How we use your informationWe take great care to ensure your information is kept safe and secure. This policy explains how we will collect, store, use and share your personal information. We collect information in a number of ways including when you use our website, submit an application form or provide information to us by post, email or phone.
Who we areH.J. Roelofs (UK) Limited trading as Bordengate Insurance, BGi.uk, Omar Insurance and Elwell and Co. We are authorised and regulated by the Financial Conduct Authority (FCA). Our Financial Services Register number is 307129 and our Company Registration number is 3464365.
What information do we collect about you?We will only ask you for information that we need, and we have strict controls to keep it safe. We collect your personal information to provide products and services to you. Whilst there are a number of ways in which we collect your personal information, the two main ways that we might collect personal information about you are from the things you tell us about yourself and from things we ask other people or organisations to share with us. We collect personal information directly from you:
- via enquiry, registration and claim forms;
- when you purchase any of our products or services;
- through quotes and applications forms ;
- via cookies. You can find out more about this in our Cookies Policy;
- via telephone calls with you, which may be recorded;
- when you provide your details to us either online or offline.
- directly from an individual who has a policy with us under which you are insured;
- from credit reference agencies who will supply us with information, including from the Electoral Register and credit information, Please note that the agencies may record details of the search whether or not your application proceeds;
- from social media where fraud is suspected; and
- via third parties including:
- your family members where you may be incapacitated or unable to provide information relevant to your policy; and
- medical professionals and hospitals.
- Personal Information
- Contact details such as name, email address, postal address and telephone number;
- Details of any other persons included and named on the policy and the relationship to you as the policyholder;
- Identification information such as your date of birth, national insurance number, passport and driving licence;
- Financial information such as bank details, credit card details and information obtained as a result of our credit checks;
- Information relevant to your insurance policy such as details about your property, previous policies or claims, recent damage;
- Information relevant to your claim or your involvement in the matter giving rise to a claim;
- Information about the nature of your business and commercial assets
- Details of bankruptcies and other financial sanctions such as HMRC investigations;
- Your marketing preferences.
- Sensitive personal information
- Details of your current or former physical or mental health;
- Details concerning sexual life or sexual orientation, for example marital status;
- Details regarding criminal offences, including alleged offences, criminal proceedings, outcomes and sentences (previous criminal convictions, bankruptcies and other financial sanctions such as County Court Judgements)
How we use and share your personal informationThe personal information we ask for will be used by us and third parties who process information on our behalf. This includes organisations who administer your policy, service your claims and reinsurers. Under data protection laws we need a reason to use and process your personal information and this is called a legal ground. When the personal information we process about you is classed as sensitive personal information we must have an additional legal ground for such processing, or where appropriate, we apply a specific exemption for Insurance purposes.
- Processing is necessary in order for us to provide your insurance policy and services, such as assessing your application and setting you up as a policy holder, administering and managing your insurance policy, providing all related services, providing a quote, dealing with claims and communicating with you. In these circumstances, if you do not provide such information, we will be unable to offer you a policy or process your claim.
- Where we have legal or regulatory obligation to use such personal information, for example, when our regulators the Financial Conduct Authority (FCA) and our data protection regulator, the Information Commissioner’s Office (ICO) wish us to maintain certain records of any dealings with you.
- Where we need to use your personal information to establish, exercise or defend our legal rights, for example, when we are faced with any legal claims or where we want to pursue any legal claims ourselves.
- Where we need to use your personal information for reasons of substantial public interest, such as investigating fraudulent claims and carrying out fraud, credit and anti-money laundering checks.
- Where we have a specific legal exemption to process sensitive personal data for insurance purposes. This exemption applies where we need to process information as an essential part of the insurance cover.
- Where you have provided your consent to our use of your personal data. We will usually only ask for your consent in relation to processing your sensitive personal information or when providing marketing information to you (including information about other products and services). This will be made clear when you provide your personal information. If we ask for your consent we will explain why it is necessary. Without your consent in some circumstances, we may not be able to provide you with cover under the policy or handle claims or you may not be able to benefit from some of our services.
- Where you provide sensitive personal information about a third party we will ask you to confirm that the third party has provided his/her consent for you to act on their behalf.
- Where we have appropriate legitimate business need to use your personal information such as maintaining our business records, developing and improving our products and services, all whilst ensuring that such business need does not interfere with your rights and freedoms and does not cause you any harm.
- Where we need to use your sensitive personal information such as health data because it is necessary for your vital interests, this being a life or death matter.
Financial crime and Fraud PreventionThe personal information that we collect will be shared with crime prevention agencies who will use it to prevent financial crime and fraud and to verify your identity. If financial crime or fraud is detected, you could be refused certain products, services finance or employment. Where we suspect financial crime or fraud, we may cancel any policies you have with us, not be able to pay a claim or offer you the requested product or service. We may share relevant information with crime and fraud prevention agencies, law enforcement agencies and other relevant organisations.
How we use your information for Management Information purposesWe use your personal information to help us understand and monitor our performance. If you are a member of a group scheme, we may provide reports to the scheme holder on the performance of the scheme. The information we provide is anonymised which means that you cannot be identified from the information. We also look to see where there might be trends in geographical areas to ensure we are prepared in the event of adverse weather conditions, or where there is a high or even low tendency to claim to ensure we offer the best price or a different type of service.
How we use your information for analytical purposesWe may use your personal information for research and statistical analysis including research about the products and services we provide. Where possible we will anonymise such information. By analysing the information you provide we are able to improve our product’s to better suit our customer’s needs. Please note we will only ever market to you if you provide your explicit consent.
How we use your information to administer your insurance policyWe use your personal information for the ongoing administration of your policy and of any claims you have. When you tell us about an incident or claim we will share this information with relevant agencies and appropriate service providers. We will also collect information from anyone else involved as necessary such as claimant, witnesses or police.
Who we share your personal information with
Disclosures to third parties
- Your relatives or guardians (on your behalf where you are incapacitated or unable) or other people or organisations associated with you such as your insurance broker or your lawyer.
- Our insurance partners such as other brokers, insurers, reinsurers or other companies who act as insurance distributors.
- Other third parties who assist in the administration of insurance policies such as insurance companies if there has been an incident which requires a claim to or from that insurance company.
- We may share the personal information of any persons named on the policy with third parties to obtain information which may be used by insurers to inform its risk selection, pricing and underwriting decisions.
- Fraud detection agencies and other third parties who operate and maintain fraud detection registers.
- The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
- Our third party service providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies.
- Other suppliers, providers of goods and services associated with your insurance and/or to enable us to deal with any claims you make.
- Financial organisations and advisers
- Central Government
- The Financial Ombudsman and regulatory authorities such as the Financial Conduct Authority and the Information Commissioner’s Office
- Loss Adjusters, claim handlers, etc.
- Debt collection agencies
- Credit reference agencies
- Selected third parties in connection with the sale, transfer or disposal of our business.
We may also disclose your personal information to other third parties where:
- We are required or permitted to do so by law or by regulatory bodies such as where there is a court order, statutory obligation or Financial Conduct Authority or Information Commissioner’s Office request; or
- We believe that such disclosure is necessary in order to assist in the prevention or detection of any criminal action (including fraud) or is otherwise in the overriding public interest.
How long we keep records forIn most cases, we only keep your personal information for as long as the regulations say we have to. This is usually between three and ten years after our relationship with you ends but it will vary depending on what data we hold, why we hold it and what we are obliged to so by the regulator or the law. Personal data that is collected and subsequently never used for any business purpose will be reviewed and may be destroyed at our own discretion.
Your RightsYou have the following rights in relation to our use of your personal information.
Right to access your personal information:
You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing, unless otherwise requested or where you have made the request by electronic means, in which case the information will be provided to you by electronic means where possible.
Right to rectification:
We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us by using the details shown in your documentation and you can ask us to update or amend it.
Right to erasure:
In certain circumstances, you have the right to ask us to erase your personal information, for example where the information we collected is no longer necessary for the original purpose or where you withdraw your consent. However, this will need to be balanced against other factors, for example according to the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.
Right to restriction of processing:
In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you think that the personal information we hold about you might be inaccurate or where you think that we no longer need to process your personal information.
Right to data portability:
In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice. Once transferred, the other party will be responsible for looking after your personal information.
Right to object to direct marketing:
You can ask us to stop sending you marketing messages at any time. Please see Marketing section below for more information.
Right to withdraw consent:
For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw consent to further use of your personal information. Please note in some cases we may not be able to process your insurance if you withdraw your consent.
Right to lodge a complaint:
You have a right to complain to the ICO at any time if you object to the way in which we use your personal information. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/You can make any of the requests set out above using the contact details provided to you in your policy document. Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make and if we are unable to comply with your request, we will tell you why. In some circumstances exercising some of these rights will mean that we are unable to continue providing you with cover under your insurance policy and may therefore result in the cancellation of the policy. You will therefore lose the right to bring any claim or receive any benefit under the policy, including in relation to any event that occurred before you exercised your right, if our ability to handle the claim has been prejudiced. Your policy terms and conditions set out what will happen in the event that your policy is cancelled.
MarketingYou are in control of how we use your personal information for marketing. We will only contact you if you have agreed it is okay. Then we might use your personal information to tell you about products and services that could be of interest to you. You can always change your mind by contacting us using the details shown in your policy document and telling us you no longer wish to be contacted. We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you wish to unsubscribe from emails sent by us, you may do so at any time by following the unsubscribe instructions that appear in all emails. Otherwise you can always contact us using the details set out in your policy document to update your contact preferences. We would like to keep you informed, from time to time, about relevant products and services. We may do this by mail, email, telephone or other electronic methods such as text message. From time to time we may run specific marketing campaigns through social media and/or digital advertising that you may see which are based on general demographics and interests. Individual personal information is not used for these campaigns. If you do not want to see any campaigns then you will need to adjust your preferences within social media settings and your cookie browser settings. Please note that we may retain any data provided to us on our websites for a limited period, even if you do not complete your quote. The information may be used to enquire as to why you did not complete your quote or for us to better understand your needs but only if you have agreed for us to contact you.
Contact DetailsBordengate Insurance, BGi.uk, Omar Insurance and Elwell and Co are trading styles of H.J. Roelofs (UK) Limited. We are authorised and regulated by the Financial Conduct Authority (FCA). Our Financial Services Register number is 307129 and our Company Registration number is 3464365.
If you wish to deal directly with BGi.uk then you can contact our head office:
The Office Manager
If you would like to contact the UK’s Information Commissioner’s Office directly please write to:
The Information Commissioner’s Office
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number