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Policy Link’s UK-based Call Centre

“If you’re currently looking for Car, Van, Bike, Motor trader, Home or other General Insurance we can provide you with access to many excellent insurance brands to get you some great insurance quotes. We can do this over the phone via Policy Link’s UK-based call centre, using our specialist software system we aim to find the best quotes for you.”

Address

Policy Link
1C Hylton Park
Sunderland
SR5 3HD

Telephone

0330 054 0477

E-mail

enquiries@policylink.co.uk

Policylink logo large

Privacy Policy

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Welcome to Policy Link Limited’s (“Policy Link”) privacy notice.

Policy Link respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website www.policylink.co.uk (regardless of where you visit it from) (the Site”) or use our services. The privacy notice will also tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. We will also provide a hard copy of the privacy notice where appropriate. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1.IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Policy Link collects and processes your personal data through your use of the Site or our services, including any data you may provide when you sign up to our newsletter, purchase a product or service or take part in a competition.

This Site is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notice and is not intended to override them.

CONTROLLER

Policy Link Limited (a company registered in England and Wales under company number 10008299) is the controller and responsible for your personal data (collectively referred to as “Policy link”, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Policy Link Limited

Name: Ethan Lowery, Director

Email address: ethan@policylink.co.uk

Postal address: Policy Link, 1C Hylton Park, Sunderland, SR5 3HD

Telephone number: 0330 054 0477

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. Updates of this policy will be published on our website. Any questions, comments or requests concerning this policy should be sent to ethan@policylink.co.uk.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Site, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

    IF YOU FAIL TO PROVIDE PERSONAL DATA
    Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

    3. HOW IS YOUR PERSONAL DATA COLLECTED?

    We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
  • Automated technologies or interactions. As you interact with the Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as brokers based inside the EU.
  • Identity and Contact Data from data brokers or aggregators such as referral companies based inside the EU.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
  • 4. HOW WE USE YOUR PERSONAL DATA

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    To assist in providing you with quotes for insurance as requested by you.

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Please refer to the Glossary at section 11 to find out more about the types of lawful basis that we will rely on to process your personal data.

    PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Purpose/Activity  Type of data  Lawful basis for processing including basis of legitimate interest  Retention Period
    To register you as a new customer (a) Identity
    (b) Contact
    Performance of a contract with you 6 Years
    To process and deliver our services including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us (a) Identity
    (b) Contact
    (c) Financial
    (d) Transaction
    (e) Marketing and Communications

    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests (to recover debts due to us)
    6 Years
    To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey (a) Identity
    (b) Contact
    (c) Profile
    (d) Marketing and Communications
    (a) Performance of a contract with you
    (b) Necessary to comply with a legal obligation
    (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

    6 Years
    To enable you to partake in a prize draw, competition or complete a survey (a) Identity
    (b) Contact
    (c) Profile
    (d) Usage(e) Marketing and Communications
    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
    6 Years
    To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
    (b) Contact
    (c) Technical
    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
    (b) Necessary to comply with a legal obligation
    6 Years
    To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing and Communications
    (f) Technical
    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) 6 Years
    To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
    (b) Usage
    Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Site updated and relevant, to develop our business and to inform our marketing strategy) 6 Years
    To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
    (b) Contact
    (c) Technical
    (d) Usage
    (e) Profile
    Necessary for our legitimate interests (to develop our products/services and grow our business) 6 Years

    Marketing / Renewal Reminders

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

    Policy Link may contact you via email and/or SMS to remind you about your upcoming renewal around the anniversary of when you last completed a quote form on our website, this will give you the opportunity to receive quotes again from our panel. If you would prefer not to be contacted for this purpose then please email ethan@policylink.co.uk

    THIRD-PARTY MARKETING
    With your consent we may also share your personal data within our group of businesses to offer you products and services that may be of interest to you.
    We will also get your express opt-in consent before we share your personal data with any company outside of the IRevolution group of companies for marketing purposes.

    OPTING OUT

    You can ask us or third parties to stop sending you marketing messages at any time by contacting us at email and/or address provided in this privacy notice any time.

    Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

    COOKIES

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy

    CHANGE OF PURPOSE

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the email or postal address provided in this privacy notice.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

    5. DISCLOSURES OF YOUR PERSONAL DATA

    We may have to share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

    6. INTERNATIONAL TRANSFERS

    We share your personal data within the Policy link Group. This may involve transferring your data outside the European Economic Area (EEA).

    Some of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
  • Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

    7. DATA SECURITY

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

    8. DATA RETENTION

    HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

    Details of retention periods for different aspects of your personal data are set out in the table above.

    We may retain your basic information for longer periods if so required by law.

    In some circumstances you can ask us to delete your data: see Request erasure below for further information.

    In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

    9. YOUR LEGAL RIGHTS

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. Including the right to:

    • Request access to your personal data.
    • Request correction of your personal data.
    • Request erasure of your personal data.
    • Object to processing of your personal data.
    • Request restriction of processing your personal data.
    • Request transfer of your personal data.
    • Right to withdraw consent.

    If you wish to exercise any of the rights set out above, please contact us

    NO FEE USUALLY REQUIRED

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    WHAT WE MAY NEED FROM YOU

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    TIME LIMIT TO RESPOND

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    10. GLOSSARY

    LAWFUL BASIS

    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

    THIRD PARTIES

    INTERNAL THIRD PARTIES

    Other companies in the Policy Link Group acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.

    EXTERNAL THIRD PARTIES

  • Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • YOUR LEGAL RIGHTS

    You have the right to:

    Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    Cookie Policy

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    As almost all websites do, this website uses a limited number of cookies to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

    How we use cookies:

  • Improve the speed/security of the site.
  • Make our website function correctly.
  • Anonymously track the use of the website pages
  • We do not use cookies to:

  • Collect any personally identifiable information.
  • Collect any sensitive information.
  • Pass personally identifiable data to any third parties.
  • Pass data to advertising or affiliate networks.
  • Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

  • Chrome
  • Firefox
  • Opera
  • Internet Explorer
  • Safari
  • Edge
  • If you wish to withdraw your consent at any time, you will need to delete your cookies using your internet browser settings (see section 1.1 Managing and Disabling Cookies).

    By continuing to use our website, you are agreeing to our placing cookies on your computer in order to analyse the way you use our website. Please read this cookie statement (section 1.0, section 1.1 and section 1.2) carefully for more details about the cookie information we collect when you use this site.

    If you do not wish to accept cookies in connection with your use of this website, you must either stop using our site or turn off your cookies in your web browser (see section 1.1).

    GDPR Policy

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    GENERAL DATA PROTECTION REGULATION POLICY

    Introduction
    This Policy sets out the obligations of Policy Link (the Company”) regarding data protection and the rights of customers, employees and business contacts (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

    The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

    This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

    The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

    1. The Data Protection Principles
    This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:

    1. Processed lawfully, fairly, and in a transparent manner in relation to the data subject.

    2. Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.

    3. Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

    4. Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.

    5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.

    6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

    2. The Rights of Data Subjects
    The GDPR sets out the following rights applicable to data subjects:

    1. The right to be informed

    2. The right of access

    3. The right to rectification

    4. The right to erasure (also known as the ‘right to be forgotten’)

    5. The right to restrict processing

    6. The right to data portability

    7 The right to object

    8 Rights with respect to automated decision-making and profiling

    3. Lawful, Fair, and Transparent Data Processing
    The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:

    1. The data subject has given consent to the processing of their personal data for one or more specific purposes;

    2. The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;

    3. The processing is necessary for compliance with a legal obligation to which the data controller is subject;

    4. The processing is necessary to protect the vital interests of the data subject or of another natural person;

    5. The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or

    6. The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

    If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:

    1. The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);

    2. The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);

    3. The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

    4. The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;

    5. The processing relates to personal data which is clearly made public by the data subject;

    6. The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;

    7. The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;

    8. The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;

    9. The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or

    10. The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

    4.Specified, Explicit, and Legitimate Purposes
    The Company collects and processes the personal data, this includes:

    1. Personal data obtained from third parties

    The Company only collects, processes, and holds personal data for the specific purpose of providing insurance policies (or for other purposes expressly permitted by the GDPR).
    Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data.

    5. Adequate, Relevant, and Limited Data Processing
    The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as above.

    6. Accuracy of Data and Keeping Data Up-to-Date
    The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject.

    The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

    7. Data Retention
    The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.
    When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

    For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

    8. Secure Processing
    The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage.

    9. Accountability and Record-Keeping
    The Company’s Director is Ethan Lowery.

    The Director shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the GDPR and other applicable data protection legislation.

    The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

    1. The name and details of the Company, its Directors, and any applicable third-party data processors;

    2. The purposes for which the Company collects, holds, and processes personal data;

    3. Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;

    4. Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;

    5. Details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy); and

    6. Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

    10. Data Protection Impact Assessments
    The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data [which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR].

    Data Protection Impact Assessments shall be overseen by the Director and shall address the following:

    1. The type(s) of personal data that will be collected, held, and processed;

    2. The purpose(s) for which personal data is to be used;

    3. The Company’s objectives;

    4. How personal data is to be used;

    5. The parties (internal and/or external) who are to be consulted;

    6. The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;

    7. Risks posed to data subjects;

    8. Risks posed both within and to the Company; and

    9. Proposed measures to minimise and handle identified risks.

    11. Data Subject Access
    Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.

    1. Employees wishing to make a SAR should do using a Subject Access Request Form, sending the form to the Company’s Director at ethan@policylink.co.uk

    2. Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.

    3. All SARs received shall be handled by the Company’s Director.

    4. The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

    12. Rectification of Personal Data
    Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

    The Company shall rectify the personal data in question, providing adequate proof is provided if required, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

    In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

    13. Erasure of Personal Data
    Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

    1. It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;

    2. The data subject wishes to withdraw their consent to the Company holding and processing their personal data;

    3. The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so)

    4. The personal data has been processed unlawfully;

    5. The personal data needs to be erased in order for the Company to comply with a particular legal obligation.

    Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

    In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

    14. Restriction of Personal Data Processing
    Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

    In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

    15. Data Portability
    The Company processes personal data using automated means. This is used to rate the individual risk based on a number of factors input into the system by the broker.

    Where data subjects have given their consent to the Company to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the right, under the GDPR, to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers).

    To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following format[s]:

    1. Secure Email

    a. Table showing all data held and where it has been submitted;

    b. Contact details of any third-party recipients;

    2. Special delivery Post

    Where technically feasible, if requested by a data subject, personal data shall be sent directly to the required data controller.

    All requests for copies of personal data shall be complied with within one month of the data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed.

    16. Objections to Personal Data Processing
    Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling),
    Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

    Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.

    17. Automated Decision-Making
    The Company uses personal data in automated decision-making processes when using a third-party credit score provider.

    Where such decisions have a legal (or similarly significant effect) on data subjects, those data subjects have the right to challenge to such decisions under the GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.

    The right described above below does not apply in the following circumstances:

    1. The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject;

    2. The decision is authorised by law; or

    3. The data subject has given their explicit consent.

    18. Personal Data Collected, Held, and Processed
    The following personal data is collected, held, and processed by the Company (for details of data retention, please refer to the Company’s Data Retention Policy):

    Data Name Type of data Purpose of Data
    Full Name (proposer or named drivers) Personal Data Insurance contract purposes
    Date of birth (proposer or named drivers) Personal Data Insurance contract purposes
    Telephone number (proposer or named drivers) Personal Data Insurance contract purposes
    Email Address (No direct marketing carried out) Personal Data Insurance contract purposes
    Full address (proposer or named drivers) Personal Data Insurance contract purposes
    Type of driving licence (proposer or named drivers) Personal Data Insurance contract purposes
    Date passed driving test (proposer or named drivers) Personal Data Insurance contract purposes
    Number of years resident in the UK (proposer or named drivers) Personal Data Insurance contract purposes
    Marital status (proposer or named drivers) Personal Data Insurance contract purposes
    Occupation’s full time and part time (proposer or named drivers) Personal Data Insurance contract purposes
    Employers business full time and part time (proposer or named drivers) Personal Data Insurance contract purposes
    Occupation type (proposer or named drivers) Personal Data Insurance contract purposes
    Relevant experience (proposer or named drivers) Personal Data Insurance contract purposes
    Relevant licencing authority specific to use including details of licence held (proposer or named drivers) Personal Data Insurance contract purposes
    Working postcode (proposer or named drivers) Personal Data Insurance contract purposes
    Number of no claims bonus (NCB) years, type declared, previous insurer and previous policy number Insurance contract purposes
    Policy holder excluded requirements Insurance contract purposes
    DSA test years passed Insurance contract purposes
    Conviction details (Via My Licence database if accessible) (proposer or named drivers) Personal Data Insurance contract purposes
    Any accidents/losses or incident details (proposer or named drivers) Personal Data Insurance contract purposes
    Vehicle Registration Mark (VRM) Personal Data Insurance contract purposes
    Vehicle Make, model, variant, number of seats, value, length of ownership, import details, modifications, alarm, tracker details Personal Data Insurance contract purposes
    Business Mileage Insurance contract purposes
    Use Of Vehicle/td> Personal Data Insurance contract purposes
    Where the vehicle is kept/td> Insurance contract purposes
    Vehicle owner and registered details/td> Personal Data Insurance contract purposes
    Vehicle lease/HP details/td> Personal Data Insurance contract purposes
    Vehicle kept at proposers address overnight? Personal Data Insurance contract purposes



    19. Data Security – Transferring Personal Data and Communications
    The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

    1. All emails containing personal data must be encrypted, when emailing through our main administration email facility this will be encrypted using Office 365 Message Encryption, all other documentation must be encrypted using PDFsam (256 bits AES encryption) other software can be used with the formal written approval of Ethan Lowery, Director, ethan@policylink.co.uk and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given;

    2. All emails containing personal data must be marked “confidential”;

    3. Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;

    4. Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;

    5. Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted, this will be done using Group Policy Object (GPO) for further information please refer to our Data Retention and Email retention policies;

    6. Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using a recorded delivery service; and

    7. All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.

    20. Data Security – Storage
    The Company shall ensure that the following measures are taken with respect to the storage of personal data:

    1. All electronic copies of personal data should be stored securely using passwords and data encryption, and using a relational database to hold records. This is to be replicated using an encrypted network storage device and replicated to a similar device over an encrypted VPN trunk between sites. Documents generated by our web application are to be stored on our application servers in a secure format;

    2. All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;

    3. All personal data stored electronically should be backed up daily with backups stored onsite and offsite. All backups should be encrypted using a Network Attached Storage device;

    4. No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of Ethan Lowery, Director, ethan@policylink.co.uk and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and

    5. No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

    21. Data Security – Disposal
    When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

    22. Data Security – Use of Personal Data
    The Company shall ensure that the following measures are taken with respect to the use of personal data:

    1. No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from Ethan Lowery, Director, available on: ethan@policylink.co.uk

    2. No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of Ethan Lowery, Director, available on: ethan@policylink.co.uk

    3. Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;

    4. If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and

    5. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Director to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

    23. Data Security – IT Security
    The Company shall ensure that the following measures are taken with respect to IT and information security:

    1. All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols;

    2. Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

    3. All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates as soon as reasonably and practically possible, unless there are valid technical reasons not to do so; and

    4. No software may be installed on any Company-owned computer or device without the prior written approval of the Systems Development Director.

    24. Organisational Measures
    The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

    1. All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;

    2. Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;

    3. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;

    4. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;

    5. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;

    6. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

    7. All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;

    8. The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;

    9. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;

    10. All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and

    11. Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

    25. Transferring Personal Data to a Country Outside the EEA
    The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
    The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:

    1. The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;

    2. The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;

    3. The transfer is made with the informed consent of the relevant data subject(s);

    4. The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);

    5. The transfer is necessary for important public interest reasons;

    6. The transfer is necessary for the conduct of legal claims;

    7. The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or

    8. The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

    26. Data Breach Notification
    All personal data breaches must be reported immediately to the Company’s Operations Director.

    If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Director must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

    In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under No.2 above) to the rights and freedoms of data subjects, the Director must ensure that all affected data subjects are informed of the breach directly and without undue delay.

    Data breach notifications shall include the following information:

    1. The categories and approximate number of data subjects concerned;

    2. The categories and approximate number of personal data records concerned;

    3. The name and contact details of the Company’s Director (or other contact point where more information can be obtained);

    4. The likely consequences of the breach;

    5. Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

    27. Implementation of Policy
    This Policy shall be deemed effective as of 12th September 2019. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

    The Approved Person responsible for compliance is responsible for monitoring the accuracy and security of data. All staff are advised of their Data Protection responsibilities.

    The person responsible for overseeing Data Protection is Ethan Lowery, Director.