records and carrying out audits	• We have a business need (to maintain appropriate financial records)	• It is necessary for the insurance purpose of assisting with claims.
For business purposes such as systems development, migration of systems and live testing, diagnosing any problems with our servers and website	• We have a business need (to run an efficient business)	• It is necessary for the insurance purpose of assisting with claims.

Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• The policyholder.
• Insurers that are involved in the claim.
• Other third parties involved in the incident from an insurance administration perspective such as brokers, insurers, claims handlers, loss adjusters and business partners.
• Third parties that have been appointed to assist in relation to the incident you witnessed and whom we need to liaise with when assisting with a claim such as medical experts, medical screening service providers and investigators.
• Third parties who provide sanctions checking services.
• Insurance industry bodies.
• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks including the Claims Underwriting Exchange (known as “CUE”).
• Other companies in the Ecclesiastical Group.
• Service providers we have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, marketing mailing providers, business suppliers.
• Any third parties in the event of a sale, merger, reorganisation, transfer or dissolution of our business.
• The Financial Conduct Authority and the Prudential Regulation who are our regulators.
• Law enforcement agencies such as the police, HMRC and taxation authorities.
• Our own insurers and companies who we have appointed to assist with arranging our insurance.

Insurers, reinsurers and other business partners

If you are an insurer, reinsurer or another type of business partner such as a supplier, subcontractor that we do business with, this section will be applicable to you and will provide key information about how we use your personal information.

What personal information will we collect?

• Your name and title, address, telephone numbers and email addresses, date of birth and gender.
• Employment status and related information such as job title, employment history and education.
• Bank and payment details.
• Financial information obtained from checking sanctions lists and credit checks such as bankruptcy orders, individual voluntary arrangements, office disqualifications or county court judgments.
• Information which is available publicly such as internet search engines.

What special category personal information will we collect?

• Information about any criminal offences you have been convicted for and any related information including about any offences or alleged offences you have committed or any court sentences which you are subject to.

How will we collect your personal information?

• Directly from you.
• Third parties who provide sanctions checking services.
• Other companies in the Ecclesiastical Group.
• Public sources such as court judgments, insolvency registers, internet search engines, social media.

What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a “legal ground” to do so. When using your “personal information”, we will rely on the “legal grounds” set out below:

• We need to use your personal information to enter into a services contract with you.
• We have a legal or regulatory obligation to use your personal information. For example, we have obligations to carry out due diligence checks on parties we engage with.
• We have a business need to use your personal information. Such needs will include keeping business and accounting records, maintaining management information, statistical analysis, developing and testing our systems, analysing our business and improving the services we offer, carrying out strategic reviews of our business models and will cover all activities which are needed to carry out everyday business activities. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

When we use your “special categories of personal information” (such as information about your health, religion or criminal offences), we need to have an additional “legal ground”. When using your “special categories of personal information”, we will rely on the “legal grounds” set out below:

• It is in the substantial public interest to prevent or detect unlawful acts and the processing of special categories of personal information is necessary for the purposes of prevention or detection of an unlawful act, for example where we suspect fraud.
• It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
• We need to use your special categories of personal information to establish, exercise or defend legal rights. This will be applicable where we are involved in legal proceedings, either against us or where we want to instigate them ourselves.
• You have given your explicit consent.

What is the purpose for using your personal information	Legal grounds for using your personal information	Legal grounds for using your special categories of personal information
To comply with our legal or regulatory obligations.	• We have a legal obligation.	• We need to establish, exercise or defend legal rights. • It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). • It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. • We have your explicit consent.
To carry out fraud, credit and anti-money laundering checks on you.	• It is necessary to enter into or perform your services contract. • We have a legal obligation. • We have a business need (to prevent fraud).	• It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). • It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty. • We have your explicit consent.
To engage with you and obtain your services and generally communicate with you.	• It is necessary to enter into or perform your services contract. • We have a business need (to respond to all communications and complaints and investigate and resolve complaints).	• We need to establish, exercise or defend legal rights. • You have made this public knowledge.
For business purposes such as systems development, migration of systems and live testing, diagnosing any problems with our servers and website	• We have a business need (to run an efficient business)	• It is necessary for the insurance purpose of placing an insurance cover. • We have your explicit consent.
For business purposes such as maintaining management information, internal audits and carrying out statistical and strategic analysis	• We have a business need (to run an efficient business and improve our business)	• It is necessary for the insurance purpose of placing insurance cover. • We have your explicit consent.
For financial purposes such as maintaining management information and accounting records and carrying out audits	• We have a business need (to maintain appropriate financial records)	• It is necessary for the insurance purpose of administering an insurance policy. • We have your explicit consent.

Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• The policyholder and any claimants.
• Third parties involved in the insurance and claim process such as insurers, third party claimants, defendants, witnesses and our own business partners.
• Third parties who have been appointed in relation a claim such as claims handlers, medical experts and medical screening service providers, surveyors, investigators and loss adjusters.
• Third parties who provide sanctions checking services.
• Insurance industry bodies.
• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks.
• Other companies in the Ecclesiastical Group.
• Service providers we have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, marketing mailing providers and business suppliers.
• Any third parties in the event of a sale, merger, reorganisation, transfer or dissolution of our business.
• The Financial Conduct Authority who are our regulators.
• Law enforcement agencies such as the police, HMRC and taxation authorities.
• Our own insurers and companies who we have appointed to assist with arranging our insurance.

Users of the SEIB website

If you use or access the SEIB website, this section will be applicable to you and will provide key information about how we use your personal information.

What personal information will we collect?

• Name, contact details, postcode, IP address and any details relevant to the insurance cover you may request • Information obtained through our use of cookies. You can find more information about this in our cookies policy here

How will we collect your personal information?

We collect your information directly from our website and where you have submitted any information on our website.

What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a “legal ground” to do so. When using your “personal information”, we will rely on the “legal grounds set out below:

• We have a business need to use your personal information, such as developing and testing our systems, analysing our business and improving the services we offer, diagnosing any problems with our website and assessing usage of our website. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

Legal grounds for using your data

What is the purpose for using your personal information	Legal grounds for using your personal information	Legal grounds for using your special categories of personal information
To respond to any enquiries you make	• We have a business need (to respond to all enquiries made on our website).
To provide marketing materials about products and services we think you might be interested in.	• We have a business need (to inform you about other services we offer).

Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• Other companies in the Ecclesiastical Group.
• Service providers we have contracted with relating to the website such as our subcontractors and agents and website providers.

We may use your personal information to provide you with information about our services which may be of interest to you where you are an existing client or where you have provided your consent for us to do so.

We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you no longer wish to receive information from us and want to be removed from our standard mailing list you can “unsubscribe” by clicking the link that appears in all emails or post by contacting using the details set out in section 8. Please note that by stopping these communications you may not hear about a new product or services such as a new insurance product or additions to our insurance that may save you money.  This includes products and services from the Ecclesiastical group of companies.

Please note that, even if you opt out of receiving marketing messages, we may still send you communications which are relevant to the type of services we provide you with.

We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out in section 3 above and to comply with our legal and regulatory obligations.

If you would like further information about how long we will keep your personal information for, please contact us using the details set out in section 10.

We implement and maintain appropriate technical and organisational measures to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services. These include but are not limited to the following key activities:

• We adopt a framework of information security controls operating at different levels within the company to restrict access and safeguard systems, in accordance with a ‘defence in depth’ methodology (which is the coordinated use of multiple security controls to protect the integrity of the information and assets in the company’s IT network);
• We have an established documented information security and data protection policy framework which is regularly reviewed to consider changes in technology, regulations and threats;
• We maintain encryption technologies to encrypt data stored on portable computers and portable media, and ensure security when data is transferred;
• We maintain awareness and education on information security and data protection in all areas of our business;
• We conduct risk based due diligence on our suppliers;
• We operate a programme of testing the effectiveness of our information security measures.

We are continually improving our methods of communication and alongside with changes in the law and the changing nature of technology, our data practices and how we use your data will change from time to time. If and when our data practices change, we will notify you and we will provide you with the most up-to-date notice. You can view it by checking our website here.

This notice was last updated on 21/05/18.