Privacy Policy

GM Insurance Brokers Ltd is committed to protecting information which identifies and relates to you or other individuals (personal information) and complying with data protection laws.

This privacy policy sets out GM Insurance Brokers Ltd’s personal information collection and sharing practices in relation to the personal information that we collect and use for the administration of insurance policies, reinsurance contracts and the provision of advisory services. This privacy policy also covers any personal information collected through your use of any of GM Insurance Brokers Ltd’s websites.

The persons to which this privacy policy applies:

Policyholders, clients, suppliers, advisers, service providers, enquirers, beneficiaries or claimants and their agents and relatives (“you”)

Important

Please read this privacy policy with care. It provides information about how we use personal information and the rights available to you under data protection laws.

This website may contain links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information

Layered approach

Data protection laws require us to provide you with a lot of information about how we collect and use your personal information – and it is easy for all this information to become confusing rather than helpful.

We use a layered approach to provide you with the information required by law. This means that we may provide the information required in a number of different formats and documents. In particular, it means that in our initial contact with you, we may provide you only with the most important information about how we will use your personal information; but we will always provide you with easy access to all the further information you need about our privacy practices

As an example, if you buy an insurance policy from us, then we may use a two layered approach:

• A short form privacy notice in your policy related documentation that refers to this privacy policy
• Access, via this privacy policy, to an insurance market standard information notice that explains in more detail how the insurance market works and uses personal information to provide insurance cover.

As an example, if you engage us to provide you with advisory services, then we may use this three layer approach:

• A short form privacy notice in your terms of engagement that refers to this privacy policy
• Access to this privacy policy online or by post
• Additional privacy notice terms in your letter of engagement that accompanies the terms of engagement, tailored to the specific advisory services provided and data involved if required.

By using this three-layer approach, we provide you with both specific and general information about how we use personal information to provide you with the insurance cover or advisory services that you require, whilst at the same time making sure that you get the most important information without overwhelming you with facts and information about all our privacy practices in one go.

How this Privacy Policy Works

This privacy policy is intended to explain our privacy practices and covers the following areas:

1. Information we may collect about you
2. Why we collection information about you
3. How we may use your personal information
4. Consent
5. Sharing your personal information
6. Transmission, storage and security of your personal information
7. Retention of your personal information
8. Your rights
9. Contacting us
10. Changes to this privacy policy
11. Cookies Statement
12. Your right to complain

1. Information we may collect about you

We may collect and process the following personal information about you:

• that you provide by filling in forms or upload to us;
• information including your name, address, contact details
• for insurance products, this includes details relating to a proposal or a claim (which depending on the nature of the claim may include medical reports and reports of criminal convictions or crime) that you, your employer or organisation whom we insure or reinsure or a third party claimant provide to us in relation to the administration of an insurance policy that we insure or re-insure;
• for advisory services, this includes details relating to your instructions for us to provide advisory services, the administration and management of those services and of any claim or complaint including details provided by a third party;
• information relating to any criminal or fraudulent activities provided to us by you or third parties (such as law enforcement, anti-fraud agencies or other insurers);
• if you contact us, we may keep a record of that correspondence, voicemail or details of any conversation we may have with you;
• details of your visits to our website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access;
• details of transactions you carry out through our website, including the quotations obtained for insurance and advisory services and the insurance policies and advisory services; and information that is available from publicly available sources including social media websites.

2. Why we collect information about you

We may process personal information for certain legitimate or lawful purposes in some or all of the following ways:

• to enhance the security of our network and information systems;
• to identify and prevent fraud;
• to maintain our accounts and records;
• to modify, personalise or otherwise improve our services/ communications;
• to comply with foreign law, law enforcement, court and regulatory bodies’ requirements;
• to defend or make claims;
• to correspond with clients, beneficiaries and claimants in order to facilitate the insurance policies or advisory services;
• to comply with a legal obligation;
• to protect your vital interest or the interest of another individual;
• to gather market intelligence, communicate with and tailor offers to individuals;
• for training and quality purposes;
• for the performance of a contract with you or to take steps to enter into a contract; and
• for the performance of a task carried out in the public interest or in the exercise of an official authority.

3. How we may use your personal information

We may use your personal information in the following ways:

• to make decisions on whether to provide insurance or advisory services;
• to manage your insurance policy or advisory services including underwriting and claims handling
• to monitor calls and transactions to ensure service quality, compliance with procedures, to combat fraud and insure compliance with UK/ EU and international sanctions;
• to identify you and to carry out any identity checks as may be required by applicable law and best practice at any given time;
• to recover any payments due to us and where necessary to enforce such recovery through the engagement of debt collection agencies or taking other legal action;
• to analyse it in order to understand the service we provide and in order to improve our business;
• to manage our infrastructure, business operations and comply with internal policies and procedures;
• to notify you about changes to our service; and
• for marketing services to you by post, email, SMS, phone and fax.

We will never process your data where these interests are overridden by your interests.

4. Consent

Your consent to our processing of your personal information for certain purposes may be necessary to comply with applicable data protection laws; and where this is the case we will ask you for your consent in accordance with those laws.

You may withdraw your consent to such processing at any time. However, if you withdraw your consent in relation to advisory services or insurance cover that we have provided then this is likely to impact our ability to provide those advisory services or insurance cover and pay claims under the cover.

5. Sharing your personal information

GM Insurance Brokers Ltd may make personal information available to:

We have a panel of Appointed Representatives. We may share your personal data with our Appointed Representatives, but only for the purposes set out in this privacy policy and we remain responsible for the management and security of personal information. Access to personal information within GM Insurance Brokers Ltd, and our panel of Appointed Representatives, is restricted to those individuals who have a need to access the information for our business.

We may also permit selected third parties and agents including suppliers, service providers, and financial organisations to access to your personal information for the purposes set out in section All such exchanges will be made in accordance with applicable laws. If false or inaccurate information is provided and/or fraud is identified or suspected, details may be passed to fraud prevention and anti-money laundering agencies, law enforcement agencies or other insurers and may be recorded by us or by them.

We and other organisations may also access and use this information to prevent fraud and other crime, for example when deciding whether to make a payment to you under an insurance or reinsurance policy;

We, and other organisations that may access and use information recorded by fraud prevention agencies, may do so from other countries including outside the EEA.

We may disclose your personal information to third parties, the courts and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or in order to enable GM Insurance Brokers Ltd to comply with its regulatory requirements or dialogue with its regulators as applicable.

6. Transmission, storage and security of your personal information

Unfortunately, no data transmission over the Internet or any website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with applicable data protection laws.

All information within our control is stored on our secure servers (or secure hard copies) and accessed and used subject to our security policies and standards.

Where GM Insurance Brokers Ltd discloses your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or any other portal we operate, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

Your personal information may be accessed by staff or authorised third parties and, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) where the data protection laws may be of a lower standard than in the EEA. Regardless of location or whether the person is an employee or contractor we will impose the same data protection safeguards that we deploy inside the EEA.

7. Retention of your personal information

We will retain your personal information for as long as is reasonably necessary for the purposes listed in section 2 of this privacy policy. This may mean that we hold your personal information for some time where, for instance, there is a possibility that it may be needed in connection with a claim under an insurance policy or the advisory services, or where we are obliged to keep it to comply with tax, accounting, regulatory or legal requirements.

We maintain a data retention policy which we apply to all data in our care. Where your personal information is no longer required we will ensure it is securely deleted.

8. Your rights

Data protection laws give you rights in relation to the personal information we hold about you, which may include the right to require us to:

• provide you with further details on the use we make of your personal information
• provide you with a copy of the personal information we hold about you
• update any inaccuracies in the personal information we hold about you
• delete any of your personal information that we no longer have a lawful ground to use
• where processing is based on consent, stop that processing by withdrawing your consent
• object to any processing based on our legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
• restrict how we use your personal information whilst a complaint is being investigated
• transfer your personal information to a third party in a standardised machine-readable format
• In certain circumstances, we may need to restrict your rights to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

9. Contacting us

The Managing Director supervises how we use personal information. You can contact the Managing Director about privacy related issues by:

sending an email to gavin.mead@gm-insurance.co.uk

writing to the Managing Director, 6a Cranmere Court, Lustleigh Close, Matford Business Park, Exeter, Devon. EX2 8PW.

10. Changes to our privacy policy

We may change the content of our website or services without notice, and consequently our privacy policy may change at any time in the future. We therefore encourage you to review it from time to time to stay informed of how we are using personal information.

This privacy policy was last updated on March 2018.

11. Cookies Statement

Our Site uses cookies. If you would like to find out more about how we use cookies then please go to our Cookies Statement Page.

12. Your right to complain

If you are not satisfied with our use of your personal information or our response to any request by you to exercise your data protection rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the authority that supervises our processing of your personal information. In the UK, this is the ICO, details of which can be found here https://ico.org.uk/

If you are unsure of the authority that supervises our processing of your personal information, then please contact us for further guidance.