This privacy notice tells you what we do with information we collect about you. It’s relevant to anyone who uses our services, including policyholders, prospective policyholders, website users and beneficiaries under our policies, such as named drivers. We refer to all these individuals as "customers", "you" and “policyholders” in this notice.
Who "we" are
We are “Tudor House Insurance Services Ltd.
We are an independent insurance broker who are authorised and regulated by Financial Conduct Authority(FCA). We are a privately-owned company who provide insurance policies for private individuals and commercial organisations.
What information do we collect about you?
Information collected from you
Where we have collected information directly from you it will usually be obvious what this is, as you will have given it to us. Examples are:
Information collected from others
We can collect information about you from others. This includes information from:
Joint policyholders or policy beneficiaries. Where you are named on a joint policy or a beneficiary of that policy we may collect information about you from any named policyholder. We will ask them to confirm that they have your permission to give us this information about you.
Fraud prevention, law enforcement or government agencies and other data sources used to prevent or detect fraud or provide details to us about criminal convictions or offences.
HM Treasury and other authorities in relation to regulatory issues e.g. where someone is subject to a financial sanction they will appear on HM Treasury's asset freezing list.
Credit reference agencies e.g. credit searches that are made when we produce a quotation for a new policy or at renewal. (Note that the results of these searches are automatically deleted after 12 months and do not affect your ability to obtain credit.) Please also see section 4 below.
External sources such as no claims discount databases.
Sensitive personal information
We collect information that is sensitive, information related to unspent past criminal convictions or offences. We also collect your sensitive personal information for specific types of policy or applications, for example when offering you a travel policy or a driving application e.g. Telematics. We obtain this from your mobile devices for driving applications and the following people:
The main policyholder will provide most of the information we collect about health (including confirming whether hospital treatment is being sought) and unspent criminal convictions or offences, including on behalf of others named on the insurance policy e.g. medical screening to support a travel policy;
Fraud prevention or law enforcement agencies may provide details to us about criminal convictions or offences;
Witnesses to an accident may provide medical information to us if there is an investigation of a claim;
We may use information about a child, for example, where the child is a beneficiary under a policy or if involved in an accident.
We collect and use this information as part of your insurance quotation or contract with us, or where it is necessary for a legal obligation, or as part of the establishment or defence of a legal claim.
What do we do with information we collect about you and why may we do this?
We use your personal information in order to meet our obligations in our contract of insurance with you. We use your personal information in the following ways:
A. Provide insurance services
When you request us to provide you with a quote for one of our insurance policies or you purchase an insurance policy from us, we use information about you:
We cannot provide the services unless we use the information about you in this way.
B. Do what we are required to do by law
As part of our duty as a Broker providing insurance services, sometimes we are required by law to use information about you:
To help make sure our customers are being treated fairly (e.g. to assist our regulators where we have a legal duty to do so);
We can use your personal information in this way because we are required to do so by law.
C. Prevent fraud occurring
Fraud has an impact on all customers as it increases costs for everyone. We use your personal information to check for signs that customers might be dishonest (e.g. if someone has behaved dishonestly in the past it may increase the risk they will do so in future).
We may use your personal information in this way because it is in our interests to detect fraud and in all our customers' interests to ensure that they are not prejudiced due to increased premiums as a result of a few customers acting dishonestly.
D. Recover debt
If you owe us money we will use your personal information to help us recover it.
We can use your personal information in this way because it is a necessary part of the contract of insurance. We need to ensure that premiums are paid so that the majority of our customers do not suffer (e.g. through increased premiums) due to the actions of a small minority of customers.
E. Where your or another person's life may be at risk
We will use your personal information to assist where your or another person's life or health is in danger and obtaining your permission is not possible (e.g. arranging emergency medical treatment in a remote location).
F. To administer and improve our services
To administer our services we will share information with others (including to people or organisations that may be based overseas):
In order to enable us to process your claim or administer your insurance policy more cost effectively;
We may also process your personal data to better understand you as a customer, including to determine how best to retain your custom, and to ask you to provide feedback on the service we provide to you.
We can use your personal information in this way because it is in our legitimate interests to provide the services in the most efficient way. We will always ensure that we keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum to achieve this efficiency.
Who do we share your personal information with and why do we do it?
We may share your personal information with third parties and other companies for the purposes mentioned in sections above. You should make sure everything you tell us is correct because your records may be checked in the following circumstances:
When you apply for insurance, financial services, or work by police and other law enforcement agencies.
In particular we share information with:
Fraud prevention agencies that provide databases and services, such as CIFAS, National Hunter, SIRA and ENI, to prevent or detect fraud.
Fraud prevention agencies will process this personal information in order to assist our prevention of fraud and money laundering, and to verify your identity and may also process your personal information in order to prevent fraud and money laundering by other people.
Fraud prevention agencies will hold your personal information for up to 1 year, or up to 6 years if you’re considered to pose a fraud or money laundering risk.
If we or a fraud prevention agency determine that you pose a fraud or money laundering risk, we may refuse to provide the services and / or financing you have requested.
A record of this risk will be retained by the fraud prevention agencies and may result in others refusing to provide services or financing to you. If you have any questions about this, please contact the appropriate fraud prevention agency.
Law enforcement or government agencies we and fraud prevention agencies may permit law enforcement or government agencies to access and use your personal information, if they request it.
Credit reference agencies help us decide whether to offer you credit if you choose to pay your premium by instalments. We share this information when you first take a policy with us and at each renewal. We may exchange your personal information with credit reference agencies to reflect your credit application (as payment by instalments means that there will be a credit agreement between us). We will let you know before we do this. This will be visible to other credit providers. Failure by you or anyone who pays for your policy to keep up the monthly payments due under your credit agreement will be reflected in your credit score, not theirs. The identities of the credit reference agencies and the ways in which they use and share personal information are explained in more detail at www.experian.co.uk/crain/. Alternatively, you can call us and we will send you a copy.
Your spouse or partner who calls us on your behalf, provided they are named on the policy. Please tell us who they are when you take out your policy. If you would like someone else to deal with your policy on your behalf on a regular basis please let us know. In some exceptional cases, we may also deal with other people who call on your behalf, but only with your permission. If at any time you would prefer us to deal only with you, please let us know.
Other insurance companies to help settle any insurance claim or to verify that the information you have provided is correct (e.g. we will check the amount of No Claims Discount you have told us with your previous insurer).
Insurance industry bodies such as The Motor Insurance Database to meet our obligations under the Road Traffic Act.
Insurance industry databases, such as the Claims and Underwriting Exchange where you make a claim so that insurers can check that your claims history is correct, the Insurance Fraud Register and, for commercial policies, the Employers’ Liability Tracing Office.
Government bodies, such as the Driver and Vehicle Licensing Agency.
How long may we keep your personal information for?
We are only allowed to keep your personal information if we need it for one of the reasons we describe in sections above.
As a general rule, we will keep it for 6 years from the end of your relationship with us, as it is likely that we will need the information for regulatory reasons or to defend a claim. For example, should you wish to bring some form of legal action relating to your relationship with us, this would generally need to be done within 6 years from the end of that relationship. However there may be exceptions where we need to keep your personal information for longer, such as where a claim has involved a minor.
When can you ask us to stop using your information?
If we rely on your consent to collect and process your personal information, you can ask us to stop using your personal information at any time by withdrawing that consent and we will stop using your personal information for those purposes.
What happens if you don't give us some of your personal information?
Where you do not provide the personal information we need in order to provide the service you are asking for or to fulfil a legal requirement, we will not be able to provide the service that you are asking us to give you.
We will tell you about why we need the information when we ask for it.
How to contact us about this privacy notice
Our Data Protection Officer is in charge of answering questions about this privacy notice or your requests to exercise your rights which are set out below. The Data Protection Officer may be contacted at:
63 Regent Street Wrexham LL11 1PF tel: 01978 290800
You may contact us at the address above for one or more of the following reasons:
To ask us to fix information about you that is wrong or incomplete, or to delete personal information about you (the so-called "Right to be Forgotten").
To tell us you no longer agree to, that you object to, or that you wish to restrict us using information about you and ask us to stop.
To tell us to stop using your personal information to tell you about products or services that may be of interest to you (direct marketing).
A right of access, namely to ask us to provide you with a copy of all of the personal information that we have about you. To receive this information please write to the Data Protection Officer 63 Regent Street Wrexham LL11 1PF
Version - April 2018