- What information do we collect?
- How will we use the information about you?
- Will we share your information with anybody else?
- How can I choose to opt out from any communication?
- Do we use automated decision-making systems?
- Do we transfer your data outside Europe?
- What are your legal rights?
- How long do we keep the data for?
- What happens when we change our Privacy Notices?
- What do you do if you have a complaint?
- How do you contact us?
To be clear on what we mean in this privacy notice:
- “we” and “us” means Dickson Financial Services Limited. Innovation Broking is a brand and trading name of Dickson Financial Services.
- “Aston Lark group” means the companies, subsidiaries and associated companies in which Aston Lark Group Limited holds significant share capital – you can find out more about the companies in the group by visiting www.astonlark.com;
- “the Howden Group” means Howden Group Holdings Limited and any company or organisation in which Howden Group Holdings Limited holds significant share capital. You can find more information about the other companies in the Howden Group by visiting howdengroupholdings.com;
- “third-party” means someone who isn’t you, us, the Aston Lark group or the wider Howden Group
This Privacy Notice explains how we use the personal information we collect to provide you, a company or its employees with our services and at the same time meet our obligations regarding data protection and the rights of our customers, prospective customers, and former customers in respect of their Personal Data as defined under relevant data protection legislation (including the Data Protection Act 2018, the General Data Protection Regulation effective from 25 May 2018 and any subsequent data protection legislation).
In accordance with our data protection obligations we have appropriate safeguards in place for the protection of any Personal Data which we process. Our security controls are aligned to industry standards and good practice so as to provide a control environment that effectively manages risks to the confidentiality, integrity and availability of your information. We also ensure our staff are and remain, aware of our data protection obligations. We take the protection of your privacy and the confidentiality of your personal information (“Personal Data”) seriously.
The Regulation defines Personal Data as any information relating to an identified or identifiable natural person (a Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Dickson Financial Services Limited / Innovation Broking is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all Personal Data, respecting the legal rights, privacy, and trust of all individuals with whom we deal.
What information do we collect?
We collect and hold personal information that may include an individual’s name, email address(es) telephone number(s) and other personal information when:
- You or a company makes an enquiry with us; or
- Engages us to provide insurance broking or employee benefits;
Due to the nature of our services we may also collect personal information about you from the company that employs you or from publicly available records.
In some instances you will provide us with credit card details to enable payment of your insurance premium. When this occurs the card details will be securely destroyed immediately following their use and we will never hold card details for use at a later date.
This information is collected with the purpose of providing you, a company and its employees with the services we are contracted to deliver as an insurance broker and employee benefits intermediary.
How will we use the information about you?
This information is collected with the purpose of providing you, a company and its employees with the services we are contracted to deliver as an insurance broker and employee benefits intermediary. Our processing of your Personal Data will include:
- assessing your circumstances and insurance needs;
- presenting such details to insurers for the purpose of obtaining quotations and placing cover;
- arranging premium finance arrangements;
- processing claims;
- undertaking checks to guard against fraud, money laundering, bribery and other illegal activities; and
- handling complaints.
To ensure that our processing of your data is lawful, such processing will only be undertaken if:
- it is necessary for the performance of a contract to which you are, or will be, a party; or
- you have given your consent; or
- you confirm that any personal information you give to us about another person is given with their informed consent
- processing is necessary for compliance with a legal obligation to which we are subject; or
- processing is necessary to protect your vital interests; or
- to perform a task carried out in the public interest or in the exercise of official authority vested in us; or
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your fundamental rights and freedoms which require protection of Personal Data.
In some instances, we may use your data to provide you with information or services we consider could be of interest to you or to help us provide a better service to you.
Will we share your information with anybody else?
As we act as an intermediary between you and the insurer or services provider, we may need to share your personal data with other third parties in order for us to provide service(s) to you. These parties may include:
- Other companies in the Aston Lark group and/or the wider Howden Group;
- Your agent, adviser or employer
- Support companies for the delivery of the products and services we offer to you including but not limited to: insurers; other insurance brokers, loss adjusters and loss assessors; risk managers, administrators, incident management firms; professional advisors; premium finance companies; IT providers, internet service providers and mailing/fulfilment houses;
- Our regulators and supervisory authority e.g. the Financial Conduct Authority (FCA) and the Information Commissioner’s Office for the UK (the ICO)
- Law enforcement, credit and identity check agencies for the prevention and detection of crime
- HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance
Those parties will be governed by the same laws as us. Therefore, they only be permitted to use your personal data for the purposes we specify and the provision of services to you.
How can I choose to opt out from any communication?
As we are specialist insurance broker and employee benefits intermediary we will only contact you when we consider it is beneficial to you. However, if you receive something and do not wish us to continue any contact, please let us know and we will stop. Details of how to contact us are below.
Do we use automated decision-making systems?
You’ll be pleased to hear we use humans for any decision about the services we provide you or consider would be of benefit for you to be contacted about, so the answer is no!
Do we transfer your data outside Europe?
In order to provide our services there may be circumstances when it is necessary to send some of the personal data collected to countries outside the European Economic Area (EEA).
Should this be necessary we will ensure that at least one of the following safeguards is implemented:
- We will only transfer personal data to countries which have been deemed by the European Commission to provide an adequate level of protection for personal data; or
- Where we use certain service providers, we may use specific codes of conduct, contracts or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States of America (US), we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the European Union (EU) and US.
If you would like further information on the specific safeguard we use when transferring your personal data outside the EEA, please use the how to contact us below.
What are your legal rights?
You have certain rights under data protection law in relation to your personal data. Depending on circumstances, these may include the right to request:
- Access to the personal data we hold
- Correction of the personal data we hold
- Deletion of the personal data we hold
- Restriction of processing the personal data we hold
- Transfer of the personal data we hold to another organisation
- A withdraw of consent (where we rely on consent for processing)
Should you wish to contact us about any of these rights, please use the how to contact us below and we will endeavour to respond within one month. However, if you have a complex request, or make a number of requests, it may take us longer and if this is the case, we will let you know how long we think it will take and keep you updated. We do not make a charge for responding to any request which results from you exercising your legal rights.
How long do we keep the data for?
We will only keep your personal data for as long as it is necessary to fulfil the purpose(s) for which we collected it or as required by statutory or FCA rules. Our retention periods are determined by the nature and sensitivity of the personal data held, the potential for harm caused by its unauthorised use or disclosure and whether it is possible for us to achieve our objectives in another way.
Unless we tell you other otherwise, we will keep records of your personal data for no more than:
- Six years from the date that our agreement with you comes to an end; or
- Two years from the date we provide you with a quotation for services which you do not take up.
What happens when we change our Privacy Notices?
What do you do if you have a complaint?
If you have any complaints we ask you contact us first to discuss the matter and all being well we can resolve the issue. To contact us please send an email to email@example.com or better still call 01923 222211 and ask to speak to Paul Dickson (CEO) or Andrew Buckingham (CFO)
You also have a right to lodge a complaint about the way we handle, or have handled, your personal information with the Information Commissioner’s Office (ICO), the UK’s data protection supervisory authority. They can be contacted in a number of ways, including by phone, 01625 545745, or email firstname.lastname@example.org
How do you contact us?
We hope you found the above policy helpful and should you have any questions, please contact us by email to email@example.com or better still call 01923 222211 and ask to speak to your regular contact or Andrew Buckingham (CFO).