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    NASH WARREN INSURANCE SERVICES LIMITED PRIVACY NOTICE

    About Us

    In this privacy notice, references to “we”, “us” or “our” means Nash Warren Insurance Services Limited (company number 05047099). For any questions or concerns relating to this Privacy Notice or our data protection practices, or to make a subject access or any other request regarding the information we hold, please contact us at:-
    Nash Warren Insurance Brokers Limited, 309 – 311 Long Lane, Halesowen, West Midlands, B62 9LD. Telephone Number: 0330 053 5110 Website:
    www.nashwarren.co.uk.

    This Privacy Notice should be read in conjunction with our terms of business.

    We are registered with the Information Commissioners Office (ICO) under registration reference: Z9800462

    We are authorised and regulated by the Financial Conduct Authority (FCA) No.466459. Full details can be found at www.fca.org.uk.

    In accordance with the General Data Protection Regulation and related UK Data Protection Legislation, we are committed to protecting the confidentiality and security of the information that you provide to us. This Privacy Notice is designed to help you understand how we collect and use your information.

    We may collect information from you about other people, for example, named drivers to be included for cover on a motor insurance policy. If you give us information about another person it is your responsibility to ensure and confirm that:-

    • You have told the individual who we are and how we use personal information, as set out in this Privacy Notice
    • You have permission from the individual to provide that personal information to us and for us to use it, as set out in this Privacy Notice

    For the purposes of this policy personal data or data may include both personal data (any information that may identify a living individual), such as your name, address, date of birth and claims history and “special categories” of data such as information about alleged offences, criminal or motoring convictions and medical conditions.

    Nash Warren Insurance may change and/or update this policy from time to time, however we will not advise you of the changes so you should check our website to ensure you are referring to the latest version www.nashwarren.co.uk.

    How do we obtain your personal data?

    Nash Warren Insurance may obtain your personal data from a variety of sources. We may obtain it from you directly, a third party you have asked to act on your behalf such as a spouse, friend, parent, guardian or others named on your insurance policy. We may also receive data from other insurers you have dealt with in the past, for example if we request them to provide us with proof of your no claims bonus entitlement.
    Information about you may also be obtained from credit reference agencies such as Experian, fraud prevention agencies such as LexisNexis, HMRC’s Financial Sanctions Register, the Claims Underwriting Exchange (CUE), the Motor Insurance Bureau (MIB) and the Driver and Vehicle Licencing Agency (DVLA).
    We may request your Driving Licence Number as part of your application for motor insurance, if you add an additional driver to the policy mid-term or when you renew your policy. We may use your Driving Licence Number to obtain information from the DVLA’s My Licence system. For details relating to information held about you by the DVLA, please visit www.dvla.gov.uk and www.mylicence.org.uk. To view your driving licence, visit www.gov.uk/view-driving-licence.

    Your personal data may also be used to allow us to fulfil our legal or regulatory responsibilities, this may involve sharing your personal data with authorities such as the Financial Conduct Authority (FCA) or the Information Commissioner’s Office (ICO) if requested to do so. If you are unable or unwilling to allow us to use your data in line with this Privacy Notice, we will be unable to enter into a contractual relationship with you.

    Why we need and how we use your personal information?

    We only collect, use and store your information where we have lawful grounds and legitimate business reasons to do so. We collect, use and store your personal information in order to fulfil requests for quotes, products and services as part of our insurance broking, claims handling, complaint responding and risk management business. It may also be used to verify your identity, to administer payments and to enable us to carry out anti-money laundering and other financial crime checks where required. If you pay by instalments your information may also be used to arrange credit.

    The use of your data is essential for us to check your identity, to enable you to enter into an insurance contract and for the insurance to operate (for example, in the event of a claim). We may also use it to keep our records up to date, to notify you about changes to our service and to help us in the development of new products and services.
    If you do not provide the information required we are unlikely to be able to arrange your insurance and may not be able to provide certain services to you.

    We may monitor calls, emails, text messages and other communications with you. When you contact us we may keep a record of that correspondence and any information provided to us during that or any subsequent communication.

    Details of any vehicle insured and the insurer will also be used to demonstrate that you have insurance cover on the vehicle in line with the Road Traffic Act 1988 (RTA). In order to do so, these details will be passed to the Motor Insurance Database (MID), run by the Motor Insurers Information Centre (MIIC).

    We may also use your personal data for analytical purposes. For example, we may analyse how many claims happen in a particular postcode area. Using your data in this way assists us in providing our customers with the lowest possible premiums.

    We may ask you to review your experience with Nash Warren, this will assist us in developing and improving the service we offer.

    Who will we share your personal data with?

    We take the security of your personal data very seriously. In order to provide our range of products and services to you, it is necessary to share your personal data with third parties. We always ensure that the required safeguards are in place before sharing your data outside of our company.

    On occasion, it may be necessary to transfer some of your data outside of the EU, but we will only do so if that company is a member of the Privacy Shield scheme which affords you the same protection to your data as you would get within the EU. More information on Privacy Shield can be found at www.privacyshield.gov/welcome.
    The following outlines who we may share your data with and the circumstances in which we would do this.

    If you request a quotation

    • We pass your personal data to the insurer(s) who provide possible quotations for your policy and their appointed agent(s). Insurers or their agents will act as joint data controllers alongside us. The data you provided will be held on our internal systems and those of our software provider until they are removed in line with our retention policy.
    • In order to reduce insurance fraud and verify your identity, we may share your data with credit reference agencies and anti-fraud databases such as the Claims Underwriting Exchange (CUE) and Experian.
    • We may be requested by government or regulatory authorities, such as the Police or the Department for Work and Pensions, to provide your personal data to them. If we are under a legally obligation to do so, we may share your data with these government agencies for the purposes of crime and fraud prevention and the apprehension and prosecution of offenders.
    • We may share your personal data with internal or external auditors or professional advisors such as solicitors.
    • We may also share your personal data with anyone named on the insurance policy, parents or guardians of the policy holder or anyone whom you have authorised to discuss the policy on your behalf.
    • If false or inaccurate information is provided or fraud is identified, we may also pass your details to fraud prevention agencies. These and other organisations may access and use this information to prevent fraud and money laundering, for example, when checking details on proposals and claims for all types of insurance. Other organisations both inside and outside of the UK may also access the information recorded by these fraud prevention agencies for the prevention of crime or other lawful reason. You can contact your insurer directly to find out which fraud prevention agencies they use.
    • We may share your personal data with the Financial Ombudsman Service, if you have made a complaint to them about the provision, or a failure to provide our services to you.
    • It may be necessary to share you data with regulatory, supervisory or government agencies if we are required to do so by law.

    If you take a policy with us

    • We pass your personal data to the insurer(s) who underwrites your policy and their appointed agent(s), they may also share your personal data with their reinsurer(s). Insurers will act as joint data controllers alongside us. If you have a claim your personal data may be passed to claims management companies in order to assist with the administration and handling of the claim on your or an insurers behalf and to various anti-fraud databases for the detection and prevention of insurance fraud. The data you provided will be held on our internal systems and those of our software provider until they are removed in line with our retention policy.
    • In order to reduce insurance fraud and verify your identity, we may share your data with credit reference agencies and anti-fraud databases such as the Claims Underwriting Exchange (CUE) and Experian.
    • Details of any vehicle insured and the insurer will also be added to the Motor Insurance Database (MID), run by the Motor Insurers Information Centre (MIIC). This may be consulted by the Police in order to establish who is insured to drive the vehicle. If you are involved in an accident, (in the UK or abroad) other UK Insurers, the Motor Insurers Bureau and MIIC may search the MID to ascertain relevant policy information. Persons with a valid claim in respect of a road traffic accident (including citizens of other countries) may also obtain certain information which is held on the MID. You can find out more about this at www.mib.org.uk.
    • If you apply to pay your premium via a finance agreement, we will share your personal data with them in order for them to process your application for credit, they in turn may share this data with their appointed agents and credit reference agencies in order to ascertain your suitability for credit. A finance provider may also note your credit file if you miss monthly instalments on your finance agreement as they fall due.
    • We may be requested by government authorities, such as the Police or the Department for Work and Pensions, to provide your personal data to them. If we are under a legally obligation to do so, we may share your data with these government agencies for the purposes of crime and fraud prevention and the apprehension and prosecution of offenders.
    • We may share your personal data with internal or external auditors or professional advisors such as solicitors.

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    • We may also share your personal data with anyone named on the insurance policy, parents or guardians of the policy holder or anyone whom you have authorised to discuss the policy on your behalf.
    • We may also share your personal data with debt collection agencies (DCA’s) or debt tracing services for the purpose of managing debts and recovering outstanding monies owing on your account. We may also share your personal data with credit reference agencies in order to assist us in the recovery of outstanding balances or pass your details to the County Courts with a view to recovering any outstanding balance you owe by obtaining a County Court judgement (CCJ) against you. In addition we may sell the outstanding balance to a debt purchasing company.

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    • If false or inaccurate information is provided and fraud is identified we may also pass your details to fraud prevention agencies. These and other organisations may also access and use this information to prevent fraud and money laundering, for example, when checking details on proposals and claims for all types of insurance. Other organisations both inside and outside of the UK may also access the information recorded by these fraud prevention agencies for the prevention of crime or other lawful reason. You can contact your insurer directly to find out which fraud prevention agencies they use.

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    • We use carefully selected third party companies to act as an email platform to allow us to contact you efficiently and will share your personal data with them to allow us to do this.
    • In the event that we undergo re-organisation or are sold to a third party, in which case any personal data we hold about you may be transferred to that re-organised entity or third party.
    • We may disclose your personal data to a credit card company to validate your credit card details and obtain payment where it is necessary to deliver the products and services bought by you.

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    • We may share your personal data with the Financial Ombudsman Service, if you have made a complaint to them about the provision, or a failure to provide our services to you.
    • It may be necessary to share you data with regulatory, supervisory or government agencies if we are required to do so by law.

    What legal basis do we use for processing your personal data?

    We only use and store your personal data if we have a legal basis for doing so. It is your right as the subject of this data to be informed what the legal basis is for each type of processing that we undertake.

    We will process your personal data for the purposes of providing an insurance quotation, managing and administering your insurance policy, assisting with any claims, responding to complaints, policy enquiries, arranging premium finance on the legal basis that this process is necessary for the performance of a contract with you or to take steps to enter into a contract with you.

    If you are unwilling to share your personal data with us for these reasons, we are unable to enter into a contractual relationship with you. For the purposes above, personal data that is classed as “special data”, such as information relating to criminal or motoring convictions and medical conditions will be processed in accordance with the law on the legal basis that it is necessary for the performance of a contract with you on the legal authority that it is necessary for reasons of substantial public interest. We will follow all appropriate safeguards to ensure the security of this personal data.

    For processing of personal data for analytical purposes and for the purposes of debt recovery, our legal basis for processing is that it is necessary for the purposes of legitimate interest.

    We may also use your personal data for marketing purposes. Our legal basis for doing so is that we have a legitimate interest in doing so. You have the right to request that we do not contact you for marketing purposes at any time. You can contact us using the information in the contact details section and there is no detriment to you if you choose to do this.

    How long we keep information about you

    We will keep your information for as long as it is required to enable us to provide quotations, administer your insurances, offer renewal and respond to any claims or complaints (which may arise after the period of insurance has expired). This will usually be a minimum period of seven years or otherwise as determined by law or regulation. Once we decide that we no longer need your information it will be securely and confidentially destroyed.

    If your insurance is an employer’s liability policy, we will retain the details of this policy for at last 60 years. This is to ensure that the details are available to you should an employee lodge a claim against you far into the future, such as may be the case for an industrial disease where symptoms may not present themselves for many decades.

    What rights do you have in relation to your personal data?

    You have certain legal rights under UK data protection law and regulations, summarised as follows:

    • The right to be informed about our data processing activities, including through Privacy Notices such as this.
    • The right of access to the personal information we hold about you. To request a copy of this information you must make a subject access request in writing to us. This is free of charge.
    • The right of rectification. You may ask us to correct any inaccurate or incomplete data.
    • The right to erasure and to restrict processing. You have the right to have your personal data erased and to prevent processing except where we have a legal obligation to process your personal information. You should bear in mind that by exercising this right you may hinder or prevent our ability to provide products and services.
    • The right to data portability. On your request, we will provide you with your personal data in a structured format.
    • The right to object. You have particular rights in relation to automated decision making and profiling to reduce the risk that a potentially damaging decision is taken without human intervention. You can object to your personal data being used for profiling, direct marketing or research purposes.

      • Nash Warren Insurance have strict internal processes in place to ensure that your rights are upheld and that any requests you make in relation to these rights are responded to within 30 days of you making it.

      If you want to invoke any of these rights please write to us at the address specified at the beginning of this document, or alternatively e-mail us: info@nashwarren.co.uk.

      What responsibilities do you have?

      We will always endeavour to ensure that your personal data is accurate and up to date. If you notice that any information on your policy documentation is incorrect or if any of your personal details change, for example your address, your occupation, your bank details, please contact us to make us aware of the changes.

      Use of cookies on the Nash Warren Insurance website and Universal Analytics

      A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

      We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes.

      Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. This will however have a negative impact upon the usability of many websites, including ours.

      Our website has Google Analytics installed which allows us to track and compile anonymous visitor statistics. The information collected ranges from simple traffic volume to the type of browser you are viewing our website with and your computers IP address. This information is valuable to improve the usability, security and load speed of our website content. Google Analytics is a popular, secure, flagship webmaster product from Google. The privacy and security of Google Analytics data is a high priority at Google that you can read more about on Google’s Analytics Data Safeguarding page. Google also offer a Google Analytics Opt-out Browser Add-on that will allow you to automatically Opt-out of all websites that track your activity via Google Analytics. No personal information is collected by Google Analytics. Google’s privacy policy can be found at: https://policies.google.com/privacy.

      Links to other websites

      Where we provide links to you for third party websites, we accept no responsibility for any statements, information, content and products associated with these websites. We accept no liability for these third parties for any viruses or anything else that could be infectious or destructive.

      Withdrawal of consent

      Where you have provided your specific consent to the use of personal data, you may withdraw that consent by contacting us:
      Nash Warren Insurance Brokers Limited, 309 – 311 Long Lane, Halesowen, West Midlands, B62 9LD.
      Telephone Number: 0330 053 5110 Email: info@nashwarren.co.uk

      How to make a complaint

      If you wish to make a complaint about how we hold or use your data, please contact us:
      Nash Warren Insurance Brokers Limited, 309 – 311 Long Lane, Halesowen, West Midlands, B62 9LD.
      Telephone Number: 0330 053 5110 Email: helen@nashwarren.co.uk

      If you are dissatisfied with how we deal with your complaint, you may contact the Information Commissioner’s Office:
      The Information Commissioner Wycliffe House Water Lane Wilmslow Cheshire, SK9 5AF
      Telephone Number: 0303 123 1113 Website: www.ico.org.uk

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