Data Protection & Privacy Statement
Occam Underwriting Limited (“Occam”, “we”, “us”) is committed to protecting the privacy and security of those with whom we interact. We recognise the need to respect and protect information that is collected or disclosed to us. This notice is to explain how we collect and use your Personal Information during and after your relationship with us, in accordance with applicable Data Protection Laws.
Occam Underwriting is a Managing General Agent operating on behalf of a number of insurers. Occam is committed to handling data fairly and lawfully and takes its data protection obligations seriously. Occam ensures that it processes Personal Information in compliance with applicable data protection laws, including, without limitation, the General Data Protection Regulation 2016/679 (“GDPR”)
For the purposes of this Data Protection Notice “Personal Information” consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier (e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. When we combine other information (i.e. information that does not, on its own, identify you) with Personal Information, we treat the combined information as Personal Information.
The Personal Information that we collect may include the following:
- Information about your job including job title, business description and professional certifications
- Contact details including address, telephone number and email address
- Relationship to the customer
- Risk Information
- Information relating to the advice that you request or the services that we are providing
- Details of Bankruptcies, CCJ’s. IVA’s etc
- Financial information such as your financial history and needs, income, bank details, payment details and information obtained as a result of a credit check
- Payment information and reasons for cancellation
- Information captured or notes taken during telephone calls
- Queries and complaints
- We may also obtain Special Category Personal Data:
- Information obtained when we carry out checks of sanction lists
- Information relating to criminal sanctions (including offences and alleged offences and any caution, court sentence or criminal conviction). We may receive this information as a result of carrying out sanctions checks
We use your Personal Information for business purposes such as to arrange insurance policies, fraud prevention and claims notifications. This may involve sharing your information with third parties such as insurers, brokers, other insurance intermediaries, reinsurers, claims handlers, loss adjusters, credit reference agencies, service providers, professional advisors, our regulators, police and government agencies and fraud prevention agencies.
Collecting personal information
We will obtain your personal information directly from you or from a third party in a number of ways including:
- Communication such as email and telephone calls, application forms and initial disclosure documents
- Third parties who introduce you to us such as brokers and insurers
- Publically available sources such as internet search engines and social media sites
- Credit reference agencies or company searches
- Fraud prevention and detection databases and sanctions screening tools
- Government agencies such as Companies House and the FCA
Using your information
We may process your information for a number of different purposes. For each purpose, we must have a legal ground for such processing ie:
- We need to use your personal information to enter into or perform our contract with you, for example to fulfil our obligations under our contract and place appropriate insurance cover or to provide you with a quote
- We have a genuine business need to use your personal information such as maintaining our business records, keeping records of insurance policies we place and analysing and improving our business model and services. When using your personal information for these purposes, we have considered your rights and ensured that our business need does not cause you harm
- We have a legal or regulatory obligation to use your personal information, for example to meet regulatory record keeping requirements
When the information that we process is classed as a special category of information, we must have one of the following additional legal grounds for such processing:
- It is necessary for an insurance purpose and it is in the substantial public interest. This will apply where we are advising or arranging an insurance policy, assisting with any claims under a policy, and undertaking any activities to prevent and detect fraud.
- Where the use of your special categories of information is necessary to establish, exercise or defend our legal rights, for example legal proceedings are being brought against us or we want to bring a legal claim ourselves.
Disclosing your information
From time to time, we may share your personal information with the following third parties for the purposes set out above:
- Insurance partners such as other insurance intermediaries, insurers, reinsurers or other companies who act as insurance distributors
- Brokers who act directly for you and who have approached us to facilitate the placement of an insurance policy for you
- Third parties who assist in the administration of insurance policies such as accountants, auditors, lawyers and other experts
- Fraud detection agencies and other third parties who operate and maintain fraud detection registers
- Police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime
- Insurers who provide our own insurance
- Industry bodies
- Third party services providers such as IT suppliers, finance and payment providers, actuaries, auditors, lawyers, marketing agencies, document providers, tax advisers and insurance software providers
- Third parties in connection with the sale, transfer or disposal of our business
- We do not sell Personal Information to third parties.
We have in place appropriate physical and technical measures to safeguard the Personal Information that we collect. In addition, we limit access to Personal Information to those employees, agents, contractors and other third parties who have a need to know. They will process your Personal Information on our instructions and they are subject to a duty of confidentiality.
Although we take appropriate steps to protect your Personal Information, no website, product, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.
International data transfer
The Personal Information that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area (“EEA”).
By using or participating in any service and/or providing us with your Personal Information, you acknowledge that we may collect, transfer, store and process your information outside of the EEA. We will take all steps reasonably necessary to ensure that your Personal Information is kept secure and treated in accordance with this Data Protection Notice and the requirements of applicable law wherever the data is located. Where we transfer your Personal Information outside the EEA to other countries, we will ensure that appropriate transfer agreements and mechanisms (such as the EU Model Clauses) are in place to help ensure that our third-party service providers provide an adequate level of protection to your Personal Information. We will only transfer your Personal Information outside the EEA in accordance with applicable laws.
Occam retains Personal Information for as long as necessary to fulfil the purposes for which your Personal Information has been collected as outlined in this Data Protection and Privacy Statement unless a longer retention period is required by law. When your Personal Information is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.
Accessing your personal information and other rights
Occam will collect, store and process your Personal Information in accordance with your rights under any applicable Data Protection Laws. You have the following rights in relation to your Personal Information:
- Subject Access – you have the right to request details and a copy of the Personal Information which we hold about you
- Right to Withdraw Consent – where our use of your Personal Information is based upon your consent, you have the right to withdraw such consent at any time
- Data Portability – you may request us to transmit your Personal Information directly to another organisation
- Rectification – to the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Information about you. If you think that any information we have about you is incorrect or incomplete, please let us know.
- Erasure – you have the right to have your Personal Information erased where the personal data is no longer necessary in relation to the purpose for which it was originally collected; where you withdraw consent; and where the personal data has to be erased in order to comply with a legal obligation
- Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information and to only store such Personal Information
- Object to processing – You have the right to object to specific types of processing of your Personal Information
- Prevent automated decision taking – in certain circumstances, you have the right not to be subject to decisions being taken solely on the basis of automated processing
Enforcing your rights
Please contact us if you wish to enforce any of your rights under applicable Data Protection Laws.
We will respond to your request without undue delay and no later than one month from receipt of any such request, unless a longer period is permitted by applicable Data Protection Laws, and we may charge a reasonable fee for dealing with your request which we will notify to you. Please note that we will only charge a fee where we are permitted to do so by applicable Data Protection Laws.
If you are concerned that we have not complied with your legal rights under applicable Data Protection Laws, you may contact the Information Commissioner’s Office (ico.org.uk) which is the UK data protection regulator. If you are based outside the UK, you may contact your local data protection supervisory authority.
Third-party links and products on our services
Our websites, applications and products may contain links to other third-party websites that are not operated by Occam, and our websites may contain applications that you can download from third parties. These linked sites and applications are not under Occam’s control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third-party websites or applications, any Personal Information collected by the third party’s website or application will be controlled by the Data Protection Notice of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Information.
Data protection officer
We have appointed a Data Protection Officer to ensure continued compliance with Data Protection Laws.
Changes to this data protection notice
We may change this Data Protection and Privacy Statement from time to time, changes will become effective upon our posting of the revised Data Protection and Privacy Statement on our website. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. We will provide this notice by posting a notice of the changes on our website.
Occam Underwriting Limited
One Silk Street, London. EC2Y 8HQ