This privacy notice of Blackmore Borley Limited (Company registration number 03317764) whose registered office and business address is at Boundary House, 7 – 17 Jewry Street, London, EC3N 2HP, covers our requirement to provide you with information on how we collect and process your personal data.


This privacy notice also provides certain information that is legally required and lists your rights in relation to your personal data.


A Little Background


The Data Protection Act controls how your personal information is used by organisations, businesses or the government.


Personal Information


Personal information identifies you as a natural person (whether you are an actual or potential customer of Blackmore Borley Limited or whether you browse our website or an individual outside of our organisation with whom we interact).
This privacy notice tells you what to expect when Blackmore Borley Limited collects personal information about you. Personal information may also be referred to as personal data.
Personal Information denotes:


Information you provide us with by filling in online questions via our website
Information that you provide us with over the telephone, via email or face to face
Information that you provide us with when completing a proposal form
Information you provide us with when enquiring about insurance, or when you purchase an insurance policy through us including information about who or what you want to insure such as vehicle details, business activities or your home or travel details
General information you provide us with about you – your name, address, contact details and date of birth
Your claims and credit history
Financial details, such as bank account and card details
Criminal convictions
Information about how you use your website such as your IP address, which is a unique number identifying your computer, including personal data gathered using cookies


By providing us with information about yourself, you are considered to be a Data Subject.


The Data Protection Principals


Personal Information denotes:


• Information you provide us with by filling in online questions via our website 
• Information that you provide us with over the telephone, via email or face to face


By providing us with information about yourself, you are considered to be a Data Subject.  


The Data Protection Principals
As we are responsible for gathering and using your personal information, we have to follow strict rules called the data protection principles. As such, we must make sure that your information is:


√ Used fairly and lawfully in a transparent manner
√ Used for explicit and legitimate grounds only
√ Used in a way that is adequate, relevant and not excessive
√ Accurate and kept up to date
√ Kept for no longer than is absolutely necessary
√ Handled according to your rights
√ Kept safe and secure
√ Not transferred outside of the United Kingdom without adequate protection


Who Is Responsible For Your Personal Information
Blackmore Borley Limited, as the Data Controller determines the purposes for which and the manner in which any personal data is, or is to be, processed.


Data Controllers must ensure that any processing of personal data for which they are responsible complies with the Act.


Why We Gather Personal Information About You
Blackmore Borley Limited provide a range of insurance products.  We process data provided by you (the Data Subject) and other sources in order to deliver the appropriate products and services to you.   


The reasons for processing your data is mainly to:
Provide you with a quotation for insurance
Arrange and administer your policy if you buy one through us
Arranging premium credit if required
Inform you about our other products and services
We do not collect more information than we need to meet our obligations to you and will not retain it for longer than is necessary.


Some of the personal information we ask you to provide us with may be sensitive (special category data). For example, we may need to know about any past offences that you may have.


 We are allowed by legislation to collect such information for insurance purposes without specific consent but it will only be used for the purposes we have set out above.  


We will only ever use your personal information for the purpose of progressing your application for insurance, administering your insurance policy, or fulfilling our legal or regulatory requirements such as fraud prevention, help preventing financial crime and audit purposes. 


If you provide us with information about another person, in doing so, you confirm that they have given you permission to provide it to us and that we may use their personal data in the same way as your own as set out in this Privacy Notice.


Legal Basis For Processing Your Personal Information
We are required to have a lawful basis in order to process your personal data and the relevant bases which apply:


Purpose of Processing
Providing quotations, arranging and administering insurance policies
Arranging Premium Credit
Provision of information on products and services
To notify you of changes to our service
To prevent and detect fraud, money laundering and other financial crimes
To meet general legal or regulatory obligations
Lawful Basis
Necessary for the performance of an insurance contract
Necessary for the performance of an insurance contract
Our legitimate interests or your explicit consent
Our legal and regulatory obligations
Our legal and regulatory obligations
Our legal and regulatory obligations
Who Do We Share Your Details With and Why


To meet our regulatory obligations and our obligations to you, we may therefore need to share your personal information with product and service providers such as insurers and underwriters, insurance industry databases, premium finance companies, regulatory authorities, the Police and other law enforcement bodies.


To provide you with other types of insurance such as Professional Indemnity, we may need to share your personal information with our associated company – Randell Dorling Limited but will only do so after gaining your consent.


To help provide you with more specialist types of insurance, we may need to share your personal information with one or more of our carefully selected external specialist providers.  This will be limited to your name and contact details.  Any such specialist provider is also required to abide by the rules of Data Protection and will have their own privacy notice which you will be provided with / given access to.


Automated Decision Making And Profiling


In using our online Quote and Buy system, we carry out automated decision making to decide whether we can provide insurance to you.


This may be classed as ‘profiling’ under the current legislation.


We are required to have safeguards in the event that this may have a legal or significant effect on individuals.  We do not consider that our Quote and Buy systems poses such risks but you are able to request further information should you wish.


Data Retention


The type of insurance we arrange for you dictates the amount of time we retain your personal information for.  For the majority of insurance products, we retain records for a period of 7 years after your insurance contract with us expires.  


Marketing
If you are an existing customer, we may contact you by email, text, telephone, mail or by other agreed means to keep you up to date about our products or services.  In other circumstances, we can only do so with your explicit consent.  


In either case, you are able to opt out of receiving such communications at any time.


Security
We are committed to protecting the security and privacy of all personal information which we obtain and hold about you.  
We employ appropriate technical security measures to protect your personal information and ensure that it is not accessed by unauthorised persons.  Information is stored on secure computers, in a locked information centre, and information is encrypted wherever possible.
Blackmore Borley Limited use a third party service, Eagle View Digital Solutions Limited to help maintain the security and performance of our website. To deliver this service it processes the IP addresses of visitors to our website.


Cookies In General
Cookies are small text files that are placed on your computer by websites that you visit.  They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website.  


The cookie is sent back and forth between a web browser and the server it accesses. The information a cookie contains and its purpose is determined by the website operator and can be used by the web server every time you visit that site.


Cookies are used to save time and make visiting web sites more efficient, to record site usage and remember information input on forms and pass information from page to page during a single user’s website session.


They can be used for many different reasons – from remembering login information and what is in your online shopping basket and in respect of online adverts so you see more adverts suited to what you want.


Cookies At Blackmore Borley Limited


We use cookies for statistical and functionality purposes only, we track how many individual unique users we receive and the frequency they visit our website.


The information tells us which of our pages are most frequently visited and by which types of users and from which countries. This allows us to see which content is more popular than others. We use Google Analytics to do this.


The information that we collect from cookies is anonymous and does not identify people or collect personal data about website visits.


We don’t sell the information collected by cookies, nor do we disclose the information to third parties, except to our associated companies and where required by law (for example to government bodies and law enforcement agencies).


How Can You Manage Your Cookies?
You can manage how your computer/internet device manages cookies through your browser settings.


Most browsers can be altered to prevent your computer from accepting cookies. This may result in some of the features of this site and other sites not working properly and may restrict your user experience.


If you don’t want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether.


Your can modify your browser settings through the menu, generally found under ‘options’ or ‘preferences’.


The following links may be helpful, otherwise you should use the ‘Help’ option in your browser for more details.


How To Manage Your Cookie Settings In:
Internet Explorer 
Firefox 
Chrome
Safari


There is lots of guidance available explaining what cookies are and what they can do.


More Information about Cookies


More information to help you find out more about cookies can be found on the following links: –
http://www.allaboutcookies.org 
http://www.youronlinechoices.eu 
http://www.international-chamber.co.uk/our-expertise/digitaleconomy


Conditions of Use
By continuing to use the site you agree to the use of cookies. Acceptance of these cookies is a condition of using the Blackmore Borley Limited website and if these cookies are restricted or refused in any way we can offer no guarantee that the site will function properly for you.


Where Your Information Is Stored
Information which you provide us with is stored on a computer located in the European Economic Area (EEA). This is necessary in order to process the information and to send you any information you have requested. In addition, if you use our Services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those Services.


If You Send Us An Email
Any email you send to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy.  Email monitoring or blocking software may also be used.  Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.


If You Make A Complaint to Us
If we receive a complaint, we make up a file containing the details of the complaint.  The file is likely to contain the identity of the complainant and any other individuals involved in the complaint.  


We will only use the personal information we collect to investigate and process the complaint.


We usually have to disclose the complainant’s identity to whomever the complaint is about.  This is inevitable where, for example, the accuracy of a person’s record is in dispute.


We also usually have to disclose details of the complaint to our professional Indemnity Insurance Broker and Insurer.


We may also be required to provide a copy of the file to the Financial Ombudsman Service should an adjudicator be required to consider the complaint.


We are required to disclose high-level analytics to the Financial Conduct Authority (FCA) concerning the number and nature of any complaints we receive.  This data does not include names or details that identify the specific data subject.


We will keep personal information contained in complaint files in line with our retention policy.  This means that information relating to a complaint will be retained for 3 years from closure.  It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.


Use of Data Processors
Data processors are third parties who provide elements of our service for us.  We have contracts in place with our data processors.  This means that they cannot do anything with your personal information unless we have instructed them to do it.  They will not share your personal information with any organisation apart from us.  They will hold it securely and retain it for the period we instruct.


Your Rights
You have rights as an individual which you can exercise in relation to the information we hold about you.  


Please ask us for an explanation of each should you wish to have more information:


√ The right to be informed
√ The right of access
√ The right to rectification
√ The right to erasure
√ The right to restrict processing
√ The right to portability
√ The right to object
√ Rights to automated decision and profiling


Your Right To Access
You have the right to access any information we hold about you, and the right to know why that data is being processed, how long it’s stored for, and who has had or has access to it.  


You will not be charged for us supplying you with this information however we do reserve the right to apply a reasonable fee where requests are deemed excessive.


We will respond to any such request within the maximum time frame allowed of one month.


How To Contact Us
For further information on how your information is used, how we maintain the security of your information and your rights to access the information we hold on you or if you would like to make a complaint, you can write to us, email us, or call us as follows:


Peter Blackmore
Blackmore Borley Limited
Boundary House
7/17 Jewry Street
London
EC3N 2HP


Tel:  0207 929 4616


If You Have A Complaint
If you have any concerns about your rights and our practices in relation to data protection, please contact us directly using the details provided above.  We will aim to respond to your concerns and clarify how we have processed your information and with whom.  We will also endeavour to put right anything that’s gone wrong.


If you are still dissatisfied after contacting us, you may report your concern to the Information Commissioner’s Office by contacting them as follows:


Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel:     0303 123 1113 
Website:  www.ico.org.uk


Version 1 – Jan 2022