Promotions Direct Ltd. T/a Sheridan Insurances believe in data protection and respecting your privacy rights under the relevant data protection Acts and regulations therefore this privacy statement explains to you what to expect when you supply your personal information to Promotions Direct Ltd. T/a Sheridan Insurances (“we”, “us”, “our”). Reference to “insurance company” hereafter means any of the following: insurance companies, managed general agents, underwriting agencies, insurers and product producers.
Collecting personal information about you for the performance of your insurance contract is necessary and legitimate however we set out hereunder further explanations in Plain English so that you can become aware of all the different data processors and sub-processors who may obtain your information, we also set out the reasons for this processing. This privacy statement is effective from 24th of May 2018
We are the data controller of your personal data. Should you wish to contact us in relation to any aspect of our use of your personal data, please contact our Data Protection Officer:
Phone: 049 438 0020
Address: 43 College Street, Cavan Town, Co. Cavan
Our friendly staff will be happy to assist with any queries you may have.
We provide support, advice, assistance and service in placement and arrangement of general insurance, health insurance, life, pension, savings and investment products suitable to your needs and this statement applies to information we collect about you:
- Should you visit us in person at our main office, contact us by telephone or through our Website the process is similar. For some insurance types our website allows you to submit your Name, Email Address, Phone Numbers, Type of Cover Sought, and Brief Description about your enquiry. This information is then sent to our Brokers who will assist you with your enquiry. Please note that we will need to collect further information that is necessary for the performance of your insurance contract and to fulfil the duty of care that we are required to provide to you.
- If your quotation is unsuccessful we will retain this information for a further 15 months due to our legal obligations and that of our joint controller(s) / processor(s). We may in the interest of good business relations, contact you by phone, post, email, text or through other digital media to offering to quote for similar needs in the subsequent year of your initial quotation.
- We may also in the interest of good business relations, contact you by post offering to quote for similar needs in the subsequent years of the above communication.
- Naturally, you will be given an option to “opt-out” of this information service which will be outlined by us in any form of communication to you. Should our quotation be successful, we will process your data in accordance with our terms of business which will be provided to you before purchase of your policy. Please refer to this document which clearly explains our legitimate basis for processing your data.
WHAT INFORMATION DO WE COLLECT?
Your proposal form contains all types of legitimate questions that an insurance company can ask in respect of an insurance risk that you seek cover for, depending on the types of risks you wish to obtain a quotation for, we will need to ask you certain types of questions, they include but are not limited to:
- Full Name which may include middles name(s)
- Address & Eircode
- Place of Residence & Previous Residence (should it be necessary)
- Date of Birth (This may be linked to databases for fraud detection)
- Telephone Numbers / Email Address
- Credit / Debit Card and Bank Account details
- Medical / Health / Health Related Information
- Unspent Criminal Convictions
- Marital Status
- Previous Claims History
- Employer Details
- Driver Licence Details
- Penalty Points / Road Traffic Offences
- Telematics Data
- GPS Tracker Information >
We also provide a premium finance credit facility which may be of interest to you. Should this be the case our outsourced partners may need to complete credit checks regarding your financial history and receive Proof of Identification in the form of a driving licence and/or passport, copy of recent Bank Statement and Proof of Address.
Should it be the case that you wish to insure another person such as a named driver(s) under your motor insurance policy or a spouse living with you in the home under your house insurance policy or include another interested party on any other policy type, we may need similar information regarding these persons/parties. Should you provide this information, we will assume that you have been given the consent of these persons/parties to supply this information to us. You should make these other persons/parties aware of this privacy statement, inform them that it also applies to them and give them our contact details outlined above should they wish to contact us with any concerns they may have.
DO YOU NEED TO SUPPLY THIS INFORMATION TO US?
We request this information from you so that your insurance contract can legitimately perform. If we are collecting your data for this purpose and you cannot provide this data the consequences of this could mean the contract cannot be completed and/or details are incorrect and may result in a policy being cancelled, claims not being paid and your encountering difficulty in trying to purchase another insurance contract.
However, you do have a range of different options available to you in respect of the current data protection regulations and Acts, some of these include the Right to Restriction, Right to be Forgotten, Right to Data Portability and the Right to Object. Should you require more information about your rights please visit www.dataprotection.ie
Where the use of your personal information by us requires your consent, such consent will be provided to us in accordance with our terms of business available at www.sheridaninsurances.com or any other contract we may have entered into with you or stipulated in our communication with you from time to time. Where we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw your consent at any time by contacting us.
WHY WE NEED TO COLLECT SENSITIVE INFORMATION ABOUT YOU?
We will process your personal data where it is necessary for us to comply with our contractual obligations to you, or where we need to take pre-contractual steps at your request.
We will process your personal data where necessary for the purposes of our legitimate interests. “Legitimate interests” means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience. For example, we may process your information to protect you against fraud when transacting on our website and to ensure that our websites and systems are secure. When we process your personal information for our legitimate interests, we make sure that we consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests –we will not use your personal data where our interests are overridden by the impact on you (unless we are required or permitted by law).
Your Insurance Company may process personal data they receive about you from third parties including but not limited to us, business partners, other insurers, claims teams and fraud prevention agencies.
Insurance is a risk-based market therefore insurers request your information so that they can evaluate and cost rate the risk accordingly, for the performance of your contract you need to disclose all material facts which are material to your insurance contract.
Some of the material information and facts you may have to disclose are regarded as sensitive information such as Unspent Criminal Convictions data or Health data. If there are questions related to unspent Criminal Convictions or Health on your proposal form, we will need to ask you about them.
Data Concerning Health is personal data which is regarded as more sensitive and so needs greater protection, such as medical records. In the event that you disclose such information to us we will assist you with greater security needs. In such circumstances, where necessary to protect your health, your insurer may process and share such data either with your explicit consent or, where this is not possible, they will do so in order to protect your vital interests.
WHO GETS TO ACCESS YOUR PERSONAL DATA AND SHARING YOUR INFORMATION?
Assuming you purchase an insurance, life, pension, savings or investment product from us, during the life of your policy and for a legitimate time thereafter, a range of different third parties may obtain your data for any further processing, we may share your information with third parties which includes but is not limited to:
- Insurers / Underwriters / Managing General Agents (MGA’s) / Sub-Brokers / Re-Insurers
- Vehicle Repair Companies / Property Repair Companies
- Motor Assessor(s)
- Loss Adjusters / Loss Assessors
- Solicitors / Accountants
- Witnesses to an accident
- Forensics Experts or Claims Investigators
- Law Enforcement agencies like the Gardaí
- Regulatory authorities like the Central Bank
- Credit Reference agencies
- Central Credit Register
- Company Director Search Websites
- Financial Services Ombudsman
- Injuries Board
- Brokers Ireland / Insurance Ireland
In accordance with their remit, insurers may seek highly confidential information about you from other sources, these include but are not limited to:
- Publicly available information including social media sites, online content, newspaper articles, TV, radio and other media content, court judgements.
- Insurance industry databases which collect and share information about you
- Insurance Ireland also have a fraud prevention website and should a statement be made about you by another it will be forwarded onto the relevant insurance provider.
When you place a risk on cover with us, your insurance company may reinsure that risk with another company as part of their risk management strategy therefore your information may be shared with them. They will use your data to decide whether they wish to provide reinsurance cover, or deal with reinsurance claims, we do not have a direct relationship with these however you should be aware that they may need to disclose your information within their group, their agents and affiliates or third-party service providers, law enforcers and regulating bodies.
If you remain concerned about the level of detail that any of the above / below has or may potentially ask you for, please do not hesitate to contact us and we will assist with the best advice possible to you due to the fact we value your business however we feel it important to make you aware of what may potentially occur.
When we ask you for certain information, it is because insurance companies need the information to perform certain validations about you, typical examples of this would include but are not limited to:
|Information Sought||Purpose(s)||Reason why|
|Driving Licence Number||To validate that your driving licence is in order with the relevant authority.|
To validate the number of penalty points disclosed by you.
|A valid driving licence is essential as an integral part of your insurance contract. Incorrect information disclosed could make your policy void.
|Motor Third Party Liability|
|Provide information about your insurance policy for inclusion in the Motor Third Party Liability Databases. (MTPLD)|
The information contained on this database can be accessed by Government bodies which include the Gardaí and the Motor Insurers Bureau of Ireland (MIBI) for the purposes permitted by law, including electronic licensing and law enforcement.
|To comply with legal obligations.|
|National Fleet Database||Commercial motor fleets/motor trade policyholder will be issued with a Unique Identification Number by insurers to upload personal information on this database. Insurers and other Government agencies including the Gardaí and the MIBI can check this database for the information you provided||To comply with statutory and legal obligations.|
|National Vehicle Data File (NVDF) & IIDS Hub||Insurers can access the NVDF controlled by the Department of Transport, Tourism and Sports (DTTAS) to validate driver numbers, number of penalty points per driver. Insurers may also be required by law to provide a validated driver number associated with all named drivers specified under an approved policy of motor insurance to the DTTAS. When you provide us with an No Claims Discount (NCD) PIN number, they will verify your No Claims information using the IIDS hub, where such information is made available by your previous insurer.||This type of information is material to your policy performance.
This type of information is material to your policy performance.
To validate your driver number and No Claims Discount.
To comply with legal obligations.
|‘Insurance Link’ Shared Claims Database – www.inslink.ie||To validate the claims details declared against claims history recorded on Insurance Link.||Claims information is integral part of your insurance contract, non-disclosure/misrepresentation could make your policy void and/or result in claims not being paid. It also assists Insurers in the detection and defence of exaggerated and fraudulent claims.
THE LEGITIMATE BASIS FOR COLLECTING YOUR PERSONAL INFORMATION AND CONTACTING YOU
Your business is important to us. We set out below the legitimate reasons why we collect your personal data and confirm that the purposes of this data collection is always in your best interests.
|Request for a quotation(s)||To obtain the necessary risk information required by Insurers on electronic quotation systems, manual quotation submission forms, proposal forms so that you will be able to enter a legitimate insurance contract.
|Set Up, Administer, Manage the policy||To obtain the necessary information required by Insurers to proceed with policy cover, set up your insurance contract, arrange premium finance, process any policy amendment instructions and keep your information accurate & up to date.
|Request for Identity Verification||To meet with fraud detection and prevention, anti-money laundering and counter terrorism requirements.
To be able to demonstrate insurable interest should you need to make a claim.
|Contacting You during the life of the policy||Sometimes, things change, as your broker we may need to inform you about changes to your policy /cover / terms and conditions.|
|Contacting you to obtain additional information requested by Insurers for Audit/Review/ Survey/Declaration or Projection purposes||As your broker, we act as agent between the insurer and you and will safeguard your interests.|
|Contacting you to verify your up to date Postal Address and to obtain your Email Address||To assist in sending your information to the correct location.|
|Contacting you to offer products and services which may be of interest / benefit to you (provided we have your explicit consent)||To offer you the best value proposition we have in the markets available to us.|
|Notification of a loss/ claim||Legal obligations.
|Investigation of a complaint||To interpret details of complaint and review information on file records/call recordings and communicate findings/outcome to complainant.
|Contacting you to obtain additional information requested by Insurers following a loss/claim||As your broker, we act as agent between the insurer and you and will assist you with your claim.
|Updating You during the life of the claim||Acting in your best interest and assist you with your claim.
SHARING YOUR INFORMATION FOR FRAUD PREVENTION, MONEY LAUNDERING AND OTHER OFFENCES
The data you provide will be sent to your insurance company and may be shared with other insurance companies, other third parties as well as certain statutory and other authorised bodies for the purposes of detection and prevention of fraud, money laundering and counter terrorism.
- Sharing information about you with other insurers and public bodies including the Department of Transport, Tourism and Sport, the Road Safety Authority, the Department of Finance and the Gardaí.
- Private Investigators, tracing debtors or beneficiaries, recovering debt, managing your accounts and/ insurance policies.
- Undertaking fraud searches on publicly available information as outlined above and other industry databases as outlined in Section 6 above.
AUTOMATED DECISION MAKING
We search the market on your behalf, insurers use automated decision making to decide if they can provide insurance to you and on what terms. In particular, they may use an automated underwriting engine coupled with algorithms to provide, or assist with providing, quotes including the premium that will apply to your policy of insurance, using the information we collected about you. An insurance company uses automated decision making as it is necessary for entering into, or performance of your policy between you as the data subject and your insurer as the data controller and other uses such as authorised by law.
Profiling for marketing purposes: when we seek to contact you about other services, we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.
USING OUR WEBSITE & ONLINE INFORMATION
YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
You have a number of rights in respect of the information stored about you, which include but are not limited to:
- Subject Access Requests for your information.
- The Right to Rectification to correct any mistakes on our records.
- The Right to be Forgotten to erase any documents you feel necessary however our legal obligations may over power these.
- The Right to Restriction of processing which allows you not to be subject to automated decision making if the decision produces legal or other significant effects about you.
- The Right to Data Portability which allows you to move certain data to other providers.
- The Right to Withdraw your consent however due to the fact we will rely on the contract as our legitimate basis for processing your information we will need to fulfil our legal obligations.
You can also contact the Data Protection Commission in Ireland at www.dataprotection.ie for information about your rights.
RIGHT OF ACCESS
Every person has a Right to be given a copy of his/her personal data. Under the Data Protection Acts, a Subject Access Request should be submitted in writing along with proof of your identity to our postal address for the attention of the “Data Protection Officer” and we will reply within 30 calendar days. Please be specific in your request as this will assist us to complete your request promptly.
HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION
Information submitted for a quotation may be retained by us for a period of up to 15 months from the date of quotation due to our legal obligations. If you purchase a product from us, information will be held for the duration of your insurance policy cover and for at least six years after our relationship ends in order to comply with applicable laws and regulations and for use in connections with any claims. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. For more information on our data retention policy/schedule please contact us.
Promotions Direct Ltd. intent is to strictly protect the security of your personal information; honour your choice for its intended use; and carefully protect your data from loss, misuse, unauthorised access or disclosure, alteration or destruction. We have taken appropriate steps to safeguard and secure information we collect online, including the use of encryption when collecting or transferring sensitive data such as credit card information. However, you should always take into consideration that the internet is an open forum and that data may flow across networks with little or no security measures, and therefore such information may be accessed by people other than those you intended to access it.
COMPLAINT AND CONTACT US
This privacy statement was last updated on 24th of May 2018.
Promotions Direct Ltd. T/a Sheridan Insurances is regulated by the Central Bank of Ireland.