Fair Processing Notice - Property Risk Solutions

The privacy and security of Your information is important to Us. This notice explains who We are, the types of information We hold, how We use it, who We share it with and how long We keep it. It also informs You of certain rights You have regarding Your personal information under current data protection law.

The terms used in this Fair Processing Notice relate to the Information Commissioner’s Office guidance. You can find out more about the Information
Commissioner’s Office at https://ico.org.uk.

Who are We?

When We refer to “We”, “Us” and “Our” in this notice it means Property Risk Solutions.

Property Risk Solutions is a trading name of Towergate Underwriting Group Ltd and is part of the Ardonagh Group of Companies. Property Risk Solutions and Allianz Insurance plc will be separate Data Controllers of the information You provide to Us. We are registered with the Information Commissioner’s Office for the products and services We provide to You. Please refer to the Allianz fair processing notice for more details about Allianz Insurance plc.

You can contact Us for general data protection queries by email to prs@towergate.co.uk or in writing to Commercial Business Director, Property Risk Solutions, Jellicoe House, Botleigh Grange Office Campus, Grange Drive, Hedge End, Hampshire, SO30 2AF.

Please advise Us of as much detail as possible to comply with Your request.

What information do We collect?

To enable Us to provide You with the right product or service to meet Your needs (or to handle a claim) We will collect personal information which may include Your name, telephone number, email address, postal address, occupation, date of birth, additional details of risks related to Your enquiry or product and payment details (including bank account number and sort code).

We may need to request and collect sensitive personal information such as details of convictions or medical history for Us to provide You with the product or service or to process a claim.

We only collect and process sensitive personal data where is it is critical for the delivery of a product or service and without which the product or service cannot be provided. We will therefore not seek explicit consent to process this information as the processing is legitimised by its criticality to the service provision. If You object to use of this information then We will be unable to offer You the product or service requested.

How do We use Your personal information?

We will use Your personal information to

  • assess and provide the products or services that You have requested
  • communicate with You
  • develop new products and services
  • undertake statistical analysis

We may also take the opportunity to

  • contact You about products that are closely related to those You already hold with Us
  • provide additional assistance or tips about these products or services
  • notify You of important functionality changes to Our websites

From time to time We will need to call You for a variety of reasons relating to Your products or service (for example, to update You on the progress of a claim or to discuss renewal of Your insurance contract). We are fully committed to Ofcom regulations and have strict processes to ensure We comply with them.

To ensure confidentiality and security of the information We hold, We may need to request personal information and ask security questions to satisfy ourselves that You are who You say You are.

We may aggregate information and statistics on website usage or for developing new and existing products and services, and We may also provide this information to third parties. These statistics will not include information that can be used to identify any individual.

Securing Your personal information

We follow strict security procedures in the storage and disclosure of Your personal information in line with industry practices, including storage in electronic and paper formats.

We store all the information You provide to Us, including information provided via forms You may complete on Our websites, and information which We may collect from Your browsing (such as clicks and page views on Our websites).

Any new information You provide Us may be used to update an existing record We hold for You.

When do We share Your information?

To help Us prevent financial crime, Your details may be submitted to fraud prevention agencies and other organisations where Your records may be searched, including the Claims and Underwriting Exchange (CUE) and the Motor Insurers Anti-Fraud and Theft Register (MIAFTR).

In addition to companies within the Ardonagh Group and within the global Allianz Group (www.allianz.com), third parties (for example loss adjustors) deliver some of Our products or provide all or part of the service requested by You. In these instances, while the information You provide will be disclosed to these companies, it will only be used for the provision and administration of the service provided (for example verification of any quote given to You or claims processing, underwriting and pricing purposes or to maintain management information for analysis).

This may also include conducting a search with a credit reference bureau or contacting other firms involved in financial management regarding payment.

The data We collect about You may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for Us or for one of Our suppliers. Such staff may be engaged in, amongst other things, the provision of information You have requested.

If We provide information to a third party We will require it and any of its agents and or suppliers to take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this fair processing notice. We may of course be obliged by law to pass on Your information to the police or other law enforcement body, statutory or regulatory authority including but not limited to the Employer’s Liability Tracing Office (ELTO) and the Motor Insurance Bureau (MIB).

If Your policy provides Employers Liability cover information relating to Your insurance policy will be provided to ELTO and added to an electronic database (the “Database”) in a format set out by the Employer’s Liability Insurance: Disclosure by Insurers Instrument 2010 We may also share Your information with anyone You have authorised to deal with Us on your behalf.

How long do We keep Your information?

We will not keep Your personal information longer than is necessary for the purpose for which it was provided unless We are required by law or have other legitimate reasons to keep it for longer (for example if necessary for any legal proceedings).

We will normally keep information for no more than six years after termination or cancellation of a product, contract or service We provide. In certain cases, We will keep Your information for longer, particularly where a product includes liability insurances or types of insurance for which a claim could potentially be made by You or a third party at a future date, even after Your contract with Us has ended.

Your rights?

Under data protection law You have the right to change or withdraw Your consent and to request details of any personal data that We hold about You Where We have no legitimate reason to continue to hold Your information, You have the right to be forgotten.

We may use automated decision making in processing Your personal information for some services and products. You can request a manual review of the accuracy of an automated decision that You are unhappy with.

Further details of Your rights can be obtained by visiting the Information.


Fair Processing Notice – Allianz

1. Who We are

When We refer to “We”, “Us” and “Our” in this notice it means Allianz Insurance plc or Allianz Engineering Inspection Services Ltd.

When We say, “Individuals” in this notice, We mean anyone whose personal information We may collect, including

  • anyone seeking an insurance quote from Us or whose details are provided during the quotation process
  • policyholders and anyone named on or covered by the policy
  • anyone who may benefit from or be directly involved in the policy or a claim, including claimants and witnesses

2. How We use personal information

We use personal information in the following ways

  • to provide quotes, administer policies and policyholder claims to fulfil Our contract
  • to administer third party claims and prevent financial crime to meet Our legal obligations
  • to manage Our business and conduct market research to meet the legitimate needs of Our business
  • to send marketing information about Our products and services if We have received specific consent

There is no obligation to provide Us with personal information, but We cannot provide Our products and services without it.

Anyone whose personal information We hold has the right to object to Us using it. They can do this at any time by telling Us and We will consider the request and either stop using their personal information or explain why We are not able to. Further details can be found below.
 

3. Automated decision making, including profiling

We may use automated decision making, including profiling, to assess insurance risks and administer policies. This helps Us decide whether to offer insurance, determine prices and validate claims.

Anyone subject to an automated decision has the right to object to it. To do so they should contact Us by emailing Us at acccsm@allianz.co.uk and We will review the decision.

4. The personal information We collect

We collect the following types of personal information so We can complete the activities in section 2, “How We use personal information”

  • basic personal details such as name, age, address and gender
  • family, lifestyle and social circumstances, such as marital status, dependants and employment type
  • financial details such as direct debit or payment card information
  • photographs and or video to help Us manage policies and assess claims
  • tracking and location information if it is relevant to the insurance policy or claim
  • identification checks and background insurance risk details including previous claims information
  • medical information if it is relevant to the insurance policy or claim
  • criminal convictions if it is relevant to the insurance policy or claim
  • accessibility details if We need to make reasonable adjustments to help
  • business activities such as goods and services offered

5. Where We collect personal information

Direct from Individuals, their representatives or information they have made public, for example, on social media

From other persons or organisations, for example

  • credit reference and or fraud prevention agencies
  • emergency services, law enforcement agencies, medical and legal practices
  • insurance industry registers and databases used to detect and prevent insurance fraud, for example, the Motor Insurance Database (MID), the Motor Insurers Anti-Fraud and Theft Register (MIAFTR) and the Claims and Underwriting Exchange (CUE)
  • insurance investigators and claims service providers
  • other insurers or service providers who underwrite the insurance or provide the services for Our products
  • other involved parties, for example, claimants or witnesses


6. Sharing personal information

We may share personal information with

  • other companies within the global Allianz Group www.allianz.com
  • credit reference, fraud prevention and other agencies that carry out certain activities on Our behalf, for example, the Motor Insurance Database (MID), the Insurance Fraud Bureau (IFB) and marketing agencies if agreed
  • Our approved suppliers to help deal with claims or provide Our benefit services, for example, vehicle repairers, legal advisors and loss adjusters
  • other insurers, third party underwriters, reinsurers, insurance intermediaries, regulators, law enforcement and the Financial Ombudsman Service (FOS); and
  • other companies that provide services to Us or You, for example, the Employers Liability Tracing Office (ELTO) and the Claims and Underwriting Exchange (CUE)
  • prospective buyers in the event that We wish to sell all or part of Our business

7. Transferring personal information outside the UK

We use servers located in the European Union (EU) to store personal information where it is protected by laws equivalent to those in the UK. We may transfer personal information to other members of the global Allianz Group to manage the insurance policy or claim; this could be inside or outside the EU. We have Binding Corporate Rules (BCR’s) which are Our commitment to the same high level of protection for personal information regardless of where it is processed. These rules align with those required by the European Information Protection authorities. For more information about BCR’s, contact Our Data Protection
Officer.

Some of Our suppliers have servers outside the EU. Our contracts with these suppliers require them to provide equivalent levels of protection for personal
information.

8. How long we keep personal information

We keep information only for as long as We need it to administer the policy, manage Our business or as required by law or contract.

9. Know Your rights

Any Individual whose personal information We hold has the right to

  • object to Us processing it. We will either agree to stop processing or explain why We are unable to (the right to object)
  • ask for a copy of their personal information We hold, subject to certain exemptions (a data subject access request)
  • ask Us to update or correct their personal information to ensure its accuracy (the right of rectification)
  • ask Us to delete their personal information from Our records if it is no longer needed for the original purpose (the right to be forgotten)
  • ask Us to restrict the processing of their personal information in certain circumstances (the right of restriction)
  • ask for a copy of their personal information, so it can be used for their own purposes (the right to data portability)
  • complain if they feel their personal information has been mishandled. We encourage Individuals to come to Us in the first instance but they are entitled to
    complain directly to the Information Commissioner’s Office (ICO) www.ico.org.uk
  • ask Us, at any time, to stop processing their personal information, if the processing is based only on individual consent (the right to withdraw consent)

If You wish to exercise any of these rights please contact Our Customer Satisfaction Manager

Address: Customer Satisfaction Manager, Allianz, 57 Ladymead, Guildford, Surrey, GU1 1DB
Email: acccsm@allianz.co.uk
Phone: 01483 552 438

10. Allianz (UK) Group Data Protection Officer Contact details

Allianz Insurance plc and Allianz Engineering Inspection Services Ltd are companies within the Allianz Holdings

Any queries about how We use personal information should be addressed to Our Data Protection Officer

Address: Data Protection Officer, Allianz, 57 Ladymead, Guildford, Surrey GU1 1DB
Email: dataprotectionofficer@allianz.co.uk
Phone: 0330 102 1837

Changes to Our Fair Processing Notice

Occasionally it may be necessary to make changes to this fair processing notice. When that happens We will provide an updated version at the earliest
opportunity.

Consent for Special Categories of Personal Data

The global Allianz Group may need to collect and process data relating to Individuals who may benefit from the policy (“Insured Persons”), which falls within the special categories of personal data under Data Protection Legislation, for example, medical history or convictions of Insured Persons for the purpose of evaluating the risk and or administering claims which may occur. You must ensure that You have explicit verbal or written consent from the Insured Persons to such information being processed by the global Allianz Group and that this fact is made known to the Insured Persons.

By applying for and or entering into this insurance policy You will be deemed to specifically consent to the use of the Insured Persons Personal Data in this way and for these purposes and that Your directors, officers, partners, and employees have consented to the global Allianz Group using their details in this way.

Employers Liability Tracing Office

If Your policy provides Employers Liability cover information relating to Your insurance policy will be provided to the Employers Liability Tracing Office (the “ELTO”) and added to an electronic database, (the “Database”) in a format set out by the Employer’s Liability Insurance: Disclosure by Insurers Instrument 2010 The Database assists individual consumer claimants who have suffered an employment related injury or disease arising out of their course of employment in the UK whilst working for employers carrying on, or who carried on, business in the UK and as a result are covered by the employers’ liability insurance of their employers, (the “Claimants”).

i. to identify which insurer (or insurers) was (or were) providing employers’ liability cover during the relevant periods of employment; and
ii. to identify the relevant employers’ liability insurance policies

The Database and the data stored on it may be accessed and used by the Claimants, their appointed representatives, insurers with potential liability for UK
commercial lines employers’ liability insurance cover and any other persons or entities permitted by law.

The Database will be managed by the ELTO and further information can be found on the ELTO website