It is the intention of this privacy statement to explain to you how we provide you with suitable products and services; we need to get to know you and who you are. This is the information gathering and storing practices of JD Insurances Limited in relation to the information we collect about you and other users.
This means we collect certain information about you in the course of operating our business. This notice sets out details of the information that we collect, how we process it and who we share it with. It also explains your rights under data protection law in relation to our processing of your data.
For the purposes of the GDPR the data controller is:
- JD Insurances Limited
- Data Controller: Mr. John Doyle (Director)
- Pembroke Hall, 38/39 Fitzwilliam Square West, Dublin 2. Phone 01 910 9950. Email: email@example.com
- When we refer to ‘We’ it is JD Insurances Limited
Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
We at respect your right to privacy and comply with our obligations under the Data Protection Acts 1988 and 2003 and General Data Protection Regulation (GDPR). We are committed to protecting and respecting your privacy.
If visiting our website, you are accepting the terms of Privacy Statement and Cookies Statement. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy and cookies statement of these other websites.
JD Insurances Limited collects Personal Data from you through the use of the enquiry forms, proposal forms, claim forms, pay your premium, online services, phone calls and when you email your Personal Data to us. JD Insurances Limited is the Data Controller in respect of all such Personal Data collected.
Types of Information collected
Personal Data: This is data that identifies you or can be used to identify or contact you and may include your name, address, email address, user IP addresses in circumstances where they have not been deleted, clipped or anonymised, telephone numbers, birth date, occupation, employer, income, PPS number, membership details where applicable, nationality, marital status, full details of property to be insured, disabilities, diseases or medical conditions, convictions or prosecutions, previous insurance declinatures or terms imposed by other insurers, claims history, driving experience, licence type, mileage, billing and credit card information. Such information is only collected from you if you voluntarily submit it to us. If we collect any sensitive personal information, we will restrict access to and use of this. With regard to Group Schemes, employers may provide details to facilitate cover for employees this may include name, date of birth, address, gender, contact details, this information may be provided electronically. We must have a lawful basis to collect and use personal information which is set out below.
Non Personal Data: Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our website
Cookies are small text files placed on your computer and are commonly used on the internet. They allow us to make our website more useful based on stored information about your preferences when you visit us. We do not store cookies beyond such interaction. If you choose to, you can set your web browser to reject cookies from our service, although you may not be able to experience the full service we provide if cookies are disabled.
Purpose for which we hold your information
We will process any Personal Data you provide to us for the following purposes:
(a) to provide you with insurance broking and administration services (including securing and providing quotations, arranging, managing and renewing insurance policies and processing claims) by JD Insurances Limited, our associated companies, agents and/or service providers; and/or
(b) to contact you if required in connection with the provision of our services or to respond to any communications you might send to us.
Our telephone calls with you may be recorded and monitored for training and quality control purposes.
Any Sensitive Personal Data that we collect (such as details of your medical history or criminal convictions) will be used solely for providing you with the above services.
Why do we need to collect and store personal data?
In order for us to provide you insurance broking services we need to collect personal data to commence and complete the contract of insurance on your behalf, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
Legal Basis – JD Insurances Limited needs to process your data as this is necessary in relation to a contract of insurance to which the individual has entered into or because you has asked for something to be done so you can enter into a contract. The primary basis that we use i) processing necessary for the performance of a contract of insurance. ii) Processing that is required under applicable law.
- If we provide you with advice we are required to complete an analysis of your insurance needs to ensure that we recommend an insurance plan that is the most suitable for you.
- Claims – we are required to gather information on the claim for onward transmission to the Insurance company.
- Applications/online applications/proposal forms – we are required to gather this information for onward transmission to the Insurance company.
- We carry out internal reporting, quality checking, and compliance controls to help meet our legal obligations.
- We record telephone calls for training, auditing and records purposes
- If you visit our offices we will record CCTV footage for safety and security reasons, we only hold these recordings temporarily and longer if we need to for safety and security investigations.
- We are also required to screen customers against Financial Sanctions lists and to do this we will use your name, date of birth and address.
- Keeping proper records
- Reporting to regulators
Marketing – If you consent to us sending you marketing messages about our products and services we will process your personal data in order to make sure that any marketing messages that we send you are relevant to you.
We also conduct surveys which provide us with invaluable information on service standards. Measuring customer experience helps us to improve and enhance our service to you.
Administering our computer system- Data may need to be tested by our software house prior to release of upgrades. This data is on most occasions anonymised data, but live data may have to be used at times to ensure everything is working before the change is rolled out. In general this processing of your personal data is justified by our legitimate interests in making sure our computer systems run properly and are safe and secure.
We will not disclose your Personal Data to third parties unless you have consented to this disclosure or unless the third party is required to fulfil the provision of our service to you (e.g. to secure quotations, insurance cover). We will disclose your Personal Data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
By sending your Personal Data to us, applying for quotations or purchasing our services via this website, you signify your consent to your Personal Data being used, processed and disclosed by us, our associated companies, agents, service providers, insurers and business partners, for any of the purposes outlined at above on the terms set out in this Privacy and Cookies Statement.
How will we use the personal data it collects about me?
We will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
We are required to retain information in accordance with the law, such as information needed for insurance, claims, cover verification and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Special Categories of personal data
If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) – we will ensure the below
- We will obtain your explicit consent
- You are free to withdraw your consent at any time.
To generate quotation for specific classes of insurance we may enter your data into a quotation engine which will generate a comparison quotation. The classes of Insurance this currently applies to Motor/House. The algorithms used are set by the Insurance Providers.
Who are we sharing your data with?
We have your consent
- Onward transmission to your Insurance Entity/Finance Company/Claims Handler
- We need to process your data to complete the performance of a contract where you, the data subject is a party.
- Service Providers – We rely on trusted third parties to help us run our business and to provide specialised services. These can include companies that provide IT Services (e.g. scanning, IT databases, hosting data when providing software services). This can also include legal advisors, accountants and consultants. Where our service providers have access to your personal data, we ensure they are subject to appropriate contracts and other safeguards.
- Protect the vital interests of the data subject, including the protection of rights and freedoms
- Necessary for the legitimate interests of the data controller or third party, unless the processing is overridden by the vital interests, including rights and freedoms
If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.
Data Subjects Rights:
JD Insurances Limited facilitate you, our clients, rights in line with the data protection policy and the subject access request procedure. This is available on request.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access– you have the right to request a copy of the information that we hold about you.
- Right of rectification– you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten– in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing– where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review – In the event that JD Insurances Limited refuses your request under rights of access, we will provide you with a reason as to why.
All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.
Additional information we are providing you with to ensure we are transparent and fair with our processing
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which it was collected. We will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (Central Bank, Revenue ) and our internal governance.
Failure to provide further information
If we are collecting your data to fulfil a contract of Insurance and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.
Under what circumstances will we contact you?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
In the event that you wish to make a complaint about how your personal data is being processed by JD Insurances Limited, you have the right to lodge a complaint with JD Insurances data protection representative Data Protection Officer at firstname.lastname@example.org
You also have the right to lodge a complaint with the Data Protection Commission, refer www.dataprotection.ie website