Privacy

Who we are

Stuart Benger & Company Ltd is an independent general insurance broker. We arrange insurance for both commercial and personal clients. We are authorised and regulated by the Financial Conduct Authority (FCA). The FCA is the independent watchdog that regulates financial services. Our FCA number is 300862. You can check this at www.fca.gov.uk/register or by contacting the FCA on 0800 111 6768. Our permitted business is advising on, arranging and assisting in the administration and performance of contracts of insurance.

General Data Protection Regulation 2018 (GDPR)

We handle client data in accordance with the GDPR, under which we are deemed a “Data Controller”, and our clients are “Data Subjects”. We collect, process, and retain client data for the legitimate purposes of our business. Principally we will ensure data is processed lawfully, fairly and in an open and transparent manner and ensure appropriate security measures are in place against unauthorised or unlawful processing or accidental loss, destruction or damage using appropriate technical or organisational measures (such as restricting access to key people within our organisation for certain aspects of your information; and periodically checking the level of security we apply to prevent unauthorised use, accidental loss, or misuse of your information).

What client data do we collect?

We will collect contact information such as name, address, phone number, e-mail address, as well as information that we need to be able to quote for and arrange the required insurance cover. We may also collect banking details for the purposes of payment of premiums and other costs.

Where required and appropriate to do so, we will also collect more sensitive personal information (such as details about an individual’s motoring or criminal convictions, details of health, creditworthiness and
other similarly sensitive information).

We will use information, including sensitive information, about individuals, and other parties related to our group companies’ insurance activities, because it is principally:

necessary for the performance of or to take steps for an individual to enter into a contract of insurance; or
it is necessary for compliance with a legal obligation; or
it is necessary to protect the vital interests of a data subject or
another person; and
necessary for our own legitimate interests or those of other controllers or third parties (e.g., to search at credit reference agencies, monitor e-mails, calls and other communications or for market research, analysis and developing statistics) except where such interests are overridden by the interests, rights, or freedoms of the data subject.

These bases include providing an insurance quotation, arranging and placement of a policy or wholesale facility, and providing administration throughout the lifecycle of an insurance arrangement as well as assisting
with making a claim.

Why do we collect client data

We collect sufficient information from our clients so that we can conduct a normal business relationship, and so that we can carry out the normal activities of an insurance broker, in order that we can advise on and arrange insurance policies and related services as necessary.

When do we collect client data?

We will collect data throughout the time that there is a business relationship between us and the client. Data will be collected over the phone, by e-mail, during face-to-face meetings, by the completion of facts-finds or proposal forms, or by online submission.

How do we hold client data?

Client data is held on paper files and electronically. We take the security and confidentiality of client data very seriously. Our office is secured to a high standard. Electronic data is backed up daily, and our IT system incorporates a high level of encryption and security to protect against unauthorised access.

Why might we share client data with other parties?

We will share information, including sensitive information, about you, and other parties related to this insurance because it is:

necessary for the performance of or to take steps for you to enter into a contract of insurance; or
necessary for compliance with a legal obligation; or
necessary to protect your vital interests; and or,
necessary for our own legitimate interests or those of other controllers or third parties; and
necessary for a task carried out in the public interest or for an exercise of an official authority (e.g., a regulatory body).

We may need to share client data with others in the normal conduct of our insurance broking activities. These would typically be insurers other insurance intermediaries, loss adjusters, anti-fraud databases, claims registers, premium finance providers, and regulatory or statutory bodies. (You can obtain a full list of these upon request),

For how long will we keep client data?

We retain client data throughout the duration of the client’s business relationship with us. Thereafter we are required to retain data for at least six years. We use a secure destruction service to dispose of paper files.

Client's right to access and rectify the data

Our clients have the right to request a copy of their data that we hold. If a client believes that information we hold is incorrect or incomplete we will amend the data on request.

Client's right to object to data being processed or to withdraw consent

Our clients have the right to object to us processing their data and to withdraw their consent for us to do so. In this case we will stop using the data, but this will mean that we can no longer act for that client. However there may be legitimate circumstances that mean that we are compelled to continue to use the data.

Client's right to have data 'erased'

Our clients have the right to request that all data that we hold be deleted from our records. If this is done then we will no longer be able to act for the client. However there may be legitimate circumstances that mean that we are compelled to retain the data.

Marketing

We do not use client data for the purposes of marketing without the client’s consent. We use client data solely for the purposes of providing the products and services that the client has requested from us. We will typically ask for your permission when you first contact us, but you will maintain the right to easily withdraw your consent whenever you wish (unsubscribe). We will regularly review your consent to check that your relationship with us and the processing and the purposes have not changed.

We will have processes in place to refresh your consent at appropriate intervals and act on withdrawals of consent (unsubscribe) as soon as we can and not penalise you if you choose not to give or later choose to withdraw your consent.

Client's right to complain

If a client feels that we are not handling data correctly we would request that the client contact us in the first instance. However the client has the right to complain to the Information Commissioner’s Office.

We will never knowingly transfer, store, or process information about you outside the European Economic Area (EEA). In any event, if we are compelled to transfer your information outside the EEA (e.g., because it is an insurance arrangement with an Insurance Company who is outside the EEA or part of a larger group of companies who pass information outside the EEA) it shall be in compliance with the conditions for transfer set out in the GDPR and or restricted to a country which is considered to have adequate data protection laws, and all reasonable steps shall typically have been undertaken to ensure the firm has suitable standards in place to protect your information.

Use and storage of your information overseas

You will be asked to accept a cookie, which is a small file of letters and numbers that is downloaded onto your computer when you visit our website. This will be clearly explained to you when you visit our website and you will typically have to accept the cookie to benefit from the services our website can offer. Cookies are operated in strict accordance with Privacy and Electronic Communications Regulations 2011 (PECR) and are widely used by many websites and enable our website to remember your preferences, recording information you have entered.

Using our Website and Cookies

What we will not do with your information

Unless required to do so by law, or for other similar reasons, other than those outlined (see sharing your information) we will never otherwise share personal information without good reason and without ensuring the appropriate care and necessary safeguards are in place; we will in any other event ask for your consent to share that information and explain the reasons.

Client’s right not to be subject to automated decision making

In certain circumstances to not be subject to a decision when it is based on automated processing; and/or it produces a legal effect or a similarly significant effect on you;

Client’s right to portability of data

You can request a copy of your personally identifiable information we hold by contacting us. You have a right to data portability, so we will normally, not only provide the information free of charge (however we may apply a charge where information requests are excessive) but we will provide that information in a format that is easily accessible, typically in a CSV format, should you require it to allow your information to be exchanged easily
with other organisations.