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67 Lombard St, London, EC3V 9LJ
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* UK Privacy Notice
UK PRIVACY NOTICE
We are committed to ensuring your privacy is protected. This Privacy Notice sets
out details of the information that we may collect from you and how we may use
that information. Please take your time to read this Privacy Notice carefully.
When using our website, this Privacy Notice should be read alongside the website
terms and conditions.
* 1. About Us
* 2. About the insurance market
* 3. Our processing of your personal information
* 3.1 Prospective customers or parties covered under an insurance policy we
are asked to quote on
* 3.2. Customers or parties covered under an insurance policy we place
* 3.3. Third party claimant
* 3.4. Experts instructed in relation to claims
* 3.5. Witnesses to an incident
* 3.6. Brokers, insurers and reinsurers
* 3.7. Users of our various Pen websites
* 3.8. Members of a Scheme we administer
* 4. How do we protect your personal information when sending it abroad?
* 5. What marketing activities do we carry out?
* 6. How long do we keep personal information for?
* 7. Automated processing
* 8. Your rights
* 9. How we protect your information
* 10. Contacting us
* 11. Updates to this Privacy Notice
About us
This Privacy Notice describes how Pen Underwriting Limited (including when
conducting business using the trading name OAMPS Hazardous Industries, or any
other trading names as reflected on the Financial Conduct Authority’s Financial
Services Register (https://register.fca.org.uk/) "we" or "us" or “our” or "Pen"
collect and process data about individuals. Our services consist primarily of
risk consulting, (re)insurance broking and the provision of insurance, which
enable the consideration of, access to, administration of, and making of claims
on, insurance. We are part of the Arthur J. Gallagher global group of companies.
In order to offer to and provide our services, we will collect and use data
about individuals. This means that we are a 'data controller' and we are
responsible for complying with data protection laws.
During the insurance lifecycle we will receive personal information relating to
potential or actual policy holders, policy beneficiaries including their family
members as well as claimants and other parties that are involved in a claim. As
such, references to “individuals” or “you” or “your” in this Privacy Notice
include any living individual from the preceding list, whose personal
information we receive in connection with the services we provide under our
engagement with our clients.
We have appointed a Data Protection Officer to oversee our handling of personal
information. If you have any questions about how we collect, store or use your
personal information, you may contact our Data Protection Officer using the
details set out in the "Contacting Us" section.
▲ Back to Top
About the insurance market
The personal information that we collect and process will be shared with other
participants in the insurance market, some of which you will not have direct
contact with. You can identify relevant data controllers through the insurance
market life-cycle in the following ways:
* Where you took out the insurance policy yourself: intermediaries such as Pen
will be the initial data controller. The insurer will also be a data
controller. Pen’s Data Protection Officer can advise you of the identities of
other insurance market participants that have been provided with your
personal data.
* Where your employer or another organisation took out the policy for your
benefit: you should contact your employer or the organisation that took out
the policy who should provide you with details of intermediaries such as Pen
that they provided your personal data to. Pen’s Data Protection Officer can
advise you of the identities of other insurance market participants that have
been provided with your personal data.
* Where you are not a policyholder or an insured: you should contact the
organisation that collected your personal data who should provide you with
details of the relevant data protection contact.
For a more detailed description of how your personal data will be disclosed to
insurance market participants by Pen please see the current version of the
London Market Core Uses Information Notice (the LMA Notice) available here which
forms a part of our Privacy Notice. Pen’s use of personal information is
consistent with the LMA Notice.
▲ Back to Top
Our processing of your personal information
The personal information that we collect will depend on our relationship with
you. Please click on the section below that best describes your relationship
with us. For example, we will collect more detailed information about you if you
are a client than we would if you simply made an enquiry about the services that
we offer.
Sometimes we will ask for or obtain special categories of information
(information relating to your health, genetic or biometric data, criminal
convictions, sex life, sexual orientation, racial or ethnic origin, political
opinions, religious or philosophical beliefs, trade union membership) because it
is relevant to your insurance policy or claim (for example, health information
which relates to an accident policy) or information regarding criminal
convictions for the purposes of preventing, detecting and investigating fraud.
If you provide personal information to us about other people you must provide
them with a copy of this Privacy Notice and obtain any consent where we indicate
that it is required for the processing of that person's information in
accordance with this Privacy Notice.
▲ Back to Top
* 3.1 Prospective customers or parties covered under an insurance policy we are
asked to quote on
* 3.1.1. What personal information might we collect?
* 3.1.2. What special categories of information might we collect?
* 3.1.3. How will we collect your personal information?
* 3.1.4. What will we use your personal information for?
* 3.1.5. Who will we share your personal information with?
* 3.2 Customers or parties covered under an insurance policy we place
* 3.2.1. What personal information might we collect?
* 3.2.2. What special categories of information might we collect?
* 3.2.3. How will we collect your personal information?
* 3.2.4. What will we use your personal information for?
* 3.2.5. Who will we share your personal information with?
* 3.3 Third party claimant
* 3.3.1. What personal information might we collect?
* 3.3.2. What special categories of information might we collect?
* 3.3.3. How will we collect your personal information?
* 3.3.4. What will we use your personal information for?
* 3.3.5. Who will we share your personal information with?
* 3.4 Experts instructed in relation to claims
* 3.4.1. What personal information might we collect?
* 3.4.2. How will we collect your personal information?
* 3.4.3. What will we use your personal information for?
* 3.4.4. Who will we share your personal information with?
* 3.5 Witnesses to an incident
* 3.5.1. What personal information might we collect?
* 3.5.2. What special categories of information might we collect?
* 3.5.3. How will we collect your personal information?
* 3.5.4. What will we use your personal information for?
* 3.5.5. Who will we share your personal information with?
* 3.6 Brokers, insurers and reinsurers
* 3.6.1. What personal information might we collect?
* 3.6.2. What special categories of information might we collect?
* 3.6.3. How will we collect your personal information?
* 3.6.4. What will we use your personal information for?
* 3.6.5. Who will we share your personal information with?
* 3.7 Users of our various Pen websites
* 3.7.1. What personal information might we collect?
* 3.7.2. How will we collect your personal information?
* 3.7.3. What will we use your personal information for?
* 3.7.4. Who will we share your personal information with?
* 3.8 Members of a Scheme we administer
* 3.8.1. What personal information might we collect?
* 3.8.2. How will we collect your personal information?
* 3.8.3. What will we use your personal information for?
* 3.8.4. Who will we share your personal information with?
3.1 Prospective customers or parties covered under an insurance policy we are
asked to quote on
This section will detail what personal information we collect about you and use
if you are a prospective customer or you have submitted your personal
information so that we can provide you with a quote for the placing of an
insurance policy or if you are a party and would be covered under an insurance
policy we will be placing.
* 3.1.1. What personal information might we collect?
* 3.1.2. What special categories of information might we collect?
* 3.1.3. How will we collect your personal information?
* 3.1.4. What will we use your personal information for?
* 3.1.5. Who will we share your personal information with?
▲ Back to Our processing of your personal information
3.1.1. What personal information might we collect?
* General information such as your name, date of birth, gender, relationship to
the customer (where are you not the prospective policyholder), identification
information such as national insurance number, passport number or driving
licence number
* Contact details including address, telephone number and email address
* Information about your job including job title, business description,
education, employment history and professional certifications
* Information relating to the advice that you request or the services that we
are providing. For example, we might need information relating to your
previous insurance policies and claims history in order to advise on your
future needs
* Financial information such as your financial history and needs, income, bank
details, payment details and information obtained as a result of our credit
checks
* Information obtained when we carry out checks of sanction lists
* Information obtained through our use of cookies. Please see our cookies
policy for more information
* Information captured during recordings of our telephone calls
* Your marketing preferences
* Any information we record about your preferences when doing business with us
▲ Back to Prospective customers or parties covered under an insurance policy we
are asked to quote on
3.1.2. What special categories of information might we collect?
* Details of your current or former physical or mental health – for example
details about a medical claim you made under a previous travel policy when
you provide details of your claims history or details about your current
health because it is relevant to the insurance policy you want Pen to place
* Information relating to criminal sanctions (including offences and alleged
offences and any caution, court sentence or criminal conviction). We may
receive this information as a result of carrying out checks of sanctions
lists
* Information relating to any professional disciplinary action that you are or
have been the subject of
* Your political opinions, religious or philosophical beliefs or trade union
membership
▲ Back to Prospective customers or parties covered under an insurance policy we
are asked to quote on
3.1.3. How will we collect your personal information?
We may collect your information in a number of different ways:
* Directly from you or from someone else on your behalf in a number of ways
including where it is submitted through our website or in application forms,
initial disclosure documents, through interactions with our website and more
generally during any forms of communication such as face to face, written and
telephone correspondence
* From third parties and other insurance market participants who might
introduce customers to us such as another broker and insurers
* Via publically available sources such as internet search engines, open
electoral registers and social media sites
* From other companies within the Arthur J. Gallagher group
* Through customer satisfaction surveys and market research
* From credit reference agencies
* Via insurance industry fraud prevention and detection databases and sanctions
screening tools
* From government agencies such as the DVLA or HMRC and from professional
regulators
* Selected third parties who provide us with details of potential customers
▲ Back to Prospective customers or parties covered under an insurance policy we
are asked to quote on
3.1.4. What will we use your personal information for?
We may process your information for a number of different purposes. For each
purpose we must have a legal ground for such processing and we will rely on the
following legal grounds:
* We need to use your personal information to enter into or perform our
contract with you, for example, in order to fulfil our obligations under our
contract and place appropriate insurance cover, we need to use your personal
information to provide you with a quote and determine market placement.
* We have a legitimate business interest to use your personal information such
as maintaining our business records, keeping records of insurance policies we
place and analysing and improving our business model and services. When using
your personal information for these purposes, we have considered your rights
and ensured that our business need does not cause you harm
* We have a legal or regulatory obligation to use your personal information.
For example, our regulators impose certain record-keeping rules which we must
adhere to
When the information that we process is classed as a special category of
information, we must have one of the following additional legal grounds for such
processing:
* It is necessary for an insurance purpose and it is in the substantial public
interest. This will apply where we are advising or arranging an insurance
policy, assisting with any claims under a policy, and undertaking any
activities to prevent and detect fraud.
* You have provided your consent. There may be some circumstances that without
your consent to use your special categories of information we would be unable
to arrange your insurance cover. We will notify you when this will be
applicable and why your consent is necessary.
* Where the use of your special categories of information is necessary to
establish, exercise or defend our legal rights, for example legal proceedings
are being brought against us or we want to bring a legal claim ourselves.
Please see below for further details of the different ways we use your personal
information and the legal grounds we rely on when doing so.
Purpose for processing Legal grounds for using your personal information Legal
grounds for using your special categories of information To evaluate your
insurance needs and risk appetite, match those to appropriate insurer, policy
and premium and obtain quotes for you
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to determine market placement and
place insurance cover for you that is in line with your insurance needs)
* It is necessary for an insurance purpose
* Your consent
To set you up as a customer including carrying out fraud, sanctions, credit and
anti-money laundering checks
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to carry out appropriate credit
checks and fraud checks)
* We have a legal or regulatory obligation
* The prevention and detection of fraud is in the substantial public interest
* It is necessary for an insurance purpose
* It is necessary to establish, exercise or defend our legal rights
* Your consent
General client care, communicating with you and responding to any enquiries you
have
* It is necessary to enter into/perform our contract
* We have a legal or regulatory obligation
* We have a legitimate business interest (to respond to our prospective
customers and keep them updated on any future placing of insurance cover)
* It is necessary for an insurance purpose
* It is necessary to establish, exercise or defend our legal rights
To assist you in the arrangement of premium finance for your policy
* Your consent
* Not applicable
Complying with our legal or regulatory obligations (such as our requirements to
report to the FCA)
* We have a legal or regulatory obligation
* It is necessary to establish, exercise or defend our legal rights
* It is necessary for an insurance purpose
Providing improved quality, training and security (for example, with respect to
recorded or monitored phone calls to our contact numbers)
* We have a legitimate business interest (to continually improve our services)
* It is necessary for an insurance purpose
Managing our business operations such as maintaining accounting records,
analysing financial results, complying with internal audit requirements and
receiving professional advice (e.g. tax or legal advice)
* We have a legitimate business interest (to carry out business operations and
activities that are necessary for the everyday running of a business)
* Not applicable
Monitoring applications, reviewing, assessing, tailoring and improving our
products and services and similar products and services offered by Pen
* We have a legitimate business interest (to market our services)
* Not applicable
Monitoring usage of any of the various Pen websites
* We have a legitimate business interest (to assess usage of our website)
* Not applicable
Advertising, marketing, and promotional purposes, including to reach you by
email, post or telephone with more relevant advertisements and to evaluate,
measure and improve the effectiveness of our advertising campaigns; to send you
newsletters, offers or other information we think may interest you; to contact
you about our services or information we think may interest you; and to
administer promotions
* With your consent, or based on a legitimate business interest or as otherwise
permitted by law
* Not applicable
Advising, improving or developing products and services through risk modelling
and data analysis, e.g. understanding risk exposures, crafting solutions with
appropriate insurance coverage, limits, deductibles based on historical datasets
* We have a legitimate business interest (to improve and develop products and
services by drawing on our experience with ongoing and prior relationships)
* Not applicable
▲ Back to Prospective customers or parties covered under an insurance policy we
are asked to quote on
3.1.5. Who will we share your personal information with?
We may share your personal information with companies in the Arthur J. Gallagher
group to serve you, including for the activities listed above.
We may share personal information with the following third parties for the
purposes set out above:
* our insurance partners such as other insurance intermediaries, insurers,
reinsurers or other companies who act as insurance distributors
* other brokers who act directly for you and who have approached us to
facilitate the placement of an insurance policy for you
* other third parties who assist in the administration of insurance policies
such as accountants, auditors, lawyers and other experts
* insurance broking platform providers
* fraud detection agencies and other third parties who operate and maintain
fraud detection registers
* our regulators
* the police and other third parties or law enforcement agencies where
reasonably necessary for the prevention or detection of crime
* other insurers who provide our own insurance
* industry bodies
* credit reference agencies
* our third party services providers such as IT suppliers, finance and payment
providers, actuaries, auditors, lawyers, marketing agencies, document
management providers, tax advisers and insurance software providers
* selected third parties in connection with the sale, transfer or disposal of
our business
If you would like further information regarding the disclosures of your personal
information, please see the "Contacting us" section below for our contact
details.
▲ Back to Prospective customers or parties covered under an insurance policy we
are asked to quote on
3.2 Customers or parties covered under an insurance policy we place
This section will detail what personal information we collect about you and use
if you are a customer or an individual covered by an insurance policy we have
placed.
* 3.2.1. What personal information might we collect?
* 3.2.2. What special categories of information might we collect?
* 3.2.3. How will we collect your personal information?
* 3.2.4. What will we use your personal information for?
* 3.2.5. Who will we share your personal information with?
▲ Back to Our processing of your personal information
3.2.1. What personal information might we collect?
* General information such as your name, date of birth, gender, relationship to
the customer (where are you not the prospective policyholder), identification
information such as national insurance number, passport number or driving
license number
* Contact details including address, telephone number and email address
* Information about your job including job title, business description,
education, employment history and professional certifications
* Information relating to the advice that you request or the services that we
are providing. For example, we might need information relating to your
previous insurance policies and claims history
* Information which is relevant to the insurance policy we have placed or any
claims made under it. For example where we have placed property insurance for
you, we will hold information about your property and the individuals living
there
* Information obtained from requests for mid-term adjustments which may reveal
changes in your personal circumstances which are relevant to the insurance
policy we placed
* Financial information such as your financial history and needs, income, bank
details, payment details and information obtained as a result of our credit
checks
* Financial information obtained if you request cancellation of your insurance
policy and any information relating to the cancellation
* Information obtained when we carry out checks of sanction lists
* Information obtained through our use of cookies. Please see our cookies
policy for more information
* Information captured during recordings of our telephone calls
* Your marketing preferences
* Any information we record about your preferences when doing business with us
▲ Back to Customers or parties covered under an insurance policy we place
3.2.2. What special categories of information might we collect?
* Details of your current or former physical or mental health – for example
where we have placed workers compensation insurance for you, we may have
details about your employees' accidents and injuries
* Information relating to criminal sanctions (including offences and alleged
offences and any caution, court sentence or criminal conviction). We may
receive this information as a result of carrying out checks of sanctions
lists
* Information relating to any professional disciplinary action that you are or
have been the subject of
* Any other special categories of information you offer up when communicating
with us. We will only process such information to the extent necessary in
connection with the insurance policy or where in connection with legal
proceedings. Any further processing will only be with your explicit consent.
▲ Back to Customers or parties covered under an insurance policy we place
3.2.3. How will we collect your personal information?
We may collect your information in a number of ways:
* Directly from you or from someone else on your behalf in a number of ways
including where it is submitted through our website or in application forms,
initial disclosure documents, proposal forms, renewal terms, requests for
mid-term adjustments, when you require assistance in making a claim, through
interactions with our website and more generally during any forms of
communication such as face to face, written and telephone correspondence
* From third parties and other insurance market participants who might
introduce customers to us such as another broker and insurers
* From other brokers who act directly for you and who have approached us to
facilitate the placement of an insurance policy for you
* From other third parties involved in the relevant insurance policy or claim
such as claimants, witnesses to an incident, loss adjusters, claims handlers
and medical experts
* Via publicly available sources such as internet search engines, open
electoral registers and social media sites
* From other companies within the Arthur J. Gallagher group
* Through customer satisfaction surveys and market research
* From credit reference agencies
* Via insurance industry fraud prevention and detection databases and sanctions
screening tools
* From government agencies such as the DVLA or HMRC and from professional
regulators
▲ Back to Customers or parties covered under an insurance policy we place
3.2.4. What will we use your personal information for?
We may process your information for a number of different purposes. For each
purpose we must have a legal ground for such processing and we will rely on the
following legal grounds:
* We need to use your personal information to enter into or perform our
contract with you. For example, in order to fulfill our obligations under our
contract and place appropriate insurance cover, we need to use your personal
information to provide you with appropriate insurance cover according to your
needs.
* We have a legitimate business interest to use your personal information such
as maintaining our business records, keeping records of insurance policies we
place and analysing and improving our business model and services. When using
your personal information for these purposes, we have considered your rights
and ensured that our business need does not cause you harm
* We have a legal or regulatory obligation to use your personal information.
For example, our regulators impose certain record-keeping rules which we must
adhere to
When the information that we process is classed as a special category of
information, we must have one of the following additional legal grounds for such
processing:
* It is necessary for an insurance purpose and it is in the substantial public
interest. This will apply where we are advising or arranging an insurance
policy, assisting with any claims under a policy, and undertaking any
activities to prevent and detect fraud.
* You have provided your consent. There may be some circumstances that without
your consent to use your special categories of information we would be unable
to arrange your insurance cover. We will notify you when this will be
applicable and why your consent is necessary
* Where the use of your special categories of information is necessary to
establish, exercise or defend our legal rights, for example legal proceedings
have been brought against us or we want to bring a legal claim ourselves.
Please see below for further details of the different ways we use your personal
information and the legal grounds we rely on when doing so.
Purpose for processing Legal grounds for using your personal information Legal
grounds for using your special categories of information To evaluate your
insurance needs and risk appetite, match those to appropriate insurer, policy
and premium and obtain quotes for you
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to determine market placement and
place insurance cover for you that is in line with your insurance needs)
* It is necessary for an insurance purpose
To arrange appropriate insurance cover and provide policy documentation
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to ensure that you have the
appropriate policy documentation)
* It is necessary for an insurance purpose
To arrange for the collection of, to collect or refund premiums or pay claims
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to ensure that your insurance cover
is placed, that you are able to meet your financial obligations, you receive
refunds that are due and you are paid claims when due)
* Not applicable
To assist in any claims made under an insurance policy we have placed
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to assist customers in any claims
they have)
* It is necessary for an insurance purpose
To assist with any renewals, mid-term adjustments of your insurance policy or
cancellations
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to provide you with appropriate
broking services where you request a renewal, mid-term adjustment or
cancellation of the insurance policy we have placed)
* It is necessary for an insurance purpose
To set you up as a customer including carrying out fraud, sanctions, credit and
anti-money laundering checks
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to carry out appropriate credit
checks and fraud checks)
* We have a legal or regulatory obligation
* The prevention and detection of fraud is in the substantial public interest.
* It is necessary for an insurance purpose.
* It is necessary to establish, exercise or defend our legal rights.
General client care, communicating with you, responding to any enquiries you
have
* It is necessary to enter into/perform our contract
* We have a legal or regulatory obligation
* We have a legitimate business interest (to generally respond to our
customers)
* It is necessary for an insurance purpose
* It is necessary to establish, exercise or defend our legal rights
Complying with our legal or regulatory obligations (such as our requirements to
report to the FCA)
* We have a legal or regulatory obligation
* It is necessary to establish, exercise or defend our legal rights
* It is necessary for an insurance purpose.
Prevention and detection of and investigating and prosecuting fraud. This might
include sharing your personal information with third parties such as the police,
and other insurance and financial services providers.
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to ensure that we take all necessary
precautions to prevent fraud)
* The prevention and detection of fraud is in the substantial public interest.
* It is necessary for an insurance purpose.
* It is necessary to establish, exercise or defend our legal rights.
Providing improved quality, training and security (for example, with respect to
recorded or monitored phone calls to our contact numbers)
* We have a legitimate business interest (to continually improve our services)
* It is necessary for an insurance purpose.
Managing our business operations such as maintaining accounting records,
analysing financial results, complying with internal audit requirements and
receiving professional advice (e.g. tax or legal advice)
* We have a legitimate business interest (to carry out business operations and
activities that are necessary for the everyday running of a business)
* Not applicable
Monitoring applications, reviewing, assessing, tailoring and improving our
products and services and similar products and services offered by Pen
* We have a legitimate business interest (to market out services)
* Not applicable
Tracing and recovering debt
* We have a legitimate business interest (to trace and receive any debt which
is owed to us)
* It is necessary to establish, exercise or defend our legal rights
Monitoring usage of any of the various Pen websites
* We have a legitimate business interest (to assess usage of our website)
* Not applicable
To apply for and claim on our own insurance
* We have a legitimate business interest (to have our own insurance)
* We have your explicit consent
* It is necessary to establish, exercise or defend our legal rights
Advertising, marketing, and promotional purposes, including to reach you by
email, post and telephone with more relevant advertisements and to evaluate,
measure and improve the effectiveness of our advertising campaigns; to send you
newsletters, offers or other information we think may interest you; to contact
you about our services or information we think may interest you; and to
administer promotions
* With your consent, or based on a legitimate business interest or as otherwise
permitted by law
* Not applicable
Advising, improving or developing products and services through risk modelling
and data analysis, e.g. understanding risk exposures, crafting solutions with
appropriate insurance coverage, limits, deductibles based on historical dataset
* We have a legitimate business interest (to improve and develop products and
services by drawing on our experience with ongoing and prior relationships)
* Not applicable
▲ Back to Customers or parties covered under an insurance policy we place
3.2.5. Who will we share your personal information with?
We may share your personal information with companies in the Arthur J. Gallagher
group to serve you, including for the activities listed above.
We may share personal information with the following third parties for the
purposes set out above:
* our insurance partners such as other insurance intermediaries, insurers,
reinsurers or other companies who act as insurance distributors
* other brokers who act directly for you and who have approached us to
facilitate the placement of an insurance policy for you
* other third parties who assist in the administration of insurance policies
such as accountants, auditors, lawyers, loss adjusters, third parties
involved in handling or otherwise addressing claims, such as healthcare
professionals and other experts
* insurance broking platform providers
* fraud detection agencies and other third parties who operate and maintain
fraud detection registers
* investigative firms we ask to look into claims on our behalf in relation to
suspected fraud
* our regulators
* the police and other third parties or law enforcement agencies where
reasonably necessary for the prevention or detection of crime
* other insurers who provide our own insurance
* industry bodies
* premium finance providers
* debt collection agencies
* credit reference agencies
* our third party services providers such as IT suppliers, finance and payment
providers, actuaries, auditors, lawyers, marketing agencies, document
management providers, tax advisers and insurance software providers
* selected third parties in connection with the sale, transfer or disposal of
our business
If you would like further information regarding the disclosures of your personal
information, please see the "Contacting us" section below for our contact
details.
▲ Back to Customers or parties covered under an insurance policy we place
3.3 Third party claimant
This section will detail what personal information we collect about you and use
if you have made a claim against a customer for whom we have placed insurance
cover.
* 3.3.1. What personal information might we collect?
* 3.3.2. What special categories of information might we collect?
* 3.3.3. How will we collect your personal information?
* 3.3.4. What will we use your personal information for?
* 3.3.5. Who will we share your personal information with?
▲ Back to Our processing of your personal information
3.3.1. What personal information might we collect?
* General information such as your name, date of birth, gender, relationship to
the customer (where are you not the prospective policyholder), identification
information such as national insurance number, passport number or driving
licence number
* Contact details including address, telephone number and email address
* If relevant to your claim, we may collect the following information about
you:
* information about your job including job title, business description,
education, employment history and professional certifications
* your financial information such as your financial history and needs,
income, bank details, payment details and information obtained as a result
of our credit and anti-fraud checks
* Information obtained when we carry out checks of sanction lists
* Information obtained through our use of cookies. Please see our cookies
policy for more information
* Information captured during recordings of our telephone calls
▲ Back to Third party claimant
3.3.2. What special categories of information might we collect?
* Details of your current or former physical or mental health if it is relevant
to your claim – for example where you have been injured in a motor accident
and the driver is insured under a policy we placed
* Information relating to criminal sanctions (including offences and alleged
offences and any caution, court sentence or criminal conviction). We may
receive this information if it is relevant to your claim or as a result of
carrying out sanctions lists
* 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 where we seek to
validate or investigate a claim we may receive files containing any of the
above information. We may also need to collect this information to assess the
value of your claim
* Any other special categories of information you offer up when communicating
with us about your claim. We will only process such information to the extent
necessary in connection with your claim or where in connection with legal
proceedings. Any further processing will only be with your explicit consent.
▲ Back to Third party claimant
3.3.3. How will we collect your personal information?
We may collect your information in a number of different ways:
* Directly from you
* From our customer who is the policyholder
* From third parties involved in the insurance process such as another broker
and insurers
* From other third parties involved in the relevant insurance policy or claim
such as other claimants, witnesses to an incident, loss adjusters, claims
handlers and medical experts
* Via publically available sources such as internet search engines, open
electoral registers and social media sites
* From other companies within the Arthur J. Gallagher group
* Via insurance industry fraud prevention and detection databases and sanctions
screening tools
* From government agencies such as the DVLA or HMRC and from professional
regulators
▲ Back to Third party claimant
3.3.4. What will we use your personal information for?
We may process your information for a number of different purposes. For each
purpose we must have a legal ground for such processing and we will rely on the
following legal grounds:
* We have a legitimate business interest to use your personal information such
as maintaining our business records, keeping records of insurance policies we
place and claims made under such policies and analysing and improving our
business model and services. When using your personal information for these
purposes, we have considered your rights and ensured that our business need
does not cause you harm.
* We have a legal or regulatory obligation to use your personal information.
For example, our regulators impose certain record-keeping rules which we must
adhere to.
When the information that we process is classed as a special category of
information, we must have one of the following additional legal grounds for such
processing:
* It is necessary for an insurance purpose and it is in the substantial public
interest. This will apply where we are assisting with any claims under a
policy, and undertaking activities to prevent and detect fraud.
* Where the use of your special categories of information is necessary to
establish, exercise or defend our legal rights, for example legal proceedings
are being brought against us or we want to bring a legal claim ourselves.
Please see below for further details of the different ways we use your personal
information and the legal grounds we rely on when doing so.
Purpose for processing Legal grounds for using your personal information Legal
grounds for using your special categories of information To assist in any claims
made under an insurance policy we placed
* We have a legitimate business interest (to assist in any claims which have
been made under an insurance policy we placed)
* It is necessary for an insurance purpose
Complying with our legal or regulatory obligations (such as our requirements to
report to the FCA)
* We have a legal or regulatory obligation.
* It is necessary to establish, exercise or defend our legal rights
* It is necessary for an insurance purpose
Prevention and detection of and investigating and prosecuting fraud. This might
include sharing your personal information with third parties such as the police,
and other insurance and financial services providers.
* We have a legitimate business interest (to ensure that we take all necessary
precautions to prevent fraud)
* The prevention and detection of fraud is in the substantial public interest
* It is necessary for an insurance purpose
* It is necessary to establish, exercise or defend our legal rights
Providing improved quality, training and security (for example, with respect to
recorded or monitored phone calls to our contact numbers)
* We have a legitimate business interest (to continually improve our services)
* It is necessary for an insurance purpose
Managing our business operations such as maintaining accounting records,
analysing financial results, complying with internal audit requirements and
receiving professional advice (e.g. tax or legal advice)
* We have a legitimate business interest (to carry out business operations and
activities that are necessary for the everyday running of a business)
* Not applicable
Advising, improving or developing products and services through risk modelling
and data analysis, e.g. understanding risk exposures, crafting solutions with
appropriate insurance coverage, limits, deductibles based on historical datasets
* We have a legitimate business interest (to improve and develop products and
services by drawing on our experience with ongoing and prior relationships)
* Not applicable
▲ Back to Third party claimant
3.3.5. Who will we share your personal information with?
We may share your personal information with companies in the Arthur J. Gallagher
group to serve you, including for the activities listed above.
We may share personal information with the following third parties for the
purposes set out above:
* our insurance partners such as other insurance intermediaries, insurers,
reinsurers or other companies who act as insurance distributors
* other brokers who act directly for you and who have approached us to
facilitate the placement of an insurance policy for you
* other third parties who assist in the administration of insurance policies
such as loss adjusters, claims handlers, accountants, auditors, lawyers and
other experts
* insurance broking platform providers
* fraud detection agencies and other third parties who operate and maintain
fraud detection registers
* investigative firms we ask to look into claims on our behalf in relation to
suspected fraud
* our regulators
* the police and other third parties or law enforcement agencies where
reasonably necessary for the prevention or detection of crime
* other insurers who provide our own insurance
* industry bodies
* debt collection agencies
* credit reference agencies
* our third party services providers such as IT suppliers, finance and payment
providers, actuaries, auditors, lawyers, marketing agencies, document
management providers, tax advisers and insurance software providers
* selected third parties in connection with the sale, transfer or disposal of
our business
If you would like further information regarding the disclosures of your personal
information, please see the "Contacting us" section below for our contact
details.
▲ Back to Third party claimant
Experts instructed in relation to claims
This section will detail what personal information we collect about you and use
if you are an expert instructed in relation to a claim which has been made under
an insurance policy we placed.
* 3.4.1. What personal information might we collect?
* 3.4.2. How will we collect your personal information?
* 3.4.3. What will we use your personal information for?
* 3.4.4. Who will we share your personal information with?
▲ Back to Our processing of your personal information
3.4.1. What personal information might we collect?
* General information such as your name, identification information such as
national insurance number, passport number or driving licence number
* Contact details including address, telephone number and email address
* Information about your job including job title, business description,
education, employment history and professional certifications
* Information captured during recordings of our telephone calls
▲ Back to Experts instructed in relation to claims
3.4.2. How will we collect your personal information?
We may collect your information in a number of different ways:
* Directly from you
* From other third parties involved in the insurance process and claims process
such as another broker and insurers
* Via publically available sources such as internet search engines, open
electoral registers and social media sites
* From other companies within the Arthur J. Gallagher group
▲ Back to Experts instructed in relation to claims
3.4.3. What will we use your personal information for?
We may process your information for a number of different purposes. For each
purpose we must have a legal ground for such processing and we will rely on the
following legal grounds:
* We have a legitimate business interest to use your personal information such
as maintaining our business records, keeping records of insurance policies we
place and business entities we interact with and analysing and improving our
business model and services. When using your personal information for these
purposes, we have considered your rights and ensured that our business need
does not cause you harm.
* We have a legal or regulatory obligation to use your personal information.
Please click below for further details of the different ways we use your
personal information and the legal grounds we rely on when doing so.
Purpose for processing Legal grounds for using your personal information Legal
grounds for using your special categories of information To assist in any claims
made under an insurance policy we have placed
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to assist customers in any claims
they have)
* Not applicable
Managing our business operations such as maintaining accounting records,
analysing of financial results, complying with internal audit requirements and
receiving professional advice (e.g. tax or legal advice)
* We have a legitimate business interest (to carry out business operations and
activities that are necessary for the everyday running of a business)
* Not applicable
Advising, improving or developing products and services through risk modelling
and data analysis, e.g. understanding risk exposures, crafting solutions with
appropriate insurance coverage, limits, deductibles based on historical dataset
* We have a legitimate business interest (to improve and develop products and
services by drawing on our experience with ongoing and prior relationships)
* Not applicable
▲ Back to Experts instructed in relation to claims
3.4.4. Who will we share your personal information with?
We may share your personal information with companies in the Arthur J. Gallagher
group to serve you, including for the activities listed above.
We may share personal information with the following third parties for the
purposes set out above:
* our insurance partners such as other insurance intermediaries, insurers,
reinsurers or other companies who act as insurance distributors
* other third parties who assist in the administration of claims such as loss
adjusters, claims handlers, accountants, auditors, lawyers and other experts
* investigative firms we ask to look into claims on our behalf in relation to
suspected fraud
* our regulators
* our third party services providers such as IT suppliers, finance and payment
providers, actuaries, auditors, lawyers, marketing agencies, document
management providers, tax advisers and insurance software providers
* selected third parties in connection with the sale, transfer or disposal of
our business
If you would like further information regarding the disclosures of your personal
information, please see the "Contacting us" section below for our contact
details.
▲ Back to Experts instructed in relation to claims
3.5 Witnesses to an incident
This section will detail what personal information we collect about you and use
if you are a witness to an incident which is the subject of a claim made under
an insurance policy we have placed.
* 3.5.1. What personal information might we collect?
* 3.5.2. What special categories of information might we collect?
* 3.5.3. How will we collect your personal information?
* 3.5.4. What will we use your personal information for?
* 3.5.5. Who will we share your personal information with?
▲ Back to Our processing of your personal information
3.5.1. What personal information might we collect?
* General information such as your name, date of birth, gender and occupation
* Contact details including address, telephone number and email address
* Information which is relevant to the incident you witnessed
* Information captured during recordings of our telephone calls
▲ Back to Witnesses to an incident
3.5.2. What special categories of information might we collect?
* Special categories of information will only be collected where it is relevant
to an incident, for example a particular health condition that is of
relevance to your statement
▲ Back to Witnesses to an incident
3.5.3. How will we collect your personal information?
We may collect your information in a number of different ways:
* Directly from you
* From our customer who is the policyholder
* From other third parties involved in the claims process such as another
broker and insurers
* From other third parties involved in the relevant claim such as claimants,
other witnesses, loss adjusters, claims handlers and medical experts
* Via publically available sources such as internet search engines, open
electoral registers and social media sites
▲ Back to Witnesses to an incident
3.5.4. What will we use your personal information for?
We may process your information for a number of different purposes. For each
purpose we must have a legal ground for such processing and we will rely on the
following legal grounds:
* We have a legitimate business interest to use your personal information such
as maintaining our business records, keeping records claims made under
insurance policies we have arranged and analysing and improving our business
model and services. When using your personal information for these purposes,
we have considered your rights and ensured that our business need does not
cause you harm.
* We have a legal or regulatory obligation to use your personal information.
For example, our regulators impose certain record-keeping rules which we must
adhere to.
When the information that we process is classed as a special category of
information, we must have one of the following additional legal grounds for such
processing:
* It is necessary for an insurance purpose and it is in the substantial public
interest. This will apply where we are assisting with any claims under a
policy, and undertaking any activities to prevent and detect fraud.
* You have provided your consent.
* Where the use of your special categories of information is necessary to
establish, exercise or defend our legal rights, for example legal proceedings
have been brought against us or we want to bring a legal claim ourselves.
Please see below for further details of the different ways we use your personal
information and the legal grounds we rely on when doing so.
Purpose for processing Legal grounds for using your personal information Legal
grounds for using your special categories of information To assist in any claims
made under an insurance policy we placed
* We have a legitimate business interest (to assist in any claims made under an
insurance policy we have arranged)
* It is necessary for an insurance purpose
* We have your explicit consent
Complying with our legal or regulatory obligations (such as our requirements to
report to the FCA)
* We have a legal or regulatory obligation
* It is necessary to establish, exercise or defend our legal rights
* It is necessary for an insurance purpose
Prevention and detection of and investigating and prosecuting fraud. This might
include sharing your personal information with third parties such as the police,
and other insurance and financial services providers.
* We have a legitimate business interest (to ensure that we take all necessary
precautions to prevent fraud)
* The prevention and detection of fraud is in the substantial public interest.
* It is necessary for an insurance purpose
* It is necessary to establish, exercise or defend our legal rights
Managing our business operations such as maintaining accounting records,
analysing of financial results, complying with internal audit requirements and
receiving professional advice (e.g. tax or legal advice)
* We have a legitimate business interest (to carry out business operations and
activities that are necessary for the everyday running of a business)
* Not applicable
Advising, improving or developing products and services through risk modelling
and data analysis, e.g. understanding risk exposures, crafting solutions with
appropriate insurance coverage, limits, deductibles based on historical dataset
* We have a legitimate business interest (to improve and develop products and
services by drawing on our experience with ongoing and prior relationships)
* Not applicable
▲ Back to Witnesses to an incident
3.5.5. Who will we share your personal information with?
We may share your personal information with companies in the Arthur J. Gallagher
group to serve you, including for the activities listed above.
We may share personal information with the following third parties for the
purposes set out above:
* our insurance partners such as other insurance intermediaries, insurers,
reinsurers or other companies who act as insurance distributors
* other third parties who assist in the administration of insurance policies
and claims such as loss adjusters, claims handlers, accountants, auditors,
lawyers and other experts
* fraud detection agencies and other third parties who operate and maintain
fraud detection registers
* investigative firms we ask to look into claims on our behalf in relation to
suspected fraud
* our regulators
* the police and other third parties or law enforcement agencies where
reasonably necessary for the prevention or detection of crime
* other insurers who provide our own insurance
* industry bodies
* debt collection agencies
* our third party services providers such as IT suppliers, finance and payment
providers, actuaries, auditors, lawyers, marketing agencies, document
management providers, tax advisers and insurance software providers
* selected third parties in connection with the sale, transfer or disposal of
our business
If you would like further information regarding the disclosures of your personal
information, please see the "Contacting us" section below for our contact
details.
▲ Back to Witnesses to an incident
Brokers, insurers and reinsurers
This section will detail what personal information we collect about you and use
if you are a wholesale broker, third party producing broker, an appointed
representative, an insurer or reinsurer.
* 3.6.1. What personal information might we collect?
* 3.6.2. What special categories of information might we collect?
* 3.6.3. How will we collect your personal information?
* 3.6.4. What will we use your personal information for?
* 3.6.5. Who will we share your personal information with?
▲ Back to Our processing of your personal information
3.6.1. What personal information might we collect?
* General information such as your name, identification information such as
national insurance number, passport number or driving licence number
* Contact details including address, telephone number and email address
* Information about your job including job title, business description,
education, employment history and professional certifications
* Information obtained when we carry out checks of sanction lists
* Information obtained through our use of cookies. Please see our cookies
policy for more information
* Information obtained as a result of carrying out due diligence
* Information captured during recordings of our telephone calls
* Your marketing preferences
* Any information we record about your preferences when doing business with us
▲ Back to Brokers, insurers and reinsurers
3.6.2. What special categories of information might we collect?
* Information relating to criminal sanctions (including offences and alleged
offences and any caution, court sentence or criminal conviction). We may
receive this information as a result of carrying out checks of sanctions
lists
* Any information we record that is relevant to you doing business with us
▲ Back to Brokers, insurers and reinsurers
3.6.3. How will we collect your personal information?
We may collect your information in a number of different ways:
* Directly from you
* From other third parties involved in the insurance process such as another
broker and insurers
* Via publically available sources such as internet search engines, open
electoral role and social media sites
* From other companies within the Arthur J. Gallagher group
* Via insurance industry fraud prevention and detection databases and sanctions
screening tools
▲ Back to Brokers, insurers and reinsurers
3.6.4. What will we use your personal information for?
We may process your information for a number of different purposes. For each
purpose we must have a legal ground for such processing and we will rely on the
following legal grounds:
* We need to use your personal information to enter into or perform our
contract with you.
* We have a legitimate business interest to use your personal information such
as maintaining our business records, keeping records of insurance policies we
place and analysing and improving our business model and services. When using
your personal information for these purposes, we have considered your rights
and ensured that our business need does not cause you harm
* We have a legal or regulatory obligation to use your personal information.
When the information that we process is classed as a special category of
information, we must have one of the following additional legal grounds for such
processing:
* It is necessary for an insurance purpose and it is in the substantial public
interest. This will apply where we undertake activities to prevent and detect
fraud.
* You have provided your consent.
* Where the use of your special categories of information is necessary to
establish, exercise or defend our legal rights, for example legal proceedings
are being brought against us or we want to bring a legal claim ourselves.
Please see below for further details of the different ways we use your personal
information and the legal grounds we rely on when doing so.
Purpose for processing Legal grounds for using your personal information Legal
grounds for using your special categories of information To enter into business
relationships which facilitate and enable us to place insurance policies for our
customers
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to enter into arrangements with other
insurance partners so that we can provide services to our customers)
* It is necessary for an insurance purpose
To carrying out fraud, sanctions and anti-money laundering checks
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to ensure that we take all necessary
precautions to prevent fraud)
* We have a legal or regulatory obligation
* The prevention and detection of fraud is in the substantial public interest
* It is necessary for an insurance purpose
* It is necessary to establish, exercise or defend our legal rights
Complying with our legal or regulatory obligations (such as our requirements to
report to the FCA)
* We have a legal or regulatory obligation
* It is necessary to establish, exercise or defend our legal rights
* It is necessary for an insurance purpose
Providing improved quality, training and security (for example, with respect to
recorded calls
* We have a legitimate business interest (to carry out business operations and
activities that are necessary for the everyday running of a business)
* Not applicable
Managing our business operations such as maintaining accounting records,
analysing of financial results, complying with internal audit requirements and
receiving professional advice (e.g. tax or legal advice)
* We have a legitimate business interest (to carry out business operations and
activities that are necessary for the everyday running of a business)
* Not applicable
Monitoring applications, reviewing, assessing, tailoring and improving our
products and services and similar products and services offered by Pen
* We have a legitimate business interest (to market our services)
* Not applicable
To apply for and claim on our own insurance.
* We have a legitimate business interest (to have our own insurance)
* We have your explicit consent
* It is necessary to establish, exercise or defend our legal rights
Advertising, marketing, and promotional purposes, including to reach you by
email, post or telephone with more relevant advertisements and to evaluate,
measure and improve the effectiveness of our advertising campaigns; to send you
newsletters, offers or other information we think may interest you; to contact
you about our services or information we think may interest you; and to
administer promotions
* With your consent, or based on a legitimate business interest or as otherwise
permitted by law
* Not applicable
Advising, improving or developing products and services through risk modelling
and data analysis, e.g. understanding risk exposures, crafting solutions with
appropriate insurance coverage, limits, deductibles based on historical dataset
* We have a legitimate business interest (to improve and develop products and
services by drawing on our experience with ongoing and prior relationships)
* Not applicable
▲ Back to Brokers, insurers and reinsurers
3.6.5. Who will we share your personal information with?
We may share your personal information with companies in the Arthur J. Gallagher
group to serve you, including for the activities listed above.
We may share personal information with the following third parties for the
purposes set out above:
* our insurance partners such as other insurance intermediaries, insurers,
reinsurers or other companies who act as insurance distributors
* other third parties who assist in the administration of insurance policies
and claims such as loss adjusters, claims handlers, accountants, auditors,
lawyers and other experts
* insurance broking platform providers
* fraud detection agencies and other third parties who operate and maintain
fraud detection registers
* investigative firms we ask to look into claims on our behalf in relation to
suspected fraud
* our regulators
* the police and other third parties or law enforcement agencies where
reasonably necessary for the prevention or detection of crime
* other insurers who provide our own insurance
* industry bodies
* credit reference agencies
* our third party services providers such as IT suppliers, finance and payment
providers, actuaries, auditors, lawyers, marketing agencies, document
management providers, tax advisers and insurance software providers
* selected third parties in connection with the sale, transfer or disposal of
our business
If you would like further information regarding the disclosures of your personal
information, please see the "Contacting us" section below for our contact
details.
▲ Back to Brokers, insurers and reinsurers
Users of our various Pen websites
This section will detail what personal information we collect about you and use
if you access and use any of the Pen websites.
* 3.7.1. What personal information might we collect?
* 3.7.2. How will we collect your personal information?
* 3.7.3. What will we use your personal information for?
* 3.7.4. Who will we share your personal information with?
▲ Back to Our processing of your personal information
3.7.1. What personal information might we collect?
* General information collected via the website such as your name, job title
and company you work for
* Contact details including telephone number and email address
* Any information that you choose to provide to us in relation to the nature of
your query
* Your IP address
* Your marketing preferences
* Information obtained through our use of cookies. Please see our cookies
policy for more information
▲ Back to Users of our various Pen websites
3.7.2. How will we collect your personal information?
* Directly from any of the Pen websites you use
▲ Back to Users of our various Pen websites
3.7.3. What will we use your personal information for?
We may process your information for a number of different purposes. For each
purpose we must have a legal ground for such processing and we will rely on the
following legal grounds:
* We have a legitimate business interest to use your personal information such
as maintaining our business records, monitoring usage of our website and
marketing our services and improving our business model and services. When
using your personal information for these purposes, we have considered your
rights and ensured that our business need does not cause you harm.
* We have a legal or regulatory obligation to use your personal information.
For example, our regulators impose certain record-keeping rules which we must
adhere to.
Please see below for further details of the different ways we use your personal
information and the legal grounds we rely on when doing so.
Purpose for processing Legal grounds for using your personal information Legal
grounds for using your special categories of information Communicating with you
and responding to any enquiries you have
* We have a legitimate business interest (to respond to any enquiries)
* Not applicable
Monitoring and analysing usage of any of the various Pen websites and presenting
relevant information to you based upon your browsing habits
* We have a legitimate business interest (to assess usage of our website and to
point you to relevant materials based upon your browsing habits)
* Not applicable
Advertising, marketing, and promotional purposes, including to reach you by
email, post or telephone with more relevant advertisements and to evaluate,
measures and improve the effectiveness of our advertising campaigns; to send you
newsletters, offers or other information we think may interest you; to contact
you about our services or information we think may interest you; and to
administer promotions.
* • With your consent, or based on a legitimate business interest or as
otherwise permitted by law
* Not applicable
▲ Back to Users of our various AJG websites
3.7.4. Who will we share your personal information with?
We may share your personal information with companies in the Arthur J. Gallagher
group for the purposes set out above.
▲ Back to Users of our various Pen websites
Members of a Scheme that we administer
This section will detail what personal information we collect about you and use
if you are a member of a Scheme that we administer.
* 3.8.1. What personal information might we collect?
* 3.8.2. How will we collect your personal information?
* 3.8.3. What will we use your personal information for?
* 3.8.4. Who will we share your personal information with?
▲ Back to Our processing of your personal information
3.8.1. What personal information might we collect?
* General information such as your name, your membership start and end date
* Contact details including address, telephone number and email address
* Information about your job including the company that you work for, job
title, business description
* Information captured during recordings of our telephone calls
* Information obtained through our use of cookies. Please see our cookies
policy for more information
* Your marketing preferences
* Any information we record about your preferences when doing business with us
▲ Back to Members of a Scheme that we administer
3.8.2. How will we collect your personal information?
We may collect your information in a number of different ways:
* We will obtain your personal information directly from you or from someone
else on your behalf in a number of ways including where it is submitted
through our website or in application forms, through interactions with our
website and more generally during any forms of communication such as face to
face, written and telephone correspondence
* From third parties who might introduce potential Scheme members to us
* Via publicly available sources such as internet search engines, open
electoral registers and social media sites
▲ Back to Members of a Scheme that we administer
3.8.3. What will we use your personal information for?
We may process your information for a number of different purposes. For each
purpose we must have a legal ground for such processing and we will rely on the
following legal grounds:
* We need to use your personal information to enter into or perform our
contract with you. For example, in order to fulfill our obligations under our
contract to provide Scheme Administration services to you
* We have a legitimate business interest to use your personal information such
as maintaining our business records, keeping records of insurance policies we
place and analysing and improving our business model and services. When using
your personal information for these purposes, we have considered your rights
and ensured that our business need does not cause you harm
* We have a legal or regulatory obligation to use your personal information.
For example, our regulators impose certain record-keeping rules which we must
adhere to
Please see below for further details of the different ways we use your personal
information and the legal grounds we rely on when doing so.
Purpose for processing Legal grounds for using your personal information Legal
grounds for using your special categories of information To set you up as a
member of a Scheme we administer and to manage your Scheme membership including
operations such as processing payments, managing membership databases,
maintaining accounting records, analysis of financial results, complying with
internal audit requirements
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to ensure that you can reap the
benefits of being a member of the Scheme and to carry out business operations
and activities that are necessary for the everyday running of a business)
* Not applicable
General client care, communicating with you, responding to any enquiries you
have
* It is necessary to enter into/perform our contract
* We have a legitimate business interest (to generally respond to our
customers)
* Not applicable
Providing improved quality, training and security (for example, with respect to
recorded or monitored phone calls to our contact numbers)
* We have a legitimate business interest (to continually improve our services)
* Not applicable
Monitoring applications, reviewing, assessing, tailoring and improving our
products and services and similar products and services offered by Pen
* We have a legitimate business interest (to market our services)
* Not applicable
Tracing and recovering debt
* We have a legitimate business interest (to trace and receive any debt which
is owed to us)
* Not applicable
Advertising, marketing, and promotional purposes, including to reach you by
email, post or telephone with more relevant advertisements and to evaluate,
measures and improve the effectiveness of our advertising campaigns; to send you
newsletters, offers or other information we think may interest you; to contact
you about our services or information we think may interest you; and to
administer promotions
* With your consent, or based on a legitimate business interest or as otherwise
permitted by law
* Not applicable
Advising, improving or developing products and services through risk modelling
and data analysis, e.g. understanding risk exposures, crafting solutions with
appropriate insurance coverage, limits, deductibles based on historical dataset
* We have a legitimate business interest (to improve and develop products and
services by drawing on our experience with ongoing and prior relationships)
* Not applicable
▲ Back to Members of a Scheme that we administer
3.8.4. Who will we share your personal information with?
We may share your personal information with companies in the Arthur J. Gallagher
group to serve you, including for the activities listed above.
We may share personal information with the following third parties for the
purposes set out above:
* Scheme administrators
* Other third parties who assist in the administration of Scheme Membership
* The police and other third parties or law enforcement agencies where
reasonably necessary for the prevention or detection of crime
* Credit reference agencies
* Debt collection agencies
* Industry bodies
* Our third party services providers such as IT suppliers, finance and payment
providers, actuaries, auditors, lawyers, marketing agencies, document
management providers, tax advisers and insurance software providers
* Selected third parties in connection with the sale, transfer or disposal of
our business
If you would like further information regarding the disclosures of your personal
information, please see the “Contacting Us” section below for our contact
details.
▲ Back to Members of a Scheme that we administer
How do we protect your personal information when sending it abroad?
Sometimes we (or third parties acting on our behalf) will transfer personal
information that we collect about you to countries outside of the United Kingdom
(“UK”) or European Economic Area ("EEA"). Our regular transfers include:
Country of transfer Reason for the transfer Method we use to protect your
information United States
* Central IT systems (including corporate emails) are routed through our US
parent company AJG & Co who also provide certain email, file share and
application support services
* Data analysis for the purposes of risk modelling, advising, improving or
developing products and services through data analysis, e.g. understanding
risk exposures, crafting solutions with appropriate insurance coverage,
limits, deductibles based on historical dataset
* Intragroup data transfer agreements (utilising Standard Contractual Clauses
(Controller to Controller))
India
* To assist with our back office functions
* Intragroup data transfer agreements (utilising Standard Contractual Clauses
(Controller to Processor))
Where other transfers to countries outside of the UK or EEA take place this will
be subject to appropriate mechanisms to ensure they have an adequate level of
protection.
If you would like further information regarding our data transfers and the steps
we take to safeguard your personal information, please see the "Contacting us"
section below for our contact details.
▲ Back to Top
What marketing activities do we carry out?
We may from time to time provide you with information about our products or
services or those of our partners which we think will be of interest to you.
These may be sent by email or post or we may contact you by telephone.
We ensure that our marketing activities comply with all applicable legal
requirements. In some cases, this may mean that we ask for your consent in
advance of sending you marketing materials.
You can opt out of receiving marketing communications at any time. An
"unsubscribe" link appears in all our marketing emails. To unsubscribe from
emails sent by us, simply click on the link at any time. Alternatively, you can
contact us to update your preferences at uk.unsubscribe@penunderwriting.com or
uk.unsubscribe@oamps.co.uk. In such circumstances, we will continue where
necessary to send you service related communications including information
related to the renewal of your policy.
▲ Back to Top
How long do we keep personal information for?
We will only store your personal information for as long as reasonably necessary
to fulfil the purposes set out in this Privacy Notice and to comply with our
regulatory and/ or legal obligations.
When personal information is no longer needed, we de-identify or aggregate the
data (in which case we may retain this de-identified or aggregated data for
analytics purposes) or securely destroy it.
We have a detailed retention policy in place which governs how long we will hold
different types of information for. The exact time period will depend on the
purpose for which we collected that information, for example:
Purpose Retention period Providing a quote 15 months from issue Providing or
administering an insurance policy Depending on the type of policy this would be
between 7 and 40 years from expiry Handling a claim 6 years after
settlement/closure Dealing with a complaint 6 years after resolution/closure
For further information regarding how long your personal information will be
kept, please see the "Contacting us" section below for our contact details.
▲ Back to Top
Automated processing and profiling
In order to determine insurance limits and insurance premiums, insurance market
participants benchmark client and beneficiary attributes and likelihood for
insured events to occur and to understand fraud patterns. This requires that Pen
and other insurance market participants may compile and analyse information in
respect of all insureds, beneficiaries and claimants to model such likelihoods.
We may use personal and commercial information in order to create the models and
also to match against the models (profiling) to determine both the risk and the
premium price for you and other insureds based on similar exposures and risks.
We also use this information to help advise you about the typical levels of
insurance coverage that your peers may have in place. This may necessitate the
use of special categories of data and criminal records data (such as prior
motoring convictions for motor insurance).
Where a decision is necessary in relation to your insurance policy sometimes we
may make decisions using automated means. The automated process will consider
the information that you provide us (for example, details of the property that
you wish to insure), as well as other information such as postcode, information
resulting from analytics, and local crime rate, to determine whether your
application for insurance can be accepted and the associated premium. Where we
make automated decisions about you using your personal information, you may
request that the decision is verified to confirm that the automated decision has
been made correctly as well as to ask that it be reviewed by an individual
decision-maker.
▲ Back to Top
Your rights
Under data protection law you have the right to make certain requests in
relation to the personal information that we hold about you. We will not usually
make a charge for dealing with these requests. If you wish to exercise these
rights at any time please contact us using the details set out in the
"Contacting us" section.
There may be cases where we may not be able to comply with your request (such as
where this would conflict with our obligation to comply with other regulatory
and/ or legal requirements). However, if we can't comply with your request, we
will tell you the reason, and we will always respond to any request you make.
There may also be circumstances where exercising some of these rights (such as
the right to erasure, the right to restriction of processing and the right to
withdraw consent) will mean your insurance can no longer be provided and it may
therefore result in cancellation of your policy. You will therefore lose the
right to bring any claim or receive any benefit, including in relation to any
event that occurred before you exercised your right of erasure, if our ability
to handle the claim has been prejudiced. Your policy terms and conditions set
out what will happen in the event your policy is cancelled.
Your rights include:
The right to access your personal information
You are entitled to a copy of the personal information we hold about you and
certain details of how we use it.
We will usually provide you with your information in writing, unless you request
otherwise, or where you have made the request using electronic means, in which
case the information will, where possible, be provided to you by electronic
means.
The right to rectification
We take reasonable steps to ensure that information we hold about you is
accurate and complete. However, you can ask us to amend or update it if you do
not believe this is the case.
The right to erasure
You have the right to ask us to erase your personal information in certain
circumstances, for example where you withdraw your consent or where the personal
information we collected is no longer necessary for the original purpose. This
will need to be balanced against other factors however. For example, we may have
regulatory and/ or legal obligations which mean we cannot comply with your
request.
The right to restriction of processing
In certain circumstances, you are entitled to ask us to stop using your personal
information, for example where you think that we no longer need to use your
personal information or where you think that the personal information we hold
about you may be inaccurate.
The right to data portability
You have the right, under certain circumstances, to ask that we transfer
personal information that you have provided to us to another third party of your
choice.
The right to object to marketing
You can ask us to stop sending you marketing messages at any time. You can do
this either by clicking on the "unsubscribe" link which is contained in any
email that we send to you or you can use the details set out in the "Contacting
us" section to contact us. If you opt out of receiving marketing messages, we
may still send you service related communications where necessary including
information related to the renewal of your policy.
Rights relating to automated decision-making
You can contact us using the details set out in the "Contacting us" section and
ask us to review the decision if you have been subject to an automated decision
using your personal information.
The right to withdraw consent
We will ask for your consent for certain uses of your personal information.
Where we do this, you have the right to withdraw your consent to further use of
your personal information.
The right to lodge a complaint with the ICO
We would always encourage you to contact us if you have any concerns with how we
use your personal information and we will do our best to resolve your concerns.
Where you feel that we have not addressed your concerns appropriately please
contact our data protection officer using the details in the Contacting Us
section. However, you have a right to complain to the Information Commissioner's
Office if you believe that any use of your personal information by us is in
breach of applicable data protection laws and/ or regulations. More information
can be found on the Information Commissioner’s Office website:
https://ico.org.uk/. This will not affect any other legal rights or remedies
that you have.
▲ Back to Top
How we protect your information
To protect your information we use a range of organisational and technical
security measures.
Where we have given you (or you have chosen) a password, you are responsible for
keeping this password confidential. Please do not share your password with
anyone.
Within Pen we restrict access to your information as appropriate to those who
need to know that information for the purposes set out above.
We use firewalls to block unauthorised traffic to the servers and the actual
servers are located in a secure location which can only be accessed by
authorised personnel. Our internal procedures cover the storage, access and
disclosure of your information.
▲ Back to Top
Contacting us
You may contact our data protection officer if you have any questions about how
we collect, store or use your personal information:
Pen
Data Protection Officer
The Walbrook Building
25 Walbrook
London EC4N 8AW
Email: UK.DPO@penunderwriting.com
OAMPS
The Walbrook Building
25 Walbrook
London EC4N 8AW
Email: UK.DPO@oamps.co.uk
▲ Back to Top
Updates to this Privacy Notice
We may update this Privacy Notice periodically. When we do, we will post the
current version on this site, and we will revise the version date located at the
bottom of this page. We encourage you to periodically review this Privacy Notice
so that you will be aware of our privacy practices.
This Privacy Notice was last updated on: 1 July 2020
▲ Back to Top
* Legal and Regulatory Information
* Modern Slavery Act
* UK Privacy Notice
* EEA Privacy Notice
* Cookie Policy
* Complaints
67 Lombard St, London, EC3V 9LJ
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