OBF

OBF INSURANCE GROUP LTD. DATA PRIVACY NOTICE

1. General
   

This document provides details of how we will use and protect the personal data we receive and hold.

References to “OBF”, “we”, “our” and “us” mean OBF Insurance Group Ltd. and any associated companies from time to time.

It is important that you read this document and show it to anyone else who is insured under your policy of insurance, including any named drivers and anyone living at the property insured under your policy, as it also applies to them.

Please make sure that anyone else who is insured under your policy has provided you with consent to provide their personal data to us.

We reserve the right to amend this Data Privacy Notice from time to time at our sole discretion. We encourage you to periodically review the most up-to-date version on our website, www.obf.ie or by requesting a copy from us.

Queries and Complaints

 If you are unhappy with the way we have handled your personal data or if you want further information about the way your personal data will be used, please contact us by any of the following methods:

• In writing to Data Protection, OBF Insurance Group Ltd., Bridge House, Baggot Street Bridge, Dublin 4
• By phoning us on +353 (0)1 6601033
• By email to dataprotection@obf.ie

Alternatively, you have the right to lodge a complaint with the Data Protection Commissioner, whose contact details are:

• Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois
• Telephone : +353 (0)761 104 8000 or +353 (0)57 868 4800
• LoCall : 1890 252 231
• Fax : +353 (0)57 868 4757
• Email : info@dataprotection.ie.

 

2. Collection

In order to gather personal data about you (and, if applicable, other people insured under your policy of insurance), we may obtain personal data from various parties including you, your representatives (if applicable), other insurance companies, third parties involved in an accident which may result in a claim including but not limited to claimants, witnesses, solicitors and claims specialist service providers and from searches (on line or off line) including searches of industry databases such as InsuranceLink – for details of InsuranceLink, please visit their website www.inslink.ie.

Please do not send us the results of any genetic tests carried out on you or any other person.

 

3. Use of Information

We mainly use your personal information so that we can provide a quote for insurance, set up, administer and manage your policy(ies). However, more specifically, we may use the personal data we gather for any of the following purposes:

1. To verify your (or your representative’s) identity
2. To verify the accuracy of the information we receive
3. To assess your insurance needs and the nature and level of the risk associated with your proposed insurance policy
4. To make or receive payments
5. To manage and administer your policy
6. To manage and investigate claims
7. For statistical analysis and the review or improvement of our products, services and procedures
8. To carry out market research
9. For marketing purposes
10. For staff training, performance reviews and disciplinary action
11. For the detection and prevention of fraud, money laundering and other offences and to assist the Gardai
12. To manage and investigate any complaint
13. To store and make back-ups of data
14. To comply with all relevant laws and regulatory requirements.

 

4. Legal Basis for Processing Personal Data

The legal bases we rely on for using your personal data for the above purposes are as follows:

• The processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (including providing a quote which is not taken up) or
• The processing is necessary for compliance with a legal or regulatory obligation to which we are subject or
• You have given your consent to the processing of your personal data for one of more specific purposes

 

Effect of not providing information

If you choose not to provide us with information which we need, we may not be able to offer you a quote or a policy or we may not be able to process and administer an existing policy. This could impact on the cover provided  by the policy and could mean that the cover is no longer in place.

 

5. Sharing of Information

In the course of providing our services to you, we may share your personal data with various third parties including:

• Your representatives, such as a relative, another person insured under your policy or your lawyers
• Our representatives such as our employees, agents and companies that we rely on to provide various services including telecommunications, data storage, document destruction, fraud detection, claims administration and management and IT services.
• Other third parties such as our Lloyd’s brokers, underwriters, external advisors and auditors and anti-fraud bodies including anti-fraud databases.
• State or government departments, bodies, agencies and regulatory authorities.

 

6. International Transfers

On occasion, we or a service provider may transmit certain aspects of your personal data outside the European Economic Area.

We comply with the law regarding international transfers of data by relying on the European Commission’s standard data protection regulations or the decisions of the European Commission regarding the provision by certain countries, for example Switzerland, of adequate levels of data protection by their laws.

 

7. Data Collected

As brokers and underwriters, we need to collect many types of personal data about you and other parties. The following category headings and types of data are a non-exhaustive list of the data we collect, process and store. All of the following types of data are required for the purposes set out in Section 3 “Use of Information”.

 

Types of Data Collected

Category	Type of Data Collected
Policy Information	Name , Date of birth, Gender ,Marital status, Home address ,Business address ,Country of birth ,Country of residence, Phone number(s), Email address, PPS number, Income details, Financial information, Health information and history (including smoking and drinking habits), Doctor’s name and address ,Occupation, Travel history and plans, Family health history, Number of dependants, Ages of dependants ,Vehicle and property details, Driving licence details, Passport details, Bank account details, Driving and claims history, Penalty points held, Convictions, Insured Property Security Details, Qualifications, Insured Property Address, Credit/Debit Card details (they are recorded on phone),Claims Information, Association Membership details, Personal Belongings details, CV, Sub –consultant or sub-contractor’s name, Sub –consultant or sub-contractor’s address, Business contracts , Bankruptcy and/or liquidation details ,Business partners and associates , Employees’ names, etc.
Information obtained from sources other than you	Penalty points, Address look up, Geocoding information, Vehicle details and history, Credit ratings, Sanction Searches, Company Registration Office information etc.

 

We do not collect all types of data in every case.

 

8. Retention of Data

Generally, we retain personal data for the following periods:

Type of Information	Retention Period
Quote Information (where a policy is not taken out and you have no other relationship with OBF)	12 months
Quote Information (where a policy is not taken out and you have a relationship with OBF)	For the duration of the existence of the live policy and 6 years after
Quote information (where you already have policies with us)	For the duration of the existence of the live policy and 6 years after.
Claims Information	The life of the policy, plus 6 years
Live Policy/Policies	We retain personal data for the duration of our business relationship with you and for six years  after it ends.

 

9. Automated Decision-making

We use automated decision-making on our website, www.obf.ie, in order to produce indicative quotes for certain lines of business. No underwriting or acceptance decisions are made purely on the basis of automated decision-making.

 

10. Your Rights

As a “data subject”, you have the rights set out in this section.

• Right to Withdraw Consent : If we are processing your personal data on the legal basis of consent, you are entitled to withdraw your consent at any time.

• Right of Access : You have the right to be given details about the personal data concerning you that we hold and about how and why we hold and process that data. You also have the right to obtain a copy of the personal data we hold about you. To obtain the data we hold about you, you should complete and send to us a Subject Access Request Form available on our website or by requesting one from our office. There is no fee for a data access request unless the request is unjustified or excessive.

 

If we refuse your request, you are entitled to make a complaint to the Data Protection Commissioner (contact details are in Section 1 “General”).

• Right of Rectification : You have the right to require us to correct any inaccuracies or omissions in the information we hold about you. We welcome any information regarding inaccuracies and, in certain cases, it is required under the terms of your policy of insurance.
• Right of Erasure / Right to be Forgotten : In certain circumstances you have the right to have the personal data we hold about you erased. You may only request the deletion of your personal data in specific situations. You should note that the erasure or deletion of your data would compromise our ability to process your insurance policy(ies) and could result in cover being withdrawn or cancelled.
• Right not to be subject to Automated Decision-making or Profiling : Currently, we do not make any decisions based purely on automated decision-making, nor do we carry our profiling.
• Right to Data Portability : You have the right to receive from us the personal data you have provided to us. You may also request that we send this personal data to another data controller, for example another broker or insurer.
• Right to Restrict Processing of your Data : You have the right to restrict us from processing your personal data where you feel it is inaccurate, that we are processing it unlawfully or that we no longer require it.

 

Version 1 (May 2018)