This Privacy Statement relates to our use of any personal data you provide, and contains details of how we collect, use, disclose, transfer and store your personal data in connection with your relationship with HIBCI, and in particular for your use of HIB's services.
In order to provide you with the products you require and the most suitable solutions, we are required to collect personal data about you. HIBCI is committed to safeguarding your personal data and is registered as a data controller with the Guernsey Data Protection Authority. This means that we are responsible for deciding how we hold and use personal data that relates to you.
Whenever you provide personal data we are legally obliged to use your data for a lawful purpose and the processing must be fair and transparent in line with the Data Protection (Bailiwick of Guernsey) Law, 2017. We are also required under the data protection legislation to notify you of the information contained in this Privacy Statement.
This Privacy Statement applies to current and former clients of HIBCI. This Privacy Statement does not form part of any contract to provide services, and we may update this Privacy Statement at any time.
It is important that you read this Privacy Statement, together with any other privacy notice or statement we may provide on specific occasions when we are processing personal data relating to you, so that you are aware of how and why we are using such information.
Data protection principles
HIBCI will comply with data protection law. This means that personal data we hold about you must be:
- Used in a lawful, fair and transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Adequate, relevant and limited to what is necessary for those purposes;
- Accurate and kept up-to-date;
- Kept only for as long as necessary for the purposes we have told you about; and
- Kept securely.
What data will HIBCI collect about me?
Personal data includes any information about an individual from which that person can be identified. It does not include anonymised data where the identity has been removed.
There are also "special categories" of data of more sensitive personal data that require a higher level of protection.
By entering your details in the fields requested in application forms, or by communicating your details directly to HIBCI, and by using HIBCI's services you will be providing personal data to HIBCI to enable HIBCI to provide you with the services you have selected. Such personal data may include, for example, contact details, date of birth, gender, bank account and payment card details (payment card details are processed but not stored by HIBCI). HIBCI may also collect, store and use the following special categories of more sensitive personal data relating to you:
- Information about your health, including information about any medical condition, injury or illness;
- Genetic and biometric information; and
- Criminal history (if any).
How will HIBCI use the data they collect about me?
We will only use your personal data when the law allows us to. Most often we will use your personal data in the following circumstances:
- Where we are performing a contract that we have entered into with you for products or services;
- Where we must comply with a legal obligation; or
- Where it is necessary for our legitimate interest (or those of a third party), such as for direct marking purposes, and your interests and fundamental rights do not override those interests.
The situations in which we will process your personal data are listed below:
- To provide insurance brokerage services to you, and about your continuing relationship with HIBCI;
- To make a decision about, and determine the terms for, your use of HIBCI's services;
- To carry out our obligations arising from any contracts entered into between you and us;
- To provide you with the information and the services that you request from us including, for example, to administer your insurance policy and to facilitate the provision of certain services to us by third party service providers and other transactions;
- To provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
- To maintain our records;
- To send you newsletters and promotions and to conduct surveys and other promotions via email, telephone or post;
- Processing payments, including issuing invoices and preparing direct debits and standing orders;
- To conduct data analytics studies to review and better understand your use of HIBCI's services;
- Business management and planning, including accounting and auditing;
- Complying with our regulatory obligations;
- Dealing with legal disputes involving you, or HIBCI's employees, workers and contractors;
- To prevent crime and fraud;
- To monitor our information and communication systems to ensure compliance with our IT policies;
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution;
- To contact you about a submission you have made to our website, including any content you provide; and
- To personalise the way we present content to you.
HIBCI may anonymise your personal data so that it can no longer be associated with you, in which case we may use such personal data without any further notice to you.
Sensitive personal data (special category personal data)
Higher levels of protection are required for "special categories" of particularly sensitive personal data, and HIBCI needs to have further justification for collecting, storing and using this type of personal data.
HIBCI has a legal obligation to obtain sufficient knowledge of its clients to ensure that any advice is suitable to its clients' requirements. This may include collecting and using particularly sensitive information about your health for providing advice in relation to certain types of insurance policies. Such information can include information about any medical condition, injury or illness, and genetic information and biometric data. HIBCI may also have a legal obligation to collect any criminal information that relates to you. HIBCI may use such special categories of personal data in the following circumstances:
- To provide HIBCI's services;
- To make a decision about, and determine the terms for, your use of HIBCI's services;
- For your actual use of HIBCI's services;
- To comply with our legal obligations;
- To deal with legal disputes involving you, or HIBCI's employees, workers and contractors; and
- Where it is needed to protect your vital interests (or someone else's vital interests) and you are not capable of giving your consent, or where we cannot reasonably be expected to obtain your consent.
What if I fail to provide personal data to HIBCI?
If you fail to provide certain information when requested, we may not be able to perform the contract and provide our services to you, or we may be prevented from complying with our legal obligations, or insurers might reject claims for failure to disclose key information.
Will HIBCI use automated decision-making?
Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. HIBCI may use automated decision-making in the following circumstances:
Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights; and
In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
Where HIBCI uses automated decision-making, we will provide information to you about the systems used and the consequences for you from using automated decision-making.
Will HIBCI share my personal data with anyone else?
As part of arranging a contract of insurance, HIBCI will provide your information to those insurers and underwriters etc. necessary to obtain insurance terms and ultimately bind the business should you wish to proceed. Once bound, information will pass between that party and HIBCI to enable the ongoing administration of the contract.
HIBCI does outsource processing of personal data to third parties in order to provide the required service to you. This is done under a written agreement with the processor and HIBCI remains responsible for the security of your personal data.
Other than as explained in this Privacy Statement, we will keep your data confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies).
HIBCI does not sell or otherwise transfer any personal data to commercial companies or other organisations, with the exception of obtaining website statistics (please refer to our Cookie and Website Use Policy) and asset purchasers (see below).
Asset purchasers. We will not sell your personal information to third parties other than to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice. In the event that it is necessary for HIBCI to transfer your personal data to a country or territory that is outside of the Bailiwick of Guernsey, the EU or the UK, HIBCI will inform you of the name of that country or territory and the purpose for the transfer. HIBCI will also inform you whether that country or territory has an adequacy decision by the European Commission. If the country or territory does not have an adequacy decision, that country or territory is not deemed to provide an adequate level of protection for your personal data.
To ensure that your personal data receives an adequate level of protection, HIBCI will put in place appropriate measures to ensure that your personal data is treated by third parties in countries and territories outside of the Bailiwick of Guernsey, the EU and the UK in a way that is consistent with and which respects the Guernsey, EU and UK laws on data protection. If you require further information about these protective measures, you can request it by contacting: email@example.com.
How long will HIBCI keep my personal data?
HIBCI will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your personal data, we consider the amount and nature of the personal data, whether the personal data is sensitive information (special category personal data), the potential risk of harm from unauthorised use or disclosure of the personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Once you are no longer a client of HIBCI we will retain and securely destroy your personal data in accordance with applicable laws and regulations.
What are my data protection rights?
It is important that the personal data HIBCI holds about you is accurate and current. Please keep us informed if your personal data changes whilst you are a client of HIBCI.
In certain circumstances you may have the right to:
- Request access to your personal data ("data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully using it;
- Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected;
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to use it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing;
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes;
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; or
- Request the transfer of your personal data to another party.
If you wish to review, verify, correct or request erasure of your personal data, object to the use of your personal data, or request that we transfer a copy of your personal data to another party, please contact: firstname.lastname@example.org
HIBCI will not charge a fee for providing access to your personal data (or to exercise any of your other rights). However, HIBCI may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, HIBCI may refuse to comply with your request in such circumstances.
HIBCI may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any other person who has no right to receive it.
Changes to HIBCI’s Privacy Statement
HIBCI reserves the right to update this Privacy Statement at any time, and we will provide you with a new privacy statement or notice when we make any substantial updates. We may also notify you in other ways from time to time about the use of your personal data.
Please note that in accordance with our terms of business, telephone calls, including mobile communications, may be recorded.
Tel: +44 (0) 1481 704649
Att : Compliance
Heritage Insurance C.I. Brokers Limited
PO Box 225
Le Marchant Street
St Peter Port
You have the right to make a complaint at any time to the Data Protection Commissioner or the Data Protection Authority (as applicable) in Guernsey.
Revised 12 June 2019
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