Legal Notice

                     SWEENEY INSURANCE ASSOCIATES LTD PRIVACY NOTICE

 

HOW WE PROTECT YOUR PERSONAL INFORMATION

PLEASE READ THIS CAREFULLY

 

  1. What Data do we collect and where do we get it from?

 

For the purposes set out in this notice, the Information Commissioner (ICO) requires us to advise you that, information, including personal information detailed below relating to you or anyone else to be covered by an insurance policy ("Personal Data and Special Categories of Data") will be collected and processed by Sweeney Insurance Associates Limited and/or on its behalf by its third party service providers.  This data will be provided by you, or any other person you may appoint to provide us with information.  You will either be completing application forms or answering questions we ask you, in order to provide the required information.We may also obtain information from other sources that is readily available in the public domain such as the Internet of Things (IoT), Social Media, Press etc.

 

Personal Data….

This is information we may gather from you that will directly or indirectly identify you as individual, and may also provide information about your cultural or social identity.  This type of data must be processed strictly in accordance with our Basis at Law stated in the table below.  This data will include but may not be limited to:-

 

Your title, name, postal address, risk address, civil status, gender, current and or previous occupation, date of birth, contact details, registration number, mental health conditions, bank details, credit / debit card details, credit searches, National Insurance Number, Next of Kin information, children’s data where the child is under 16 (only for travel insurance policies)

Special Categories of Data….

This is information we may gather from you that might reveal your racial or ethnic origin, political opinions, religious or philosophical beliefs, your health, sex life or sexual orientation.  This data will be processed strictly in accordance with the Basis at Law stated in the table below. This data will include but may not be limited to:-

 

Your title, gender, race, ethnic origin, political opinions, religious beliefs, physical or medical health conditions, driving licence origin, UK residency period, children’s data where the child is under 16 (only for travel insurance policies), criminal history.  Data for criminal convictions and offences will only be collected as permitted by UK Law.

 

We will have asked for, and recorded either your verbal or documented consent to process any special categories of data that we may have collected from you.

 

Each time you visit our website, we may automatically collect Technical information including IP address. 

 

The controller of this Personal Data is Sweeney Insurance Associates Limited ("we" and "us"). of 35 – 37 Station Road, Billingham, Cleveland TS23 1AF If you have any query, please contact john@sweeneyinsurance.co.uk.  We process your Personal Data in accordance with this Privacy Notice, which is also available on www.sweeneyinsurance.co.uk.

 

  1. How and why do we Process Your Personal Data?

 

The following tables detail :-

 

  • why we collect your data and the consequences of not providing it

  • our legal basis as required by the Regulations

  • who we share your data with and why

  • how long we will retain your data

     

Legal basis for processing

Why we collect your data

We obtain, collect and process your Personal Data and Special Categories of Data (which includes sharing your data with others) to enable us to quote for your insurance needs, place you on cover, make any payment arrangements requested, make any alterations to your policy that you may request during the policy term, and in the unfortunate event that a claim occurs we will need to share your information to help you make your claim.  We may also have regulatory and / or legal obligations for sharing data with others, but we will only share it for the purposes stated, or in a way you would reasonably expect us to, unless we inform you otherwise.   If you do not provide the data requested it may not be possible to obtain a quote or provide you with a policy.

Our legal basis for processing your data

In order to arrange your insurance we will be using one or more of the following legal bases:-

 

  • In respect of children’s data, a child being a person under the age of 16, which is only collected for the purposes of arranging travel insurance, we will seek parental consent to hold the data and record that consent.
  • We will seek consent from you, either verbal over the phone, or signed consent from you where we are face to face, to enable us to process any special categories of data we may obtain from you, as described above.
  • Processing is necessary in order for us to take steps, at your request, to enter into a contract of insurance when you ask us to place cover, and for the performance of that contract when you need to make a claim.
  • Processing is necessary for us to comply with any legal or regulatory obligation
  • Where we believe a customer is vulnerable, processing might be necessary to protect the vital interests of that person or other person covered by the policy
  • We may have a legitimate interest in processing the data for changes to any quotation or policy which you may request, or for any other reason necessary to undertake any other requests related to your insurance policy

 

Who we share your data with and the reason for processing

We are a Data Controller and in order to process your requests we may be sharing your data with one or more other Data Controllers.  The Controllers we may share with and our reasons for sharing that information are listed but not limited to the following:-  

Insurers

Quotation, cover, to manage and progress claims

Insurance Providers, (Placing Brokers, Delegated Authority Schemes, Wholesalers and the like)

Quotation, cover, to manage and progress claims

Loss Adjusters

To manage and progress claims

Insurance Fraud Bureau

Potential policy fraud

Loss Assessor

To manage and progress claims

Financial Conduct Authority

Regulatory obligations

Financial Services & Compensation Scheme

Compensation in the event of insurer failure, if eligible

Financial Ombudsman Service

Unresolved Complaints, if eligible

National Crime Agency

Suspected criminal / fraudulent activity

HM Treasury Sanctions

Checking clients are not on the banned list

Premium Finance Company

Payment of premiums

Police

Legal obligations

Possible Suppliers

  Insurers replacement factilities - ie, white goods,

  jewellers, cleaning companies, restoration companies,

  approved repairers and garages, windscreen         

  replacement company, plumbers, builders, electricians  

  and the like.           

Staff

  Administering the quotation and policy, claims or

  payments.  Back Up Of Data

Claims Management Company

To manage and progress claims

Surveyor

  Risk survey to analyse, report upon risk.  Also in the

  event of a loss, the opportunity to survey post-loss

Debt Agency

To collect unpaid premium due

It Providers - Software

  Holds all collective management information, system

  testing when system not responding or errors occur

It Providers - Hardware, Cloud & Systems Management

  To detect issues, secure the system, and test the   

  system.  Also backup of data

Interested Parties (Mortgage Lender)

Proof of cover

Third Party Insurers

To manage and progress claims

Third Party Assessor

To manage and progress claims

Claims Management Company

To manage and progress claims

Credit Reference Agencies

  To obtain competitive premiums via some

Insurance providers

Mylicence (Uk)

To meet legislative requirements

DVLA

To meet legislative requirements

Motor Insurers Database

Registering vehicles to meet legislative requirements

Motor Insurers Bureau

To meet legislative requirements

Claims Exchange Underwriting

Sharing of previous claims information between insurers

Employers Liability Tracing Office

To provide confirmation of cover being in place

Our own Insurers

Where we need to provide information about you

Solicitor

Claims against clients or claims against us

Interpreter

  For management of the policy and claims where

language is a barrier or they use sign language

Other Data Controllers not detailed above

  To be shared only for the purposes stated, or in a way

  you would reasonably expect us to, unless we inform

  you otherwise.

How long we retain your

data

We will retain your Personal Data for as long as your insurance policy is valid with us and for 20 years thereafter.

IMPORTANT

  • For some of our products eg: motor and household insurance, we may carry out automated decision making (including profiling) to process your personal data in order for insurers to underwrite and price your insurance online and/or process your claim. We take care to ensure our profiling is fair, transparent and limited in purpose.
  • We have stated the reasons we are collecting your data above, but in the event that you do not wish to provide us with your Personal Data for all or any of the above reasons, this may limit the insurers who will quote and agree to cover, and in some cases insurers may not wish to offer cover at all. 
  • If at any point in the future we need to amend this policy, every effort will be made to make you aware and our website will always have the latest version.

 

 

  1. Where do we hold your Data?

 

At all times we will endeavour to hold your Data on servers within the UK, or within the European Economic Area (EEA).  Where we share your information with other Data Controllers they must also agree to hold your Data within the EEA.  However, in the unlikely event your data is to be held in any other geographical area we ensure that:-

 

  • Data Controllers do not do so without our prior written authority and

  • An appropriate transfer agreement is put in place to protect your personal data

     

     

    Your Acknowledgment of this Notice and YourRights

     

    Under General Data Protection Regulation you have rights and these are listed below. 

     

Right to

 

Be Informed

The General Data Protection Regulation sets out the information we must provide to you about your Data.  All of the information we are required to give you is contained within this Privacy Notice.  If you do not understand any part of this, you should contact us immediately and we will be happy to explain it to you.

Right of

 

Access

You have the right to access and obtain a copy of the Personal Data, and any supplementary information that we hold about you to enable you to verify the lawfulness of the processing carried out. This will be provided free of charge, unless your request is unfounded, excessive or repetitive, and the information will be sent to you within 30 days of your request being received.  If we refuse your request, you have the right to complain to the ICO.

Right to

 

Rectification

You have the right to request that we correct any inaccuracies in the Personal Data we hold about you.  This will be corrected within one month.  If we are unable to correct the inaccuracy you have the right to complain to the ICO.

Right to

 

Erasure

You have the right to request that we erase your Personal Data. For example, you may exercise this right in the following circumstances:

 

  • your Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed by us;
  • you withdraw consent and no other legal ground permits the processing;
  • you object to the processing and there are no overriding legitimate interests for the processing;
  • your Personal Data was unlawfully processed; or
  • your Personal Data must be erased for compliance with a legal obligation.

 

We refuse the right to delete your information when it falls within our data retention period stated above, as this data may be required to exercise or defend litigation in the event of a claim whether covered or not by the insurance policy.  If you do not agree with this you have the right to complain to the ICO.

Right to

 

Restrict Processing

You have the right to restrict our processing of your Personal Data where any of the following circumstances apply, although we will still be allowed to store it:

 

  • where you feel that the Personal Data which we hold about you are not accurate. Processing will be restricted until you verify the accuracy of the information
  • where the processing is unlawful and you do not want your Personal Data be erased and request the restriction of its use instead;
  • where we no longer need to process your Personal Data but the data may be required to establish, exercise or defend a legal claim
  • where you have objected to our processing of your Personal Data pending the verification of whether or not our legitimate business interests override your interests, rights and freedoms.

 

Where you exercise your right to restrict our processing of your Personal Data, we will only continue to process it in accordance with the requirements of this policy or our legal obligations.

Right to

 

Data Portability

You have a right to receive and transfer the Personal Data that we hold about you.  This only applies to:-

 

  • personal data you have provided to us
  • where the data was processed by you giving us your individual consent or for the performance of a contract
  • and where processing was carried out by automated means.

 

Where you make such a request, this will be provided in a structured, commonly used, machine readable format such as a CSV file.  This will be completed within one month of us receiving your request.

Right to

 

Object to Processing

In certain circumstances, you have a right to object to our processing of your Personal Data

 

  • Where we have processed it as a legitimate interest (including profiling)
  • Direct Marketing (including profiling)
  • Processing for scientific / historical research and statistics

 

We will still be able to process your Personal Data where

 

  • We can demonstrate compelling legitimate grounds for us to process your Personal Data which override your interests, rights and freedoms
  • The processing is for establishment, exercise and defence of legal claims.

 

Right to

 

Object to automated decision making including profiling

You have a right not to be subjected to decisions being made solely by automated means without any human involvement.  This might be the case where quotations are obtained online.  We will still be able to carry out this type of decision-making where:-

 

  • It is necessary to enter into or for the performance of a contract (such as a contract of insurance) which is the main reason we would use this type of decision-making; or
  • You have given your explicit consent for us to do so.

 

We will only process data in the way you would expect it to be used, and you will be entitled to have a person from our firm to review the decision so that you can query it and set out your point of view and circumstances to us.

Right to

 

Withdraw Consent

Where the legal basis of Consent has been used for Childrens’ data or special categories of data, you have the right to withdraw that consent at any time.  Where you exercise your right to withdraw consent of the processing of any children’s data or special categories of data, any data processed prior to the withdrawal of consent will remain valid.

 

You may raise any concerns about Sweeney Insurance Associates Ltd processing of your Personal Data with the Information Commissioner Office on https://ico.org.uk/.

 

  1. Changes to this Notice

 

We may amend this notice on occasion, in whole or part, at our sole discretion. Any changes to this notice will be effective immediately upon sending the revised notice to you by e-mail or post.  If at any time we decide to use your Personal Data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail or post and you will have a choice as to whether or not we use your information in the new manner.  If you have questions or concerns about this notice, please contact sue@ciclimited.com.

 

  1. Information about or provided by another person

 

Where your information for your policy has been provided to us by another person, we will send you a copy of this privacy notice directly to you, where we have your address, within one month of your policy being taken out.  If we do not have / are unable hold your address for any reason, we will send a copy of this to the person arranging the insurance with instructions to pass this to you within one month.  Where you have taken out a policy and provided us with information about another person, eg: an additional driver to your motor policy, an additional person to your travel insurance particularly where health conditions have been disclosed, it is unlikely we will have their address, and therefore you must provide them with a copy of this Privacy Notice so that they will know how their data is being used.  Additional copies can be supplied on request

 

Client Agreement - How we are regulated

 

Sweeney Insurance Associates Limited, 35-37 Station Road, Billingham, Cleveland, TS23 1AF. Telephone 01642 360222.

 

The Regulator

The Financial Conduct Authority (FCA) is an independent watchdog that regulates financial services. Our Financial Services Register number is 310183 and you can check our status and permissions at https://register.fca.org.uk/ or by contacting the FCA on 0800 111 6768.

 

Our Activities

The FCA has authorised us to advise, arrange, deal in and assist with the placing and administration of all types of General Insurance policies and Pure Protection policies. We are also authorised to undertake the following Consumer Credit Activities - Credit Broking (where we act as a credit broker)

 

Our Service

We can act both as agent of insurer, and on behalf of you, the customer. We have in place management controls to deal with any conflicts of interest that might arise. Unless we advise you otherwise, we are acting on your behalf. We also act on behalf of insurers when collecting premiums under risk transfer (See "Money" section).We will ask questions to enable us to assess reasonably your insurance requirements, this may include checking information that we already hold about you and your existing insurance arrangements with us and other parties. We will provide you with advice and guidance, after assessing what you want and need and recommend a suitable policy based on our experience of dealing with similar risks.

We will confirm to you the level of service we are providing as part of our sales process. In all cases our service will include arranging and administering your insurance, including helping you with on-going changes. If we use the services of another intermediary to place your insurance we will advise you of the name of the intermediary we use and the name of the insurer

 

Our Product Selection (Fair Analysis)

We offer products from a wide range of insurance companies. Our selection usually involves presenting to a reasonable number of insurance companies that will insure for the risk at hand, and this is called a fair analysis of the market. Sometimes we may only approach two or three insurers and this is a limited Panel, or in some cases, we may only approach one insurer, in either case, we will tell you the basis as part of our selling process. You can also request a list of the companies that form the Panel we have approached.

 

Confidentiality and Data Protection

We will exchange the information that you provide to us with insurance companies and other brokers or agents for the purposes of obtaining quotations and arranging cover, this may result in a credit check to confirm your identity and minimise the risk of fraud. We will treat all information as private and confidential, and in strict accordance with the General Data Protection Regulation (GDPR) 2018, even when you are no longer a customer and only share information if we are required to do so by law, or regulation. Under the GDPR you also have a right to Access, Rectification and Erasure. You have a right to a copy of any personally identifiable information about you that we hold in our records, you can obtain details by writing to us at the usual address. A nominal charge might apply in providing the information to you. We will, in addition use information for marketing similar products or services by us and carefully selected companies. Contact may include SMS text, post, telephone or e-mail. If you do not want us to use your information in this way, please let us know. A copy of our Privacy Notice can be seen on our website. Sweeneyinsurance.co.uk

 

Our Remuneration

We usually receive a commission from the insurance provider with whom we place your business, and in such a case, the commission will be paid to us either when we are in receipt of cleared funds from you (or the premium finance company, if one has been used) or, when the insurer has received cleared funds from us in respect of the premium due under your policy. The individual agreements we have with each insurer will determine which of the two methods above is used to make this transfer of commission. We also receive commission for arranging finance agreements for the payment of insurance premiums and this is usually expressed as a percentage of the individual loan and is paid to us directly by the premium finance provider. We may also receive a commission or fee for passing introductions to other professional firms. In addition, we also charge you a fee for arranging your insurance, £15 for Motor and Household Policies, £25 for smaller Commercial Policies and a variable fee for larger complex risks as notified and full details will be provided to you at outset.

 

Payment Options

We will provide you with full details of all the payment options available to you when we provide you with your insurance premium. If you choose to enter in a finance arrangement, your details will be passed to a third party (insurer or lender) to enable them to contact you and you should contact us at the address given in this document if you do not want your details passed to that party. This finance arrangement will be subject to interest charges that we will confirm to you when providing the full details. Importantly, the arrangement you will enter into will be with the finance company not us. It is an entirely separate contract irrespective of the insurance contract. In the event of your failure to meet with the contractual obligations regarding payment the finance provider could approach the insurer to seek a termination of the insurance contract to recoup their outstanding finance arrears. You will be liable to pay their costs and charges if you do not keep up your repayments and cover is cancelled under your policy. This is because the agreement is between you, the policyholder and the finance company direct, not us or the insurer.

It is important that you read the finance agreement that is sent to you before you agree to enter into such an agreement. We do not charge any fees to you for introducing you to a credit provider. If you are a consumer as defined under the Consumer Credit Act, you will have the benefit of a 14 day cooling off period.

Please Note: Your policy cover will cease if you fail to keep up payments on an instalment agreement or premium finance facility related to it.

 

Money

We will hold money that you pay to us in accordance with the regulators rules or under a risk transfer agreement with insurers. This will include holding your money in the following way.

A statutory trust client bank account that only allows us to use the money held in trust on behalf of a customer for paying that customers’ premium to an insurance company and to pay premium refunds or claims we receive from that insurance company to the customer, once the premium has been received from that insurance company. We cannot use that customer’s money to pay another customers premium or refund. We do not pay any interest on premiums held by us in the course of arranging and administering your insurance, unless, in the case of consumer transactions we receive more than £20 per transaction, and then we will ask for your permission to retain the interest. Unless you tell us otherwise, you are consenting to us holding your money in this way. By holding your money in this way, means that in the event that this firm becomes insolvent your money remains protected. In arranging your insurance we may employ the services of other intermediaries who are regulated by the FCA and your premium may be passed to these intermediaries for payment to insurers. These firms are also required to hold clients’ money in a separate trust account. We will also inform you if at any time we are required to pass your premium to firms that operate outside the UK where the protection may be different. Should you not wish us to pass premiums to a firm outside of the UK, please inform us.

 

Your Right to Cancel (Applicable to Consumers only)

Please contact us if you wish to cancel any policy that we have arranged for you. Customers acting outside their trade or profession (Consumers) will usually have a legal right to cancel policies for any reason, subject to no claims having occurred, within 14 days of receiving the full terms & conditions. This period is extended to 30 days for Pure Protection contracts. You will always be advised where this Right applies. A charge may apply for the period of cover provided and, in addition, an administration charge will apply as shown in the charges section above, cancellation under this right must be in writing, prior to expiry of the cancellation period, to our usual office address.

 

Complaints

Our aim is always to provide our customers with a first-class service; however we are aware that, occasionally, it is possible that we may fail to meet your expectations. If for any reason we have not met your expectations, let us know as soon as possible, by calling our main office telephone 01642 360222

Or write to John Sweeney at the above address. If we are unable to resolve the issue to your satisfaction by the end of the next business day, we will formally investigate the matter. You will receive an acknowledgement of the matter together with a copy of our complaints process promptly and certainly within 5 working days. We will then aim to investigate and provide a resolution as quickly as possible, informing you of a final response no later than 8 weeks. If you are not happy with our response, or the position after a period of 8 weeks, you may be eligible to refer your complaint to the Financial Ombudsman Service (FOS) for an independent assessment and opinion.

The FOS Consumer Helpline is on 0800 023 4567 (free for people phoning from a "fixed line" (for example, a landline at home) or 0300 123 9123 (free for mobile-phone users paying monthly charge for calls to No’s starting 01 or 02). Alternatively you can contact them at Financial Ombudsman Service, Exchange Tower, Harbour Exchange Square, London, E14 9SR. www.financial-ombudsman.org.ukA full copy of our complaints procedure is available on request.

 

Financial Services Compensation Scheme (FSCS)

If we are unable to meet our obligations, you may be entitled to compensation from the FSCS. If we have advised or arranged insurance for you this will be covered for 90% of a claim, without any upper limit, however claims under compulsory insurance, professional indemnity insurance and certain claims for injury, sickness or infirmity of the policyholder are protected at 100%. Further information is available from the FSCS helpline on 0800 678 1100 or 020 7741 4100 and www.fscs.org.uk.

The FSCS is the UK’s statutory fund of last resort for customers of authorised financial services firms. Compensation is usually payable if an authorised firm is unable or unlikely to pay claims usually because it has ceased trading or become insolvent

 

V2 – 22.05.2018

 

 

 

We are located at:

St. Cuthberts House

35/37 Station Road

Billingham 

Teesside

TS23 1AF

If you have any queries or wish to make an appointment, please contact us:

 

Main Office: 01642 360222

Mobile: 07900 692163

(Out of Hours Emergency)

 

Email Us:

john@sweeneyinsurance.co.uk

bev@sweeneyinsurance.co.uk

marie@sweeneyinsurance.co.uk

suzanne@sweeneyinsurance.co.uk

 

Or use our contact form.

Contact us today!

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© Sweeney Insurance Associates •Authorised and regulated by the Financial Conduct Authority- Reference 310183.•Registered in England and Wales, registration number 2271457.

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