Customer Privacy Notice
Why should you read this document?
During the course of dealing with us, we will ask you
to provide us with detailed personal information
relating to your existing circumstances,
your financial situation and, in some cases,
your health and family health history (Your
Personal Data). This document is important
as it allows us to explain to you what we
will need to do with Your Personal Data,
and the various rights you have in relation
to Your Personal Data.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes
or relates to your personal circumstances.
Your Personal Data may identify you directly,
for example your name, address, date of
birth, national insurance number. Your Personal
Data may also identify you indirectly, for
example, your employment situation, your
physical and mental health history, or any
other information that could be associated
with your cultural or social identity.
In the context of providing, you with assistance in
relation to your insurance requirements
Your Personal Data may include:
-
Title, name, date of birth, gender, nationality, civil/marital
status, contact details, addresses and documents
that are necessary to verify your identity.
-
Employment and remuneration information,
(including salary/bonus schemes/overtime/sick
pay/other benefits), employment history.
-
Bank account details, tax information, loans
and credit commitments, personal credit
history, sources of income and expenditure,
family circumstances and details of dependents.
-
Health status and history, details of treatment
and prognosis, medical reports (further
details are provided below specifically
with regard to the processing we may undertake
in relation to this type of information).
-
Any pre-existing insurance products and
the terms and conditions relating to these.
The basis upon which our firm will deal
with Your Personal Data
When we speak with you about your insurance requirements,
we do so on the basis that both parties
are entering a contract for the supply of
services.
In order to perform that contract, and to arrange the
products you require, we have the right
to use Your Personal Data for the purposes
detailed below.
Alternatively, either in the course of initial discussions
with you or when the contract between us
has come to an end for whatever reason,
we have the right to use Your Personal Data
provided it is in our legitimate business
interest to do so and your rights are not
affected. For example, we may need to respond
to requests from mortgage lenders, insurance
providers and our Compliance Service Provider
relating to the advice we have given to
you, or to contact you to seek feedback
on the service you received.
On occasion, we will use Your Personal Data for contractual
responsibilities we may owe our regulator,
The Financial Conduct Authority, or for
wider compliance with any legal or regulatory
obligation to which we might be subject.
In such circumstances, we would be processing
Your Personal Data in order to meet a legal,
compliance or other regulatory obligation
to which we are subject.
The basis upon which we will process certain parts of
Your Personal Data
Where you ask us to assist you with for example your
insurance, in particular life insurance
and insurance that may assist you in the
event of an accident or illness, we will
ask you information about your ethnic origin,
your health and medical history (Your Special
Data). We will record and use Your Special
Data in order to make enquiries of insurance
providers in relation to insurance products
that may meet your needs and to provide
you with advice and or guidance regarding
the suitability of any product that may
be available to you.
If you have parental responsibility for children under
the age of 13, it is also very likely that
we will record information on our systems
that relates to those children and potentially,
to their Special Data.
The arrangement of certain types of insurance may involve
disclosure by you to us of information relating
to historic or current criminal convictions
or offences (together “Criminal Disclosures”).
This is relevant to insurance related activities
such as underwriting, claims and fraud management.
We will use Special Data and any Criminal
Disclosures in the same way as Your Personal
Data generally, as set out in this Privacy
Notice.
Information on Special Category Data and Criminal Disclosures
must be capable of being exchanged freely
between insurance intermediaries such as
our Firm, and insurance providers, to enable
customers to secure the important insurance
protection that their needs require.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a
variety of sources, but mainly directly
from you. You will usually provide information
during the course of our initial meetings
or conversations with you to establish your
circumstances and needs and preferences
in relation to insurance. You will provide
information to us verbally and in writing,
including email.
We may also obtain some information from third parties,
for example, credit checks, information
from your employer and searches of information
in the public domain such as the voter’s
roll. If we use technology solutions to
assist in the collection of Your Personal
Data, for example software that is able
to verify your credit status, we will only
do so if we have consent from you, for us,
or our nominated processor to access your
information in this manner. With regards
to electronic ID checks we would not require
your consent but will inform you of how
such software operates and the purpose for
which it is used.
What happens to Your Personal Data when it is disclosed
to us?
In the course of handling Your Personal Data, we will:
Record and store Your Personal Data in our
paper files, mobile devices and on our computer
systems (websites, email, hard drives, and
cloud facilities). This information can
only be accessed by employees and consultants
within our firm and only when it is necessary
to provide our service to you and to perform
any administration tasks associated with
or incidental to that service.
Submit Your Personal Data to Product Providers and or
Insurance Product providers, both in paper
form and on-line via a secure portal. The
provision of this information to a third
party is essential in allowing us to progress
any enquiry or application made on your
behalf and to deal with any additional questions
or administrative issues that lenders and
providers may raise. Where you are making
an application for credit, the lender may
refer to a credit reference agency who will
process your data. This may impact upon
your credit rating.
Use Your Personal Data for the purposes of responding
to any queries you may have in relation
to any insurance policy you may take out,
or to inform you of any developments in
relation to those products and/or policies
of which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared
with:
Insurance providers
Third parties who we believe will be able to assist
us with your enquiry or application, or
who are able to support your needs as identified.
These third parties will include but may
not be limited to, our compliance advisers,
product specialists, providers of legal
services (in each case where we believe
this to be required due to your particular
circumstances).
In each case, Your Personal Data will only be shared
for the purposes set out in this Customer
Privacy Notice, i.e. to progress your finance
and or insurance enquiry and to provide
you with our professional services.
Please note that this sharing of Your Personal Data
does not entitle such third parties to send
you marketing or promotional messages, it
is shared to ensure we can adequately fulfil
our responsibilities to you, and as otherwise
set out in this Customer Privacy Notice.
If data is transferred outside the EEA whether
the transfer is made on the basis of an
adequacy decision by the European Commission
under Article 45 of the UK GDPR. If the
transfer is not made on the basis of an
adequacy decision, give people brief information
on the safeguards put in place in accordance
with Article 46, 47 or 49 of the UK GDPR.
Security and retention of Your Personal
Data
Your privacy is important to us and we will keep Your
Personal Data secure in accordance with
our legal responsibilities. We will take
reasonable steps to safeguard Your Personal
Data against it being accessed unlawfully
or maliciously by a third party.
We also expect you to take reasonable steps to safeguard
your own privacy when transferring information
to us, such as not sending confidential
information over unprotected email, ensuring
email attachments are password protected
or encrypted and only using secure methods
of postage when original documentation is
being sent to us.
Your Personal Data will be retained by us either electronically
or in paper form for a minimum period of
6 years following the advice/service you
receive from us, although your data could
be held for a longer period where this may
be needed to meet the requirements of our
regulatory bodies.
Your rights in relation to Your Personal Data
You can:
Request copies of Your Personal Data that is under our
control.
Ask us to further explain how we use Your Personal Data
Ask us to correct, delete or require us
to restrict or stop using Your Personal
Data (details as to the extent to which
we can do this will be provided at the time
of any such request)
Ask us to send an electronic copy of Your Personal Data
to another organisation should you wish.
Change the basis of any consent you may
have provided to enable us to market to
you in the future (including withdrawing
any consent in its entirety)
How to make contact with our Firm in relation to the
use of Your Personal Data If you have any
questions or comments about this document,
or wish to make contact in order to exercise
any of your rights set out within it please
contact:
In writing, please send your request to 40 Long Lane
Uxbridge UB10 0EG. Alternatively, please
contact our support by email info@tessaalliance.co.uk
or phone 02030626200.
If we feel we have a legal right not to deal with your
request, or to action it in a different
way to how you have requested, we will inform
you of this at the time.
You should also make contact with us as soon as possible
on you becoming aware of any unauthorised
disclosure of Your Personal Data, so that
we may investigate and fulfil our own regulatory
obligations.
If you have any concerns or complaints as to how we
have handled Your Personal Data you may
lodge a complaint with the UK’s data protection
regulator, the ICO, who can be contacted
through their website at https://ico.org.uk/global/contact-us/
or by writing to Information Commissioner’s
Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF.
This is our standard agreement upon which we intend
to rely. For your own benefit and protection
you should read the terms carefully. If
you do not understand any of these, please
ask for further information.