DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

FSB Insurance Service Limited (“We”) are committed to protecting and respecting your privacy.

This policy (together with our terms of use https://www.fsb-insurance-service.com/terms-of-website-use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1.Definitions

Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – A living individual to whom personal data relates.

Categories of data: Personal data and special categories of personal data.

Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified from that data. For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2.Who are we?

FSB Insurance Service Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: 5th Floor, Interchange, 81-85 Station Road, Croydon, CR0 2RD. Our Data Trustee is Andrew Bishop, who can be contacted on 0203 883 7976 or by e-mailing [email protected]

3.Information we may collect from you

We may collect and process the following data about you:

Information you give us. You may give us information about you by filling in forms on our site www.fsb-insurance-service.com (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information.

Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:

Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

We may also receive your information from the FSB if you’ve registered to become a member of the FSB Insurance Service and have consented to it, either online or through a membership advisor or their Customer Service team.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy (https://www.fsb-insurance-service.com/cookie-policy)

4.The purpose(s) of processing your personal data

We use your personal data for the following purposes:

Providing it to insurers and service providers in order to get you cover for relevant insurance products
To inform you of upcoming renewals, loss of cover, products, news and events
Maintaining our own accounts and records, and to enable us to provide free insurance advice to registered members.

5.What is our legal basis for processing your personal data?

Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data:

✓ Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract	In order to enable the quotation of and purchase of a policy for cover we will need to share your information with insurers
✓ Consent of the data subject	Via phone conversation, registering with the insurance service via the FSB, or through our website
✓ Processing is necessary for compliance with a legal obligation	In the event of a claim, complaint, or breach your information may be supplied to the regulators in order to assist you
✓ It is in our legitimate interest to do so, and will not be at the expense of the interests, rights or freedoms of the data subject	We have a legitimate business interest to process and store your data in ways which you would reasonably expect

6.Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared only with selected third parties including:

Insurers and service providers in order to provide relevant insurance which meets your requirements
Analytics and search engine providers that assist us in the improvement and optimisation of our site
Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
Finance providers where you have selected the option to pay in instalments via a credit agreement
Regulatory authorities, courts and governmental agencies to comply with legal or regulatory requirements.

We may disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If FSB Insurance Service or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use https://www.fsb-insurance-service.com/terms-of-website-use [or terms and conditions of supply https://www.fsb-insurance-service.com/terms-of-business and other agreements; or to protect the rights, property, or safety of FSB Insurance Service our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Sometimes FSB Insurance Service uses third parties to ensure that the data we hold on you is accurate and complete. That party is currently FSB and their Privacy Policy can be found here.

7.How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary in order to make sure we hold adequate records in the event that this information is required.

8.Where we store your personal data

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

9.Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

The right to request a copy of the personal data which we hold about you
The right to request that we correct any personal data if it is found to be inaccurate or out of date; your request will be actioned within one calendar month
The right to request your personal data is erased where it is no longer necessary to retain such data
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability), where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
The right to object to the processing of personal data where applicable (i.e. where processing is based on legitimate interests, the performance of a task in the public interest/exercise of official authority, direct marketing and processing for the purposes of scientific/historical research and statistics). We will respond to requests within 28 days

10.Transfer of Data Abroad

We will not transfer your personal data outside an Adequate Country without your approval. An ‘Adequate Country’ means: a) where Data Protection Legislation in force in the United Kingdom applies to Personal Data processed on behalf of the Customer or any Service Recipient, the United Kingdom and any country which is recognised under such Data Protection Legislation as providing adequate protection for personal data; and b) where the GDPR applies to Personal Data processed on behalf of the Customer or any Service Recipient, the European Economic Area and any country, territory or sector in respect of which an adequacy decision applies under article 45 of the GDPR.

11.Automated Decision Making
We do not use any form of Automated Decision Making in our business.

12.Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

13.Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

14.How to make a complaint

To exercise all relevant rights, queries or complaints regarding data privacy please in the first instance contact our Data Trustee on 0203 883 7976 or [email protected]

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.