James Hampden International Insurance Brokers Limited (“James Hampden International”) regularly collects and uses information which might identify an individual (“Personal Data”). Personal Data means any information about an individual from which that person can be identified.
This Privacy Notice sets out why we collect personal data, the type of data that we collect and how we may use that data. This Privacy Notice also sets out your rights with respect to that Personal Data.
We understand our responsibilities to handle your personal data with care, keep it securely and to comply with the relevant and applicable data protection laws. Your Personal Data will only be used in accordance with this Privacy Notice.
James Hampden International is a Lloyd’s insurance broker authorised and regulated by the Financial Conduct Authority. Our registered office is at 6 Bevis Marks, London, EC3A 7BA.
Our data protection obligations
We comply with the applicable data protection laws, in particular the Data Protection Act 2018 and the European General Data Protection Regulation. Under these laws and regulations, the Personal Data that we hold must be:
- Used lawfully, fairly and in a transparent way
- Collected only for valid purposes in relation to any insurance we have been requested to arrange on your behalf, or to deal with any mid-term changes or claims under the policy
- Kept secure and confidential
- Kept only as long as is necessary for the purposes required to manage any run-off, claims or to comply with any statutory or regulatory obligations
- Accurate and up to date
What Personal Data may we collect
For James Hampden International to provide insurance quotes, insurance policies and/or deal with any claims or complaints, we need to collect, retain and process Personal Data about you. This information may be collected whilst arranging insurance cover for you (including obtaining quotes for insurance that may not be taken up) or managing a claim. This information may include:
Individual details: Name, address, telephone number(s), email address, gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details
Identification details: Identification numbers issued by government bodies or agencies, such as your national insurance number or passport number
Financial Information: Bank or building society account information or other financial information
Risk details: Information about you which we and other market participants need to collect to assess the risk to be insured and provide a quote. This may include data relating to your health, criminal convictions, or other special categories of personal data
Policy Information: Information about the quotes you receive and policies you take out
Credit and Anti-fraud data: This may include the results of sanctions checks and, where relevant, details of criminal offences, along with other information received from various anti-fraud databases
Previous and current claims: Information about previous and current claims, (including other unrelated insurances), which may include data relating to your health, criminal convictions, or other special categories of personal data
Identities of Data Controllers and data protection contacts
For the purposes of the data protection laws, if you dealt with James Hampden International directly to arrange your insurance, we are the “data controller”. If you purchased your insurance via another intermediary, that intermediary will be the initial data controller and their data protection contact can advise you on the identities of other insurance market participants that they have passed your personal data to.
To ensure that James Hampden International can adequately place and service your insurance, we need to share your Personal Data with insurance market participants, some of which you will not have direct contact with. In addition, your Personal Data may not have been collected directly by an insurance market participant.
Where your employer or another organisation took out the policy for your benefit:
You should contact your employer or the organisation that took out the policy who should provide you with details with which organisations they provided your personal data to.
The use, types and processing of your Personal Data
We will only use your personal information where the data protection laws allow us to process your Personal Data and generally for the following purposes:
Quotation / Inception:
- to evaluate, process and complete your requests and/or applications for our products and services
- for security and verification of your identity
- payment of premium where the insured/policyholder is an individual
- client care, including communicating with you and sending you updates
- to update our records and maintain your policies with us
- to develop and improve our products and/or services
- payments to and from individuals
- managing insurance and reinsurance claims
- defending or prosecuting legal claims
- investigation or prosecuting fraud
- to contact the insured/policyholder to renew the insurance policy
- to evaluate the risks to be covered and premium calculation
- payment of premium where the insured/policyholder is an individual
- to provide specific information to our regulators and other government bodies to ensure that we adhere to our regulatory, legal and compliance obligations
- to meet our legal and regulatory obligations to prevent and detect fraud, money laundering and other financial crimes.
- when transferring books of business, company sales & reorganisations
- Lawful Purpose
- The lawful purpose/s for which we process your personal data will be one or more of the following:
- Necessary for the performance of an insurance contract
- Our legitimate interests or your explicit consent
- Our Legal and Regulatory obligations
Please note that in addition to the disclosures we have identified against each purpose, we may also disclose Personal Data for those purposes to our service providers, contractors, agents and group companies that perform activities on our behalf.
In order to provide insurance cover and deal with claims, in certain circumstances we and other insurance market participants may need to process your special categories of personal data, such as medical and criminal convictions records, as set out above. Your consent to this processing may be necessary to achieve the placement of your insurance policy and for handling and processing claims. You may withdraw your consent to such processing at any time. However, if you do withdraw your consent this will impact our ability to place and service your insurance or process your claims.
We may contact you by email, text, telephone, mail or other agreed means to keep you up to date about our products and services. The legislation allows us to do this in our own commercial interests for certain communications with previous customers. In other circumstances we can only do so with your explicit consent. In all cases you can opt out from receiving such communications at any time.
We may need to transfer your data to insurance market participants or their affiliates or sub-contractors which are located outside of the European Economic Area (EEA). Those transfers would always be made in compliance with the applicable data protection laws.
We will only transfer your personal data to countries which are recognised as providing an adequate level of legal protection. If you would like further details of how your Personal Data would be protected if transferred outside the EEA, please contact James Hampden International’s Data Protection Officer at email@example.com.
Security of your Personal Data
As a data controller, we have responsibilities to prevent your information from being (mis)used or accessed in an unauthorised way or by unauthorised parties. We take the security of your personal information seriously and we implement several security measures (including technical, administrative and physical security) to safeguard your personal information. We evaluate these measures regularly to help ensure the security of our processing. However, you should be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.
Disclosure of your Personal Data
We may also need to share data with third parties. These third parties help manage our business, including assisting us with improving the services which we deliver. They may also be fundamental to the placement and servicing of your insurance policy. Consequently, these third parties may, from time to time, need to have access to your personal data, and may include:
- Other insurance brokers with whom we transact business on your behalf
- Premium Finance providers
- Loss assessors
- Third Party Administrators
- Service providers e.g. who assist with the management of our IT systems
- Professional Indemnity providers
- Professional Bodies that represent you
- Regulators and other governmental bodies (both in the UK and worldwide)
- Solicitors and other professional services firms (including our auditors)
Whilst we may be required to share your data as set out above, we will not sell your details to any third party.
We will delete your personal information when it is no longer required for the purposes set out in this Privacy Notice. If, however, there are any technical reasons why we are unable to delete information entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of that Personal Data.
Your Rights over Personal Data
You have certain rights over your Personal Data, including:
- being informed about how we use your personal data (This Privacy Notice)
- requesting what personal information we hold on you
- requesting how we use your Personal Data
- correcting the Personal Data we hold on you
- erasing your Personal Data where there is no compelling reason for its continued processing
- withdrawing consent to use your Personal Data
- objecting to the use of your Personal Data for the purposes of direct marketing
- restrict our use or disclosure of your Personal Data (although we may not be able to agree to your request if it conflicts with our legitimate business interests)
Please note that your right for your Personal Data to be erased could be overridden by policy terms and conditions and our regulatory and legal based compliance requirements to retain such data.
Queries about this Privacy Notice or Complaints
If you wish to exercise any of your rights or have any questions relating to this Privacy Notice, please email the Data Protection Officer at firstname.lastname@example.org or write to us at James Hampden International Insurance Brokers Limited, 6 Bevis Marks, London, EC3A 7BA.
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Where is the information stored? Information which you submit via this website is sent to a computer located in the United Kingdom. This is necessary in order to process the information and to send you the information you have requested. Information submitted by you may be transferred by us to our other offices and to other reputable third party organisations, which may be situated outside the European Economic Area, including to countries that do not have data protection laws.
Please e-mail any questions, concerns or comments you have about this policy to: email@example.com or write to us at:
Trireme Insurance Group. 6 Bevis Marks, London EC3A 7BA
T +44 (0) 20 7220 9660