This document provides a general overview of information security at The Insurance Surgery for existing and prospective customers.

Data Protection and GDPR

Here at The Insurance Surgery, we strictly comply with the requirements of the Data Protection Act (DPA) and the General Data Protection Regulation (GDPR) and we are registered on the public register of data controllers which is overseen by the Information Commissioner.

As data controller of the personal data that we collect either from individuals or advisers, we are required to comply with the requirements of the DPA, including that the data we hold is adequately protected, that it’s kept up to date and accurate and that we allow our customers to exercise their rights.

In order to achieve compliance with our obligations under the GDPR, we have policies, standards and guidance in place and ensure that the appropriate controls and safeguards are implemented to protect personal data.

Information Security Risk Management
(Key governance positions responsible for data security)

• Managing Director.
• Operations Manager/Data Protection Officer.
• Sales Manager.

We would also like you to know that The Insurance Surgery operates the three lines of defence approach personal data protection.

• All staff within The Insurance Surgery understand and work to the guides and regulatory factors surrounding GDPR and information security.
• The management team proactively monitor this working practice alongside performing checks and continuing to safeguard GDPR and information security directly and independently.
• An internal audit is performed quarterly reporting directly to the DPO.

Certifications

The Insurance Surgery is an Insurance broker authorised and regulated by the Financial Conduct Authority (FCA) and is a member of the Association of British Insurers (ABI) – The Insurance Surgery is also registered with the Information Commissioner’s Office (number Z8689672).

Our Privacy Policy

This privacy policy applies between you, the User of this Website, and The Insurance Surgery Ltd, the owner and provider
of this Website. The Insurance Surgery Ltd takes the privacy of your information very seriously. This privacy policy applies
to our use of any and all Data collected by us or provided by you in relation to your use of the Website.
This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: heinsurance-surgery.co.uk/the-insurance-surgery-terms-of-business/.

Please read this privacy policy carefully.

Definitions and interpretation
1. In this privacy policy, the following definitions are used:

• Data – collectively all information that you submit to The Insurance Surgery Ltd via the Website. This
  definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
• Cookies – a small text file placed on your computer by this Website when you visit certain parts of the Website and
  /or when you use certain features of the Website. Details of the cookies used by this Website are set out
  in the clause below (Cookies)
• Data Protection Laws – any applicable law relating to the processing of personal Data, including but not limited to the GDPR,
  and any national implementing and supplementary laws, regulations and secondary legislation.
• GDPR – the UK General Data Protection Regulation;
• The Insurance Surgery Ltd, we or us – The Insurance Surgery Ltd, a company incorporated in England and Wales with registered number
  401425 whose registered office is at 3rd Floor, Merchants Exchange, Waters Green, Cheshire, SK11
  6JX;
• UK and EU Cookie Law – the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the
  Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy
  and Electronic Communications (EC Directive) (Amendment) Regulations 2018.
• User or you – any third party that accesses the Website and is not either (i) employed by The Insurance Surgery Ltd
  and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing
  services to The Insurance Surgery Ltd and accessing the Website in connection with the provision of
  such services; and
• Website – the website that you are currently using, https://www.the-insurance-surgery.co.uk/, and any subdomains of this site unless expressly excluded by their own terms and conditions.

2. In this privacy policy, unless the context requires a different interpretation:

a. the singular includes the plural and vice versa;

b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of
this privacy policy;

c.  a reference to a person includes firms, companies, government entities, trusts and partnerships;

d. “including” is understood to mean “including without limitation”;

e. Reference to any statutory provision includes any modification or amendment of it;

f. the headings and sub-headings do not form part of this privacy policy

Scope of this privacy policy

3. This privacy policy applies only to the actions of The Insurance Surgery Ltd and Users with respect to this Website. It
does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may
provide to social media websites.

4. For purposes of the applicable Data Protection Laws, The Insurance Surgery Ltd is the “data controller”. This means
that The Insurance Surgery Ltd determines the purposes for which, and the manner in which, your Data is processed.

Data collected
5. We may collect the following Data, which includes personal Data, from you:
a. name;
b. date of birth;
c. contact Information such as email addresses and telephone numbers;
in each case, in accordance with this privacy policy.

 

How we collect Data
6. We collect Data in the following ways:
a. data is given to us by you; and
b. data is collected automatically.

Data that is given to us by you

7. The Insurance Surgery Ltd will collect your Data in a number of ways, for example:
a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
b. when you use our services;
in each case, in accordance with this privacy policy.

Data that is collected automatically

8. To the extent that you access the Website, we will collect your Data automatically, for example:

a. we automatically collect some information about your visit to the Website. This information helps us to make
improvements to Website content and navigation, and includes your IP address, the date, times and frequency with
which you access the Website and the way you use and interact with its content

b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more
information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

Our use of Data

9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible
service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

a. internal record keeping;

b. improvement of our products / services;

in each case, in accordance with this privacy policy.

10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are
not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights”
below).
11. We may use your Data to show you The Insurance Surgery Ltd adverts and other content on other websites. If you do
not want us to use your data to show you The Insurance Surgery Ltd adverts and other content on other websites, please
turn off the relevant cookies (please refer to the section headed “Cookies” below).

 

Who we share Data with

12. We may share your Data with the following groups of people for the following reasons:

a. our employees, agents and/or professional advisors – to provide recommendations relating to Insurance products;

b. third party service providers who provide services to us which require the processing of personal data – to enable
us to produce quotes for products recommended;
in each case, in accordance with this privacy policy.

Keeping Data secure

13. We will use technical and organisational measures to safeguard your Data, for example:

a. access to your account is controlled by a password and a user name that is unique to you.

b. we store your Data on secure servers.

14. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any
misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail
address: [email protected].

15. If you want detailed information from Get Safe Online on how to protect your information and your computers and
devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get
Safe Online is supported by HM Government and leading businesses

 

Data retention

16. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the
period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
17. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights
18. You have the following rights in relation to your Data:

a. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we
modify, update or delete such information. If we provide you with access to the information we hold about you,
we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally
permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.

c. Right to erase – the right to request that we delete or remove your Data from our systems.

d. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which
we can use it

e. Right to data portability – the right to request that we move, copy or transfer your Data.

f. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

19. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data
(where consent is our legal basis for processing your Data), please contact us via this e-mail address:
[email protected].
20. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able
to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s
Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
21. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes
during the period for which we hold it.

Links to other websites

22. This Website may, from time to time, provide links to other websites. We have no control over such websites and are
not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You
are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

23. The Insurance Surgery Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or
the transfer of control of all or part of The Insurance Surgery Ltd. Data provided by Users will, where it is relevant to
any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party
will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally
supplied to us.
24. We may also disclose Data to a prospective purchaser of our business or any part of it.
25. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies
26. This Website may place and access certain Cookies on your computer. The Insurance Surgery Ltd uses Cookies to
improve your experience of using the Website and to improve our range of services. The Insurance Surgery Ltd has
carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
27. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
28. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your
consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling The Insurance
Surgery Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of
Cookies; however certain features of the Website may not function fully or as intended.
29. This Website may place the following Cookies:

• Strictly necessary cookies – These are cookies that are required for the operation of
  our website. They include, for example, cookies that
  enable you to log into secure areas of our website, use a
  shopping cart or make use of e-billing services.
• Analytical/performance cookies – They allow us to recognise and count the number of
  visitors and to see how visitors move around our website
  when they are using it. This helps us to improve the way
  our website works, for example, by ensuring that users
  are finding what they are looking for easily.
• Functionality cookies – These are used to recognise you when you return to our
  website. This enables us to personalise our content for
  you, greet you by name and remember your preferences
  you, greet you by name and remember your preferences
  (for example, your choice of language or region). By
  using the Website, you agree to our placement of
  functionality cookie.
• Targeting cookies – These cookies record your visit to our website, the pages
  you have visited and the links you have followed. We
  will use this information to make our website and the
  advertising displayed on it more relevant to your
  interests. We may also share this information with third
  parties for this purpose.

 

30. You can find a list of Cookies that we use in the Cookies Schedule.
31. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept
Cookies but this can be changed. For further details, please see the help menu in your internet browser. You can switch
off Cookies at any time, however, you may lose any information that enables you to access the Website more quickly
and efficiently.
32. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the
Website more quickly and efficiently including, but not limited to, personalisation settings.
33. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance
provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
34. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will
also find details on how to delete cookies from your computer

General
35. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights
under this privacy policy where we reasonably believe your rights will not be affected.
36. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid,
illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the
validity and enforceability of the other provisions of this privacy policy will not be affected.
37. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a
waiver of that, or any other, right or remedy.
38. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising
under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Changes to this privacy policy
39. The Insurance Surgery Ltd reserves the right to change this privacy policy as we may deem necessary from time to
time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to
have accepted the terms of the privacy policy on your first use of the Website following the alterations.
You may contact The Insurance Surgery Ltd by email at [email protected].

Cookies
Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we
have missed a cookie or there is any discrepancy, please let us know.

Strictly necessary
We use the following strictly necessary cookies:

to remember your website session; the insurance surgery use this session cookie maintain website
functionality whilst you are using our website

Functionality
We use the following functionality cookies:

to ensure the proper functioning of
the website; We use functionality cookies to ensure the proper functioning of the website and
enhance your experience while using our website

Analytical/performance
We use the following analytical/performance cookies:

collect information about how you
the user, use our website and if you
run into any problems whilst using
our website; the use of Analytical/performance cookies collect information about how you the
user, use our website and if you run into any problems whilst using our website.
These cookies do not gather any information that identifies you. The Data is
anonymous and to simply help us on improving how the website work

Targeting
We use the following targeting cookies:

to show you adverts which are
relevant to us also to use in
retargeting campaigns; we use Targeting cookies to show you adverts which are relevant to us also to use in
retargeting campaigns. Targeting cookie collect user information and builds a profile
of users, actions and interests which helps us with marketing also putting personalised
ads for the specific user in front of them

Know your rights

You have the following rights in relation to our use of your personal information.

The 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.

The 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.

The right to erasure:

In certain circumstances, you have the right to ask us to erase your personal information, for example where the personal 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.

The 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 may be inaccurate or where you think that we no longer need to process your personal information.

The right to object to direct marketing:

You can ask us to stop sending you marketing messages at any time.

The 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/

Should you wish to discuss any of the above, please write to The Data Protection Officer at;

Data Protection Officer
Address: Merchant Exchange, Castle House, Waters Green, Macclesfield, SK11 6JX

Or email: [email protected]