HARMER HEALEY LTD – PRIVACY POLICY – 25TH May 2018

This privacy notice tells you what we do with information that we collect about you. It is relevant to anyone who uses our services including clients, prospective clients, users of our website and beneficiaries under policies arranged by us, such as named drivers, employees of a company etc. We refer to all these individuals as “customers” or “you” in this notice.

1. Who “we” are

We are Harmer Healey Ltd and we sometimes use the branding, Harmer Healey Est 1926.

2. What information do we collect about you?

Where we have collected information directly from you, it will be obvious what this is, as you have given it to us. Some information is assumed, (i.e. certain property details, post codes etc.) and some is obtained from research on the internet. This might not be the case, if you have visited our website, where we have used cookies to collect information from your computer or portable electronic devices. Please see the cookies policy on our website for more information.

Information collected from others

We can collect information about you from others. This includes information from:

 A previous insurance company, broker or agent.

 Joint policyholders or policy beneficiaries.

 Fraud prevention, law enforcement or government agencies and other data sources used to prevent or detect fraud, or provide details to us or your insurance company about criminal convictions or offences.

 HM Treasury and other authorities in relation to regulatory issues, e.g. where someone is subject to a financial sanction, they will appear on HM Treasury’s asset freezing list.

 Credit reference agencies e.g. credit searches that are made when we produce a quotation for a new policy or at renewal. (Note that the results of these searches are automatically deleted after 12 months and do not affect your ability to obtain credit.) See Item 4 below.

 External Sources such as No Claims Discount Databases, The Electoral Roll, Companies House website, the DVLA Website.

 Sensitive personal information

We, and/or your insurer on our/your behalf sometimes collect information that is sensitive, such as information about children, health or geo-location (which may be sensitive personal information because for example, it may pinpoint your location at a hospital), and any information related to unspent past criminal convictions or offences.

We, and/or your insurers also collect personal information for specific types of policy or applications, for example, when offering you a travel policy, or a driving application, i.e. Telematics. We and/or your insurer may obtain this information from your mobile device, for driving applications and the following people:

 The main policyholder will provide most of the information that we collect about your health and unspent criminal convictions and offences, including on behalf of others named on the policy, e.g. medical screening to support a travel policy.

 Fraud prevention or law enforcement agencies may provide details to us or your insurance company about criminal convictions or offences.

 Witnesses to an accident may provide medical information to us/your insurance company if there is an investigation of a claim.

 We/and or your insurance company may use information about a child, for example, where the child is a beneficiary under a policy, or if involved in an accident.

We/and/or your insurer, collect this information as part of your insurance quotation or contract with us, or where it is a necessary legal obligation, or as part of the establishment or defence of a claim.

3. What do we do with this information we collect about you and why may we do this.

We use your personal information in order to meet our obligations in arranging your contract of insurance with you. We will use your personal information in the following ways:

A. Provide insurance services, including:

 To arrange insurance policies on your behalf;

 To make claims under insurance policies arranged on your behalf;

 To administer your policy and monitor the payment of instalments if you pay your premium to us in this way;

 To contact you about the policy (e.g. for billing or renewal purposes);

 To discuss your policy with your insurance company, premium finance company or claims related company. Including providing them with details about your policy, premium and claims history, so they can manage your policy; and

 To provide the agreed service, if you make a claim (e.g. arranging for your insurance company to send someone to assist you in a roadside breakdown situation or to provide you with medical assistance if you are injured or unwell, overseas).

B. Do what we are required to do by law

As part of our duty as an insurance agent/broker, sometimes we are required by law to use information about you to:

 To help make sure our customers are being treated fairly (e.g. to assist our regulators where we have a legal

duty to do so);

 To deal with complaints;

 To help prevent and detect crime (including for example, the prevention and detection of fraud); and

 To comply with a legal or regulatory obligation.

We can use your information in this way because we are required to do so by law.

C. Recover debt

If you owe us money, we will use your personal information to help us recover it, because it is a necessary part of the

insurance contract.

D. To administer and Improve our services

 In order to enable us to process your claim or administer your insurance policy more cost effectively;

 To help develop relevant products and services for our customers;

 To better understand you as a customer, including how to retain your custom and how best to improve our

service to you.

 To ask you to provide feedback on the service we provide to you.

We do this because it is in our legitimate interests to provide our service in the most efficient way. We will always ensure that we

keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum.

4. Who do we share your personal information with and why do we do it?

Other than the companies and other parties already referred to in this privacy notice,(including law enforcement,

government agencies, credit referencing agencies & Motor Insurance Database) we do not share your information with

anyone. We may use it to make you aware of relevant issues relating to your insurance contract. We will not use your

personal information to market products to you. If you would like to hear about other products or services that we can

provide, please contact us through the usual channels.

We can share information with your spouse or partner who may contact us on your behalf, provided they are named on

the policy. If you would like someone else to deal with your policy on a regular basis, please let us know.

5. How long may we keep your personal information for?

We are only allowed to keep your personal information if we need it for one of the reasons we describe in section 3 above.

As a general rule, we will keep it for 6 years from the end of your relationship with us, as it is likely that we will need the

information for regulatory reasons or to defend a claim. For example, should you wish to bring some form of legal action

relating to your relationship with us, this would generally need to be done within 6 years from the end of that relationship.

However, there may be exceptions where we need to keep your personal information for longer, such as where a claim

has involved a minor.

6. When can you ask us to stop using your information?

If we rely on your consent to collect and process your personal information, you can ask us to stop using your personal

information at any time by withdrawing that consent and we will stop using your personal information for those purposes.

At any time, you can tell us to stop using your personal information to allow computers to make decisions about you or in

order to improve our services or develop our products. To find out how to do this, see section 8.

7. What happens if you don’t give us some of your personal information?

Where you do not provide the personal information we need in order to provide the service you are asking for or to fulfil a

legal requirement, we will not be able to provide the service that you are asking us to give you.

We will tell you about why we need the information when we ask for it.

8. How to contact us about this privacy notice

Our Data Protection Officer, Richard Bonsall is in charge of answering questions about this privacy notice or your

requests to exercise your rights which are set out below. The Data Protection Office may be contacted at Harmer Healey

Ltd, Forge Lodge, 30 Brooklands Crescent, Sheffield, S10 4GE.

You may contact us at the address above for one or more of the following reasons:

1. To ask us to fix information about you that is wrong or incomplete, or to delete personal information about you (the socalled

“Right to be forgotten”).

2. To tell us you no longer agree to, that you object to, or that you wish to restrict us using information about you and ask

us to stop.

3. A right of access, namely to ask us to provide you with a copy of all of the personal information that we have about you.

To receive this information please write to the Data Rights Team, at the above address.

4. “Data portability” right, namely to obtain and reuse the information that you have provided to us for your own purposes

across different services. You may ask for this information to be provided directly to you or directly to another

organisation. We will provide the information in a machine readable format so that another organisation’s software can

understand that information.

5. To ask us not to use information about you in a way that allows our computer systems to make decisions about you.

Sometimes we will not be able to stop using your personal information when you ask us to (e.g. where we need to use it

because the law requires us to do so or we need to retain the information for regulatory purposes).

In other cases, if we stop using your personal information, we will not be able to provide services to you, such as

administering your insurance policy or servicing your claim.

We will tell you if we are unable to comply with your request, or how your request might impact you, when you contact us.