Castleacre Insurance (Ireland) Services Ltd (“Castleacre”) is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.
It is the intention of this privacy statement to explain to you the information practices of Castleacre in relation to the information we collect about you.
For the purposes of the GDPR the data controller and data processor is:
- Contact details of person responsible for GDPR: Guy Everington
t: 00 353 (0) 1 513 6140
- When we refer to ‘we’ it is Castleacre
Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Who are we?
- Castleacre is regulated by the Central Bank of Ireland to act as an insurance intermediary with Freedom of Service to allow it to administer and advise the clients in the 27 EU countries
- Castleacre provide insurance broking and advisory services to wealthy Private Clients and Small Businesses to cover property and liability.
Purpose for processing your data
We are data controllers and data processors.
- Our lead data protection authority is the Data Protection Commission.
- We hold data responsibly, fairly, legally and transparently.
The information we collect is provided directly by you, either through our online enquiry form, a direct telephone conversation, email or letter.
We only collect data that is adequate, relevant and limited to the needs of obtaining insurance quotes and for the purposes of arranging and administering insurance cover and arranging premium credit if required.
We ask for personal information to help us:
- provide a quotation for insurance purposes
- to perform our contract with you and the insurer
- legal compliancy and legitimate interests
- to help inform you about our products and services
- and substantial public interest in arranging insurance and settling claims
We only disclose information to third parties who either help us perform this contract, or help us fulfil our legal obligations and legitimate interests.
Why we are processing your data? Our legal basis
In order to provide you with our services of advising and arranging insurance policies for you and helping in the settlement of claims it is necessary for us to collect and process your personal data. We are required, therefore, to inform you of the legal bases for processing your personal data. One such legal basis is that the processing is necessary for the performance of the advisory services contract (and any other contract) that we commit to delivering to you from time to time. Another legal basis is that some processing is necessary for the purposes of the legitimate interest that we have, as a firm that is regulated by the Central Bank of Ireland, in the proper administration and correct operation of our firm. There may also be circumstances where the legal basis for processing your personal data is consent (where we have sought it and it has been provided to us), in which case that consent may be withdrawn at any time.
Castleacre is committed to ensuring that the information collected and used is appropriate for this purpose and does not constitute an invasion of your privacy.
How will Castleacre use the personal data it collects about me?
Castleacre will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). Castleacre will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
Special Categories of personal data
If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) – we will obtain your explicit consent.
Who are we sharing your data with?
Your personal information is shared with:
- Our database mangers
- Credit agencies (only where credit is requested)
and in the event of a claim:
- Loss adjusters
- Third party claims administrators
- Legal representatives (where necessary)
Storage outside the EU
Your data is stored or processed outside the EU with Castleacre Insurance Services Ltd the parent Company of Castleacre.
Castleacre ensure Castleacre Insurance Services Ltd has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.
Any other information required to demonstrate that the processing is fair and transparent.
We may pass your personal data on to third-party service providers contracted to Castleacre in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Castleacre procedures.
If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise.
We have issued all our third-party processors with a Data Processor checklist asking them GDPR specific questions.
If you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance. The third-party has a right to recover from the insurer the amount of any loss suffered by them. Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person who is able to provide it concerning:
- the existence of the insurance contract,
- who the insurer is,
- the terms of the contract, and
- whether the insurer has informed the insured person that the insurer intends to refuse liability under the contract.
Data Subjects Rights:
Castleacre facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling
- Right to judicial review: in the event that Castleacre refuse your request under rights of access, we will provide you with a reason as to why.
All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.
Additional information we are providing you with to ensure we are transparent and fair with our processing
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Castleacre will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (Central Bank of Ireland) and our internal governance.
In the event that you wish to make a complaint about how your personal data is being processed by Castleacre or how your complaint has been handled, you have the right to lodge a complaint with Guy Everington at Castleacre.
t: 00 353 (0) 1 513 6140
f: 00 353 (0) 57 868 4757
Failure to provide further information
If we are collecting your data for a contract and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact Guy Everington:
t: 00 353 (0) 1 513 6140
Source: Castleacre Insurance (Ireland) Services Ltd
Castleacre Insurance (Ireland) Services Ltd is an experienced data protection practitioner and all document templates are provided as general guidance.