Protecting Your Privacy
WHITE OAK UNDERWRITING AGENCY
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how White Oak Underwriting Agency Limited (White Oak) uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time, please come back and check it whenever you wish.
Personal data means data which relate to a living individual who can be identified –
(a) from that data, or
(b) from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller,
and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to confirm that you would like us to contact you.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you want to be insured via White Oak, we may collect your address to send your policy to.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting White Oak to law enforcement and regulatory bodies.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, if you would like to be insured via White Oak we will need your information so that we can verify and pay your claim.
We also combine the data of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
- When you visit any of our websites and enter this information
- When you provide these details to our third parties, such as brokers or claims handlers
- When you contact us and provide this information
- When you engage with us on social media
- When you contact us by any means with queries, complaints etc.
- When you ask one of our employees or partners to provide you information about a product or service we offer
- When you book any kind of appointment with us
- When you choose to complete any surveys we send you
- When you comment on or review our products and services
- When you fill in any forms. For example, if you are filing a claim, an employee or Partner may collect your personal data
- When you’ve given a third party permission to share with us the information they hold about you
- When our White Oak Partners – such as a broker or claims adjuster – share information with us about the product you have purchased or a claim that you have made
- We may collect data from publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law
- This ranges between: your name, gender, date of birth, address, email, telephone number and other relevant information for the product/service we are providing for you
- Details of your interactions with us through our Partners, For example, we may collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made and when you contact us.
- Copies of documents you provide to prove your age or identity where the law requires this (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
It is always your choice whether you share such details with us or our Partners.
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the best levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our websites or Partners. If we don’t collect your personal data during this stage, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you required, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations, for example claims payments, refunds, guarantees.
- To respond to your queries, refund requests and complaints. We may keep a record of these to assist any future communication and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business from fraud and other illegal activities. This includes using your personal data to do sanctions checks in line with our legal obligations. We’ll do this as part of our legitimate interest.
- Please note we can’t be responsible for the content of external websites or services, including those of our Partners
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests and contractual obligations. This also helps to protect us from fraudulent activity.
- If we discover any criminal activity or alleged criminal activity through fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, legally required information relating to our products.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
- To comply with our contractual or legal obligations to share data with law enforcement. For example, if a claim goes to trial and we are asked to share data with law enforcement agencies or a court of law.
- To build a fuller picture of your requirements, and to inform our business decisions, we’ll combine data captured from across White Oak, third parties and data from publicly-available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ We’ll do this on the basis of our legitimate business interest. For example, by combining this data, this will help us improve your experience and be able to tailor and build new products in the future.
We want to bring you new or improved products that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
Access to your personal data is password-protected, and sensitive data is secured to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
We will keep your Personal Information only as long as necessary for the purposes for which we collected it and to comply with applicable law. Depending on our relationship with you, we may keep your Personal Information for a number of years after our relationship ends.
We will keep Personal Information for as long as is necessary for the purposes for which we collect it. The precise period will depend on the purpose for which we hold your information. In addition, as a regulated financial services institution, there are laws and regulations that apply to us which set minimum periods for retention of Personal Information.
- Where we hold Personal Information to comply with a legal or regulatory obligation, we will keep the information for at least as long as is required to comply with that obligation.
- Where we hold Personal Information in order to provide a product or service (such as an insurance policy and claims handling), we will keep the information for at least as long as we provide the product or service, and for a number of years after expiry of the policy and the handling of any related claim.
The number of years varies depending on the nature of the product or service provided – for example, for certain insurance policies it may be necessary to keep the Personal Information for several years after the expiry of the policy. We retain the information in order to respond to any queries or concerns that may be raised at a later date with respect to the policy or the handling of a claim. Typically, for insurance products, the retention period is seven years.
For further information about the period of time for which we retain your Personal Information, please contact us using the details below.
For example, insurance companies, regulators, brokers, claims handlers or adjusters, lawyers and so on. This could be to pay a claim, for fraud management, to handle complaints and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify to them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, we will ask for any of your data held by them to either be deleted or rendered anonymous if it is no longer needed for insurance purposes.
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Operational companies such as delivery couriers.
- Google/Facebook/Twitter/LinkedIn to show you products that might interest you while you’re browsing the internet.
- Data insight companies to ensure your details are up to date and accurate.
Who is responsible for third party services accessed via White Oak?
We are not responsible for the privacy, information or other practices of any third parties, including any third party operating any site or service to which White Oak link.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the information security practices) of other organisations, such as social media platforms or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or electronic device manufacturer, including any Personal Information you disclose to other organisations through or in connection with White Oak.
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
International policy holders
If you are based outside the UK and place a policy with us, we will hold the personal data that we collect from you in the UK or the EEA.
Protecting your data outside the UK or the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
For example, this might be required in order to fulfil your order or provide support services.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You have the right to request a copy of any information about you that White Oak holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information or to amend it, please contact the Compliance Officer at the address below, or email firstname.lastname@example.org.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113 .
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites).
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK or EEA.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers around the world.
For the purposes of this Privacy Notice, ‘personal data’ means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, and whether or not the information or opinion is recorded in a material form.
If you reside in Australia you may submit any questions, comments or complaints to our UK-based team who will come back to you within 30 days.
If you are contacting us to complain about an alleged breach of this Privacy Notice or our legal privacy obligations, please provide us with as much detail as possible in relation to your complaint.
We will take every privacy complaint seriously and assess it with the aim of resolving all issues quickly and efficiently. We’d be grateful for your cooperation with us during this process by providing us with any relevant information that we made need.
If we have not come back to you within 30 days, or you are not happy with the response that you’ve received, you may submit a complaint to the Office of the Australian Information Commissioner. (opens in a new window; please note we can’t be responsible for the content of external websites.)
We are committed to keeping your personal information secure and will take all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
Nothing in this Privacy Notice restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).
To learn more about our cookies and website ‘track’ and ‘do not track’ practices please see our Cookies Notice.
As your data may be transferred to third parties outside Canada, local police or other enforcement, regulatory or Government bodies may have access to that data, with or without our knowledge.
The personal data we process may be accessed by people within White Oak, or by our third-party service providers, who require access for the purposes indicated in this Privacy Notice, or as may be permitted or required by applicable law. The personal data we collect is generally held in the UK.
If you have any questions, please contact us.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada, (opens in a new window; please note we can’t be responsible for the content of external websites) or in some Canadian provinces, your local Privacy Commissioner.
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact us and we will be pleased to help you:
Email us at email@example.com
Or write to us at:
White Oak Underwriting Agency Limited,
55 Gracechurch Street,
This notice was last updated on 22/05/2018