PRIVACY POLICY

Ascot Group Limited (‘Company’) and its subsidiaries, including Ascot Underwriting Limited writing for and on behalf of Syndicate 1414 at Lloyd’s, (together being the “Group”) gathers and uses certain information in the ordinary course of its business as an insurer and/or insurance intermediary. This information may also be used by other companies in the Group and so, in this notice, references to ‘we’ or ‘us’ mean the Company and the Group.

This Privacy Policy explains how we collect, use, disclose, transfer, and store personal information of policyholders, beneficiaries or claimants (as well as their agents or relatives) (“you”) during the course of the insurance lifecycle. You are encouraged to check periodically for any updates to these terms.

Insurance involves the use and disclosure of your personal information by various insurance market participants such as intermediaries, insurers and reinsurers. The London Insurance Market Core Uses Information Notice sets out those core necessary personal data uses and disclosures. Our core uses and disclosures are consistent with the London Market Core Uses Information Notice. We recommend you review this notice in conjunction with this Privacy Policy.

WHAT PERSONAL INFORMATION WE COLLECT

In order to deliver insurance services to you, we may collect the following information:

  • Name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to you.
  • Identification numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving licence number.
  • Bank account or payment card details, income or other financial information.
  • 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. For certain types of policy, this could also include telematics data.
  • Information about the quotes you receive and policies you take out.
  • Credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to you.
  • 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.
  • Certain categories of personal data which have additional protection under the GDPR. The categories are health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation.

WHERE WE MIGHT COLLECT YOUR PERSONAL INFORMATION FROM

We might collect your personal information from various sources, depending on your circumstances, including:

  • You.
  • Your family members.
  • Other insurance market participants.
  • Credit reference agencies.
  • Anti-fraud databases, sanctions lists, court judgments and other databases.
  • Government agencies.
  • Open electoral register.
  • In the event of a claim, third parties including the other party to the claim (claimant/defendant) witnesses, experts (including medical experts), loss adjustors, solicitors and claims handlers.

HOW WE USE YOUR PERSONAL INFORMATION

In the course of providing our services, we may use your personal information for the following purposes:

  • Setting you up as a client, including possible fraud, sanctions, credit and anti-money laundering checks, evaluating the risks to be covered and matching to appropriate policy/ premium and payment of premium where the insured/policyholder is an individual.
  • Client care, including communicating with you and sending you updates and processing payments to and from individuals.
  • Managing insurance and reinsurance claims, defending or prosecuting legal claims and investigation or prosecuting fraud.
  • Contacting the insured/policyholder to renew the insurance policy, evaluating the risks to be covered and matching to appropriate policy/ premium and payment of premium where the insured/policyholder is an individual.

Other purposes outside of the insurance lifecycle but necessary for the provision of insurance throughout the insurance lifecycle period:

  • Complying with our legal or regulatory obligations.
  • General risk modelling.
  • Transferring books of business, company sales & reorganisations.

CONSENT

In order to provide insurance cover and deal with insurance claims, we may need your consent in order to process certain categories of personal information, such as medical and criminal convictions records.

You may withdraw your consent to such processing at any time. However, if you do withdraw your consent this may impact our ability to provide insurance or pay claims.

SHARING YOUR PERSONAL INFORMATION WITH THIRD PARTIES

Further to the Purposes set out above, we may disclose personal information to our service providers, contractors, agents and to other companies within the Group that perform activities on our behalf. We will only disclose your personal information in connection with the insurance cover that we provide and to the extent required or permitted by law.

We may also need to transfer your data to insurance market participants or their affiliates or sub-contractors which are located outside of the European Economic Area (EEA). Those transfers would always be made in compliance with data protection legislation and we apply the same data protection safeguards that we would otherwise apply with the EEA. By providing us with your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

COOKIES

We only use cookies for session management, and we neither collect nor keep user personal data. In order to monitor the use of our website, we do use Google Analytics. Google Analytics does collect information on website trends, without identifying individual visitors. Google Analytics uses a different set of cookies for each website, and visitors are not tracked across multiple sites.

DOCUMENT RETENTION

We will keep your personal information only for so long as is necessary and for the purpose for which it was originally collected. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim under this insurance, or where we are required to keep your personal information due to legal or regulatory reasons.

YOUR RIGHTS

If you have any questions in relation to our use of your personal information, you should contact our Data Protection Officer. Under certain conditions, you may have the right to require us to:

  • Provide you with further details of the use we make of your personal information.
  • Provide you with a copy of the personal information that you have provided to us.
  • Update any inaccuracies in the personal information that we hold.
  • Delete any personal information, or special categories of personal information, that we no longer have a lawful ground to use.
  • Where processing is based on consent, to withdraw your consent so that we stop that particular processing.
  • Object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights.
  • Restrict how we use your personal information whilst a complaint is being investigated.

In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). Otherwise, we endeavour to deal with your request free of charge. However, where a request is manifestly unfounded or excessive, we may either charge a reasonable fee taking into account the administrative costs of providing the information or refuse to respond.

CONTACT US

If you have any questions or concerns about this Privacy Policy, or if you would like to access, correct or delete any of your personal information, or make a complaint, please contact our Data Protection Officer at: Ascot Underwriting Limited, 20 Fenchurch Street, London EC3M 3BY Email: DPO@ascotuw.com Phone: 020 7743 9600

YOUR RIGHT TO COMPLAIN

If you are not satisfied with our use of your personal information or our response to any request made by you to exercise any of your rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the ICO. Contact details for the ICO can be found here:

https://ico.org.uk/