CLIVERTON PRIVACY POLICY
This Privacy Policy applies to Cliverton which is a trading name of Lycett, Browne-Swinburne & Douglass Limited (a subsidiary of Benefact Group plc. Reg. No. 24869), who are the data controllers as defined by the Data Protection Act 2018.
Cliverton is committed to the privacy and confidentiality of information that you provide to us. This privacy notice describes our current policies and practices regarding personal data collected and used by us. Please take your time to read this policy carefully. When using our website, this policy should be read alongside the website terms and conditions.
Lycetts is an insurance broking and financial services business with 16 offices around the UK. We are part of the Benefact group of companies. We specialise in farm and estate insurance but also provide bespoke financial services, personal lines, commercial and bloodstock advice.
We need to collect and process data so that we can arrange the insurance cover you have asked for, provide you with a quote, assist with any claims made under an insurance policy we have placed, provide the service you have requested, and where relevant, handle any complaints that might arise. This makes us a “data controller”.
If you are unsure about who the data controller of your personal data is, you can also contact us at any time by e-mailing us at privacy@lycetts.co.uk or by writing to the Compliance Manager at Lycetts, Bank House, Newcastle upon Tyne, NE1 6QF.
Insurance involves the use and disclosure of your personal data by various insurance market participants such as intermediaries, insurers, and reinsurers. The London Insurance Market Core Uses Information Notice which can be accessed at Data Protection (lmalloyds.com) sets out those core necessary personal data uses and disclosures. Our core uses and disclosures are consistent with the London Market Core Uses Information Notice. We recommend you review this notice.
Depending on our relationship with you, for example individuals and/or prospective customers/parties covered under an insurance policy we place, and the nature of services we are providing you with, such as broking services, risk management or financial advice we will collect different types of personal data about you and use it for different purposes.
From time to time we may ask you to provide or we may receive your “sensitive personal data” otherwise known in data protection laws as “special categories of personal data” (which is information relating to your health, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership). For example, where we arrange travel insurance for you, we may need information about your pre-existing health conditions. In these circumstances we would use your special category data to provide a quote and arrange the placing of your insurance and to assist with any claims you make. We may also need details of any unspent criminal convictions you have for fraud prevention purposes.
Where you provide personal data to us about other individuals (for example members of your household or other persons to be named on your insurance policy) we will also be data controller of and responsible for their personal data. You should refer them to this notice.
We have structured this notice so that you only need to click on the section below that is relevant to you and reflects your relationship with us.
Prospective policyholder or beneficiary under an insurance policy we may be placing
Policyholder or beneficiary under an insurance policy we have placed
Insurers, reinsurers, and other business partners
Users of the Cliverton website
We may use your personal data to provide you with information about our services which may be of interest to you where you are an existing client or where you have provided your consent for us to do so.
We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you no longer wish to receive information from us and want to be removed from our standard mailing list you can “unsubscribe” by clicking the link that appears in all marketing emails, or by contacting us using the details set out in section 10. Please note that by stopping these communications you may not hear about a new product or services such as a new policy or additions to our insurance that may save you money.
Please note that, even if you opt out of receiving marketing messages, we may still send you communications which are relevant to the type of services we provide you with.
Lycetts do not employ automated decision-making. We may input your personal data into systems owned by Insurers which make some decisions automatically, and the decision is reached using certain processes and algorithms, rather than an Insurer employee making the decisions themselves. This is called ‘automated decision-making’.
We use your personal data, for example name, address, property detail, to obtain quotations and apply for cover on your behalf.
You have a right not to be subject to the automated decision-making described above and you can contact us, using the details set out in section 10, to request details, to ask that any declined decision is reconsidered by the Insurer concerned. If you want to opt out of automatic decision-making, let us know, although in some circumstances it may mean we cannot place your insurance policy or offer you a quote or as some automated decisions are necessary to place your insurance policy.
We will only keep your personal data for as long as reasonably necessary to fulfil the purposes set out in section 3 above and to meet our legal and regulatory obligations. This will vary according to the type of policy we have arranged for you, or the service we have provided you with. After the end of the policy period or service contract we retain data only as long as is necessary in order to fulfil our legal obligations, as required by various bodies such as HMRC and our regulator (the FCA) and to be able to deal with potential future enquiries such as handling a claim or dealing with a complaint.
For example, we keep property claim files for at least 6 years, and where long-term liability claims may arise, we keep policy information for at least 80 years.
If you would like further information about how long we will keep your personal data for, please contact us using the details set out in section 10.
There may be some instances where your personal data is transferred to countries outside of the United Kingdom, such as when we transfer information to our other companies in the Benefact group; to third party suppliers; or when third parties who act on our behalf transfer your personal data to other countries. Where such a transfer takes place we will take the appropriate safeguarding measures to ensure that your personal data is adequately protected. We will do so in a number of ways, including:
We are also entitled under data protection laws to transfer your personal data to countries outside the UK where it is necessary for the performance of the contract we have with you. A summary of our regular data transfers outside the UK is set out below:
If you would like further information regarding our data transfers and the steps we take to safeguard your personal data, please contact us using the details set out in section 10.
We strive to maintain the reliability, accuracy, completeness, and currency of Personal Data in our databases and to protect the privacy and security of our databases. The security measures in place on our website and computer systems aim to prevent the loss, misuse, or alteration of the information you provide to us. We keep your Personal Data only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or regulatory requirements, or our data retention policy.
You have several data protection rights which entitle you to request information about your personal data, to dictate what we do with it or to stop us using it in certain ways.
If you wish to exercise the rights set out below, please contact us at any time using the details set out in section 10. There will not normally be a charge for this.
We respect your rights in relation to personal data we hold about you, however we cannot always comply with your requests, for example:
In some circumstances, complying with your request may result in your insurance policy being cancelled or your claim being discontinued. Please refer to your policy terms and conditions which will explain what will happen in the event your insurance policy is cancelled.
However, we will always inform you why we cannot comply with your request.
The right to access your personal data
You can request a copy of the personal data we hold about you and certain details of how we use it.
Your personal data will normally be provided to you in writing unless you request otherwise or where you have made a request by electronic means such as email, we will supply such information in electronic form where possible.
The right to withdraw your consent
Where we rely on consent as the legal ground to use your personal data, you are entitled to withdraw that original consent.
Please note that for certain uses of your personal data, we may need your consent to place your policy. If you exercise this right and withdraw your consent, we may not be able to place your insurance policy or help you in the event you have a claim. We will inform you of these consequences when you withdraw your consent.
The right to rectification
We make reasonable efforts to keep your personal data up to date, complete and accurate. We encourage you to ensure that your personal data is accurate so please regularly let us know if you believe that the information we hold about you may be inaccurate or not complete. We will correct and amend any such personal data and notify any third-party recipients of necessary changes.
The right to restriction of processing
Subject to the circumstances in which you exercise this right, you can request that we stop using your personal data, such as where you believe that we no longer need to use your personal data.
The right to data portability
Subject to the circumstances in which you exercise this right, you can request that we port across personal data you have provided to us to a third party in a commonly used and machine-readable format.
The right to erasure
You can request that we delete your personal data. For example, where we no longer need your personal data for the original purpose we collected it for or where you have exercised your right to withdraw consent. Whilst we will assess every request, this request is subject to legal and regulatory requirements that we must comply with.
The right to object to direct marketing
You can request that we stop sending you marketing messages at any time by clicking on the “unsubscribe” button in any emails that we send to you or by contacting us using the details set out in section 10. Please note that even if you exercise this right because you do not want to receive marketing messages, we may still send you service-related communications where necessary.
Rights relating to automated decision-making
If you have been subject to an automated decision and do not agree with the outcome, you can contact us using the details set out in section 10 and ask us to review the decision.
The right to make a complaint with the ICO
Where you believe that we have breached data protection laws when using your personal data, you can complain to the Information Commissioner’s Office (ICO). For more information visit the ICO’s website at https://ico.org.uk/. Please note that exercising this right and lodging a complaint will not affect any other legal rights or remedies that you have.
If you would like further information about the ways we use your personal data, further clarity on how we use your personal data or anything referred to in this notice, please contact our Compliance Manager at privacy@lycetts.co.uk or by writing to Compliance Manager at Lycetts, Bank House, Pilgrim Street, Newcastle upon Tyne, NE1 6QF.
We are continually improving our methods of communication and alongside with changes in the law and the changing nature of technology, our data practices and how we use your data will change from time to time. If our data practices change, we will notify you and we will provide you with the most up-to-date notice. You can view it by checking our website http://www.lycetts.co.uk/.
This notice was last updated on 31st July 2023
