PRIVACY POLICY
This Privacy Notice contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Who We Are
Arrow Risk Management is a Managing General Agent and, as such, underwrites insurance products on behalf of insurance companies.
The Company collects, uses and is responsible for certain personal information about you.
When we do so we are regulated under the General Data Protection Regulations (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
The Personal Information We Collect and Use
Personal information, or personal data, means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you as follows;
Insured Persons – In order to arrange, administer and underwrite insurance policies, we collect information about the policyholder and related parties. The policyholder may be an individual, a company or their representative(s). The level and type of personal data we collect varies depending on the type of policy that you have. This is likely to include background and contact information on the policyholder or their representative(s) and matters relevant to the management of the insurance policy and assessment of risk.
Claimants – We will collect information about the individual making a claim under a policy. This will include the collection of basic contact details, together with information about the nature of the claim and any previous claims. If the claimant is an insured person, we will also need to check details of the policy you are insured under and your claims history.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or trying to enter into with you. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
Information collected from other sources
We also obtain personal information from other sources as follows:
- Insurance brokers and other insurance market participants such as Coverholders, insurance agents, service providers, reinsurers, other insurers, third party agents, legal advisers, loss adjusters and claims handlers
- credit reference agencies and background reference agencies
- antifraud, sanctions, court judgements and other databases
- government agencies and regulators
- in the event of a claim, third parties including any other party to the claim (such as a claimant/defendant), witnesses, experts, loss adjusters, lawyers and solicitors, and third-party claims handlers.
How we use your personal information
We use your personal information to:
- provide insurance services to our clients
- monitor our compliance with the laws and regulations that affect us
- perform own analysis so we can improve our business and ensure we are offering appropriate insurance products
We will share personal information with regulators including the Financial Conduct Authority, law enforcement or other authorities if required by applicable law. We will also share the information with the insurance companies that we are underwriting on behalf of in respect of your policy.
We will not share your personal information with any other third party.
How long your personal information will be kept
We will hold personal information we collect for the period we are required to retain this information by applicable legal and regulatory provisions which will be currently six years, from the termination of our arrangements, or such other period specified in line with our data retention policy.
Reasons we can collect and use your personal information
Under GDPR, we must always have your consent or a legal basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it (legal basis). You may withdraw your consent to such processing at any time.
Transfer of your information out of the UK
We may need to transfer your data to insurance market participants or their affiliates or sub-contractors which are located outside of the United Kingdom (UK). Those transfers would always be made in compliance with GDPR. If you would like further details of how your personal data would be protected if transferred outside the UK, please contact the Data Protection Officer (see ‘How to contact us’ below).
Your rights
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
Please contact us If you would like to exercise any of those rights.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Your right to complain
We hope that can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/
Changes to this privacy notice
We may change this Privacy Notice from time to time and any changes will be displayed on this page.
How to contact us
If you have any questions about this Privacy Notice, or about the information we hold about you, then you can contact us:
By letter;
Data Protection Officer
Arrow Risk Management Ltd,
34 Lime Street
London EC3M 7AT.
Or by email;
info@arrowrm.co.uk