Inigo Data Privacy Notice.
Inigo Limited values its customers and is committed to protecting and respecting your privacy; and the lawful and correct treatment of personal data. This Data Privacy Notice informs and explains how Inigo will process and protect any personal data we collect or receive about you. It applies to personal data provided by customers, brokers, coverholders, claimants, third party services providers (TPAs), complainants and job applicants. Please read this Data Privacy Notice carefully to understand our practices regarding personal data.
Your personal data has either been, or will be collected by, or transferred to, Inigo. We can be contacted via post or by email at the below addresses. We aim to respond to all correspondence within thirty (30) days.
The Data Protection Officer
7th Floor, 1 Creechurch Place
Email: [email protected]
The Inigo Data Protection Officer will handle any questions you may have on the use of your personal data and your rights as a data subject. This is covered in further detail under Your Data Subject Rights.
Types of personal data we hold:
We capture and process a variety of different types of data, including personal data depending on the nature of the services involved. This includes but is not limited to:
|Types of Personal Data||Example|
|Individual details||Name, address, other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, health, national unique identifier e.g. social security or Public Service number, passport number, driving licence number, employer, job title and employment history, and family details, including their relationship to you|
|Financial and credit information||Bank account or payment card details, income or other financial information, credit history, and credit score|
|Risk details||Information about you which we need to collect in order to assess the risk to be insured and provide a quote. This may include data relating to your health, criminal convictions, or other special categories of personal data or the health of the people to be covered.|
|Policy information||Information about the quotes you receive and policies you take out|
|Anti-fraud data||Sanctions and criminal offences, and information received from various anti-fraud databases relating to you or those seeking cover|
|Previous and current claims||Information about previous and current claims, (including other unrelated insurances), which may include data relating to your health, criminal convictions, or other special categories of personal data and in some cases surveillance reports|
Sometimes we may need to process special categories of personal data. These are certain types of personal data which require additional privacy protection. The special categories are:
- Racial or ethnic origin;
- Political opinions;
- Religious or philosophical beliefs;
- Trade union membership;
- Genetic or biometric data;
- Health data;
- Sex life or sexual orientation.
- Criminal convictions
Personal data including special category data may be required to allow us to provide a quote, underwrite your policy, consider your claim or provide other insurance services.
Why we use your personal data:
We collect your personal data to help us with advising on, arranging, underwriting or administering an insurance contract or administering a claim under an insurance contract. Specifically:
a. Advising on, arranging and underwriting your policy, including:
- Understanding your insurance requirements to offer you a product that matches your needs and circumstances
- Gaining an understanding of the nature of the risk to be covered by the policy including risk modelling and statistical use
- Providing competitive and appropriate pricing
- Performing credit or money laundering checks or other checks required by law
- Fraud prevention
b. Administering your policy, including:
- Managing any changes to your policy
- Providing and improving services under and associated with the insurance contract as appropriate
- Maintaining contact with you, for issues relating to your policy and general customer contact
c. Administering your claims, including:
- Registering your claims
- Assessing your claims, including any liaison with third parties potentially involved in your claims, e.g. communications regarding health information
- Running due diligence checks e.g. credit or money laundering
- The investigation of fraudulent claims
- The defence of or prosecution of valid and legal claims
d. Recruitment of current and former employees:
- Purpose of processing an employment application
- Assess your suitability for employment
- Assessments, tests or occupational profiles
- Providing or requesting employment references
- To carry out background checks
e. Further reasons, including:
- To ensure we comply with any legal or regulatory obligations
- The testing of our systems and processes where imitation data is unavailable. Testing which uses personal data will only by carried out in limited circumstances and only when appropriate safeguards and controls have been put in place
- To allow us to perform the essential practice and process of underwriting
- Analysing our clients and the products they select
- For reinsurances purposes
- Processing the enrolment and management of the share scheme
- To audit our business
- Transferring books of business, company sales and reorganisations
- For marketing purposes
Where we might collect your personal data from:
We might collect your personal data from various sources including:
- Your family members, employer or representative;
- Other insurance market participants such as, authorised agents, brokers, TSPs, reinsurers, other insurers, legal advisers, loss adjusters and claims handlers;
- Credit reference agencies;
- Anti-fraud databases, sanctions lists, court judgements and other databases;
- Government agencies
- In the event of a claim, third parties including any other party to the claim (such as a claimant/defendant), witnesses, experts (including medical experts), loss adjustors, legal professionals, and third party claims handlers.
- Which of the above sources apply will depend on your particular circumstances.
Our legal bases for processing your personal data
We process personal data where necessary in order to:
- Engage with you when you or someone acting on your behalf asks us for a quote and are considering entering into a contract;
- Satisfy our obligations under a contract with you;
- Comply with a legal obligation, such as due diligence and reporting obligations, and responding to binding requests from regulators, law enforcement authorities or other government authorities;
- Process data as may be required in the public interest, such as detecting and preventing fraud;
- Pursue our legitimate interests in providing clients with insurance services, improving our services, to ensure we price our products appropriately, to manage risk, to manage our business efficiently, to perform audits, and to maintain accurate records.
We process special category data when you provide explicit consent or when this is necessary to:
- Advise, arrange, underwrite or administer an insurance policy or administer a claim under an insurance policy;
- Protect, investigate, and defend legal claims;
- Exercise a right or comply with an obligation arising in connection with an insurance contract.
Who we share personal data with:
To allow us to meet our obligations and effectively provide our services to you, it may be necessary to pass your personal data onto external parties. These external parties may include:
- Credit reference agencies
- Anti-fraud databases
- Claims handlers
- Legal professionals
- Loss adjustors
- External parties involved in the claim
- Private investigators
- The police and law enforcement
- External parties involved in the investigation, defence or prosecution of claims
- Other insurers (under court order or to prevent and detect fraud)
- Regulators and Supervisory Authorities
- Our TSPs suppliers and sub-contractors for the performance of any contract we have with them
Your data will be shared securely, and only when absolutely necessary. It will never be sold to external parties or organisations for marketing purposes.
International data transfers:
As Inigo is a global insurer, we may transfer or share your data outside the European Economic Area (“EEA”) for our operational procedures, including countries that may not offer an equivalent level of protection to that applicable within the EEA. It may also be processed by staff operating outside the EEA who are working for us or one of our suppliers. We will always take steps to ensure your data is treated and transferred securely with appropriate safeguards and controls in place. We will exercise due diligence in selecting the recipients outside the EEA in accordance with Article 44 of the European Regulation 2016/679 and will require, through appropriate contractual measures (e.g. data transfer contracts based on standard European Commission clauses), that they comply with adequate organisational and technical security measures to protect personal data and process them only in accordance with our instructions and not for other purposes.
Ongoing storage and use of your personal data:
We will not keep personal data for longer than necessary for the purpose for which it is processed. It will be retained in accordance with our Records Management Policy. Applicable laws and regulations may require us to keep records for specific periods of time, subject to certain exceptions. We may also need to keep records in order to administer the insurance relationship, to fulfil our contractual or statutory obligations or to resolve queries or disputes which may arise.
We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.
Your data subject rights:
You have the right to:
- Obtain a copy of your personal data held by Inigo
- Have any incorrect personal data corrected
- Request the erasure of any of your personal data
- Restrict or object to the use of your personal data, including profiling and automated individual decision-making.
- Request the personal data you provided to Inigo to be moved to another organisation
If you wish to exercise any of these rights please write to the below address stating your request and contact details.
The Data Protection Officer
7th Floor, 1 Creechurch Place
If you contact us regarding the exercise of these rights, we will seek to action your wishes. There maybe, in some cases (particularly where the request relates to the restriction of use of personal data, the objecting to the use of personal data or the erasure of the data) reasons why we are not able to fully comply with your request, particularly where we are required to keep and use that data to comply with contractual, legal or regulatory requirements.
Right to withdraw consent:
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Inigo is committed to providing high quality products and services. If you feel that we have not met your expectations, we’d like to know so we can put things right for you. You can submit a complaint by writing to the address below.
The Data Protection Officer
7th Floor, 1 Creechurch Place
We would expect that any complaint can best be dealt with by contacting us in the first instance, and we will take complaints made to us seriously. However, if you wish to complain about our use of your personal data, and do not wish to contact us first, you also have the right to complain directly to the supervisory authority. Full details on this can be found on the following website: https://ico.org.uk/
Insurance Industry and Data Processing:
Further details of how the insurance industry uses and processes data can be found on the Lloyds website via the core uses information notice. Please note that this is a third party website and inigo is not responsible for the content.
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