Privacy Notice
We take every prudent level of protection to ensure that your data remains safe within our systems. All personal information provided to and held by us will be treated as strictly private and confidential.

Lawful reason for processing
Our lawful basis for processing your data is that of contract. We record your personal data for the purpose of providing you with insurance quotations. Your data will only be shared with insurers for this specific purpose or for complementary risk management products. We will not transfer your data internationally.

The right to be informed
We will only use and disclose information that we hold about you in the normal course of obtaining quotations or arranging and subsequently administering insurance policies. This will involve passing information to insurance providers, health and safety consultants, business continuity planning organisations and other service companies that we use whilst designing a full insurance and / or risk management programme. We or they may carry out various checks and pass your details to others for reasons that may include:

1. Identity checks
2. Sanction checks
3. Information exchanges with the Police
4. Working with fraud prevention agencies, industry databases and registers
5. Obtaining information from other public and private sources and credit searches with credit reference agencies (these may appear on your credit report whether or not cover is arranged)
6. Claims handling including insurers, loss adjusters and other claims professionals
7. Premium funding providers for the purpose of arranging payments via instalments; we may also pass them details of your payment record.
8. In some circumstances we may anonymise your data for the purpose of developing new products and services for our clients with our insurer and service company partners

We may also need to share your information with tradesmen and other service providers such as Architects or Surveyors in order to arrange repairs to your premises following a claim.

Consent
We only contact you in respect of other services that we offer once we have obtained your explicit consent to do so, your consent is implied until we have done so. You can stop this consent at any time by giving us notice. We will not disclose any information to any other parties without your consent unless required to do so by our regulator, the FCA, if it is in the public interest to do so, or if we have to by law. You are free to withdraw your consent to use your data at any time though this may prevent us from providing you with our services.

The right to access
All of our clients have the right to access the data that we hold. If you wish to see your data and cannot attend our office to do so this will be provided to you either:

1. As a series of PDF documents – these will be emailed to you at the email address that we hold in our records.
2. Within a dongle – this will be posted to your home address “recorded delivery”
3. If you do not have access to the necessary computing power to receive documents in this way we can supply your file in paper format.

We will provide this information to you within 30 days of receipt of your request and you are entitled to receive this information free of charge.

We are currently working with our software providers to allow our clients access to our computer systems in order that they can inspect their policy documentation and basic information details online. We will publish further information in this respect as and when changes are made.

PLEASE NOTE that we have the right to refuse or charge for requests that are manifestly unfounded or excessive. If we take this course of action we will write to you to inform our reasons why. If this should occur and you are unhappy with our decision you may complain to the Information Commissioner as detailed at the end of this notice. You also have the full redress available to you through the court system.

The right to rectification
We will ensure that if you find any errors within the data that we hold we will take immediate steps to rectify them. We will also ensure that we notify any other parties, for instance insurance companies that may have relied on your data, of the changes you have advised.

The right to erasure
We will ensure that we erase your contact data from all of our systems if requested as long as this does not conflict with the law or our obligations under regulation. We will though retain details of insurance contracts entered into for at least 30 years in case of a claim arising against you as failure to do so would be a serious professional breach of conduct. Generally, we will retain your records for five years before placing them into a secure electronic archive.

The right to restrict processing
We will only use your data for the procurement of insurances and ancillary insurance related services. We will not sell your data or pass it on to any other persons. It could be that we anonymise your data for the purpose of developing new products and services.

It may be that there are certain companies that you do not wish to share your details with; any such request will be noted and actioned. If you wish to restrict the use of your data we will act in accordance with your wishes, however, we may not be able to offer or recommend an appropriate contract of insurance without your full details and consent.

The right to data portability
We will supply your data to other persons or organisations at your request. This will be provided within 14 days of any request and will be supplied in an electronic medium to the email address that you specify. This will generally be in the form of an excel spread sheet unless specifically requested otherwise. We will do our best to accommodate requests in whatever format you require but can only do so within the limitations of our own systems.

The right not to be subject to automated decision-making including profiling.
The Brownhill Insurance Group will not use your data in this way.

The right to object
All customers have the right to object to the way in which we handle their data.

If you have an objection please in the first instance contact either:

NAME	TITLE	CONTACT TELEPHONE NUMBER
Gillian Henderson	Managing Director	020 8658 4334
Gary Tommy	Compliance Director	020 8353 8915

Data Retention
We will retain details of your insurance policy(ies) for at least 30 years in case of a claim arising at a later date.

Who will immediately investigate your objection and take action as is appropriate.

Notwithstanding our own investigations you also have the right to take your objection to the Information Commissioners Office.

This can be done through:

1. The Information Commissioner’s Office web site https://ico.org.uk/
2. The ICO web site has functionality for a live web chat if this is easier
3. Calling the Information Commissioner’s Office helpline on 0303 123 1113