- When we collect and use personal information, we ensure we look after it properly and use it in accordance with our privacy principles set out below, keep it safe and will never sell it.
- Personal information you provide is processed fairly, lawfully and in a transparent manner
- Personal information you provide is collected for a specific purpose and is not processed in a way which is incompatible with the purpose which Conaghan & Company collected it
- Your personal information is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed
- Your personal information is kept accurate and, where necessary kept up to date
- Your personal information is kept no longer than is necessary for the purposes for which the personal information is processed
- We will take appropriate steps to keep your personal information secure
- Your personal information is processed in accordance with your rights
- We will only transfer your personal information to another country or an international organisation outside the European Economic Area where we have taken the required steps to ensure that your personal information is protected. Such steps may include placing the party we are transferring information to under contractual obligations to protect it to adequate standards
- Conaghan & Company does not sell your personal information and we also do not permit the selling of customer data by any companies who provide a service to us.
We Collect Personal Information Directly from You
- via enquiry, registration and claim forms;
- via feedback forms and forums;
- when you purchase any of our products or services;
- via our telephone calls with you, which are recorded as a matter of policy and in order to satisfy regulatory requirements;
- when you provide your details to us either online or offline, usually for Client on-boarding and ID Verification processes.
What Personal Information Do We Collect?
- We might collect personal information, such as your contact details, information about your bank or credit cards or utility bills, for ID verification and other matters. The information we collect depends on which product or service you’re interested in or requesting advice on. Please note, in certain circumstances we may request and/or receive "sensitive" personal information about you. For example, we may need access to health records for the purposes of providing you with a policy or processing claims, or details of any court or HMRC judgments for the purposes of preventing, detecting and investigating fraud.
How Do We Use Your Personal Information?
- We mainly use your personal information to provide you with the right services based on your situation. However, there are a number of other reasons why we use your personal information; Please see below for a more detailed list of how we use your personal
- We may process your personal information for a number of different purposes and these are set out in more detail in the below sub-sections. Under data protection laws we need a reason to use and process your personal information and this is called a legal ground. We have set out below the main reasons why we process your personal information and the applicable circumstances when we will do so.
- We may use Cloud storage solutions within Storage location(s) are within the United Kingdom and the European Union which and are chosen to ensure efficiency and improved performance through up to date technology.
- Where we have a legal or regulatory obligation to use such personal information, for example, when our regulator the Financial Conduct Authority (FCA) and our data protection regulator, the Information Commissioner's Office (ICO) wish us to maintain certain records of any dealings with you.
- Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claims or where we want to pursue any legal claims ourselves.
- Where we need to use your personal information for reasons of substantial public interest, such as investigating fraudulent claims and carrying out fraud, credit and anti-money laundering checks.
- Where we have appropriate legitimate business need to use your personal information such as maintaining our business records, developing and improving our products and services, all whilst ensuring that such business need does not interfere with your rights and freedoms and does not cause you any harm.
- We may share information on other products and services that may be of interest to your company but we will only do this where you have provided your consent. You can always change your mind by contacting us using the details shown in your documentation and telling us you no longer wish to be contacted.
- We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you wish to unsubscribe from emails sent by us, you may do so at any time by following the unsubscribe instructions that appear in all emails. Otherwise you can always contact us using the details set out in your documentation to update your contact preferences. In such circumstances, we will continue to send you service related (non-marketing) communications where necessary.
- We would like to keep you informed, from time to time about relevant products and services. We may do this by mail, email, telephone or other electronic methods such as text message. In order to help us get to know you and identify what products and services may interest you we obtain information about you from other sources inside and outside Conaghan & Company for example, companies who provide consumer classification and market segmentation data for marketing purposes. Examples of these organisations are Experian or LexisNexis.
- From time to time we may run specific marketing campaigns through social media and digital advertising that you may see which are based on general demographics and interests. Individual personal information is not used for these campaigns. If you do not want to see any campaigns then you will need to adjust your preferences within social media settings and your cookie browser settings.
- We will also share information that we collect about you for marketing within Conaghan & Company, if you give us permission to do so. If you change your mind you can let us know by adjusting your choice.
- The time period we retain your personal information for will differ depending on the nature of the personal information and what we do with it. How long we keep personal information is primarily determined by our regulatory obligations. We typically keep quote information for five years. In some cases, such as if there is a dispute or a legal action we may be required to keep personal information for longer.
Our Commitment in Respect to the Use of Personal information
- We provide you with up-to-date prevention and protection solutions, through an in-depth and well-informed understanding of the risks you face. To do this, we collect your personal information and use it in compliance with data protection laws.
- We have in place procedures and contractual arrangements designed to ensure that all employees and service providers keep client files confidential.
- Our clients often entrust us with sensitive personal information. We view ourselves as custodians of this data and do not sell it to third parties outside Conaghan & Company.
- You can ask us to do various things with your personal information. For example, at any time you can ask us for a copy of your personal information, ask us to correct mistakes, change the way we use your information, or even delete it. We’ll either do what you’ve asked, or explain why we can’t - usually because of a legal or regulatory issue.
- You have the following rights in relation to our use of your personal information:
The right to access your personal information
- You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing, unless otherwise requested.
The right to rectification:
- We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us by using the details shown in your documentation and you can ask us to update or amend it.
The right to erasure:
- In certain circumstances, you have the right to ask us to erase your personal information, for example where the personal information we collected is no longer necessary for the original purpose or where you withdraw your consent. However, this will need to be balanced against other factors, for example according to the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.
Right to restriction of processing:
- In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to process your personal information.
Right to data portability:
- In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice. Once transferred, the other party will be responsible for looking after your personal information.
Right to object to direct marketing:
- You can ask us to stop sending you marketing messages at any time. Please see the Marketing section for more information.
Right to Withdraw Consent
- For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. Please note in some cases we may not be able to process your Client Onboarding or provide advisory services if you withdraw your consent.
The Right to Lodge a Complaint
- You have a right to complain to the ICO at any time if you object to the way in which we use your personal information. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/
- You can make any of the requests set out above using the contact details provided to you in your correspondence with Conaghan & Company. Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make and if we can't comply with your request, we will tell you why.
- Conaghan & Company may use data to check against lists of people known to have undertaken fraudulent transactions and will reject those people on the basis they are likely to defraud the company.
Data Protection Officer
Conaghan & Company Limited
29 Farm Street
London W1J 5RL
Tel: 020 3709 4571