Updated July 2018
Wright Group Brokers Ltd, T/A Wright Insurance Brokers, Wright Cover, is committed to respecting and protecting your privacy and would like you to feel safe when giving us your details. To provide you with relevant information on our products and services, respond to your requests we often request that you provide us with information about yourself. Wright Group Brokers Ltd will identify itself on Web pages and in correspondence and complies with our obligations under the EU General Data Protection Directive (GDPR) which came into effect from 25th May 2018, for the collection, use and retention of personal information from European Union member countries.
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union (EU) and the European Economic Area (EEA). It also addresses the export of personal data outside the EU and EEA areas. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU.
Public authorities, and businesses whose core activities centre around regular or systematic processing of personal data, may employ a data protection officer (DPO), who is responsible for managing compliance with the GDPR.
This document is a summary of the Wright Group Brokers Ltd Data Protection Statement. It contains a brief description of the information you need to understand how we use your data.
If you would like more detailed information on how we use your data, please contact Wright Group Brokers Ltd at firstname.lastname@example.org for our full Data Protection Statement. We encourage you to periodically review this document to be informed on how we use your personal data.
This privacy notice will inform you of the information we gather and how it is used. Wright Group Brokers Ltd maintains the same privacy practices with respect to data that is collected off-line and this notice also covers those methods of data collection and use. We will take all reasonable steps (including appropriate technical and organisational measures) to protect your personal data.
Some portions of our website may request that you give us information about yourself, from which we are able to identify you, such as your name, email or other address. Some of the ways in which we may collect information from you are:
- Subscription to newsletters or mail chimp correspondence.
- Event registrations for seminars, conferences, etc.
- Social media including but not limited to Facebook, LinkedIn, Twitter
- Downloads of documents or video clips.
References to “Wright Group Brokers Limited”, ‘Wright Insurance Brokers, ‘Wright Group’, “us”, “our” and “we” mean Wright Insurance Brokers, as well as any subsidiaries or associated companies.
Please note that Wright Group Brokers Ltd requires confirmation that all other individuals who are insured under your policy has provided you with their consent for us to process any information relating to them.
We would request that you show this document, or the full Data Protection Statement, to all other individuals named under this policy, as well other individuals at the property to which correspondence is delivered.
Queries and Complaints:
If you would like to contact us in relation to any aspect of our use of your personal data, please contact out Data Protection Officer at 0539155600 or email@example.com.
You also reserve the right to lodge a complaint with the Data Protection Commissioner’s office if you feel that Wright Insurance Brokers have not fulfilled its duties in safeguarding your data. More information on the Data Commissioner can be found at dataprotection.ie.
In relation to the information we gather, we will compile the relevant information in order to provide you with a quotation. This will include all relevant information regarding you or any other individual who will be named under your policy. By providing information about a named individual on your policy, it will be deemed that you have received their consent to provide us with their information. Other sources of information that may be used to gather data relevant to your policy may include any representatives you appoint, other insurers, third parties involved in previous/ongoing claims, industry databases or emergency services.
All electronic data collected and stored within secured servers.
Use of Information
Personal information provided by you will be used to set up, administer and manage your policy over the course of its life time. It will also be used to manage any claims/complaints made by you.
The information may also be used in the following ways:
- For the detection/prevention of any activities that indicate fraud, money laundering or other offences.
- To provide value added services as part of loyalty programmes
- To verify identity when providing policy information over the phone.
- For statistical analysis or market research purposes.
- Staff training
- For information backup purposes
- Reporting purposes to reinsurance agencies
- Compliance with all regulatory requirements
- Any further processing as set out in this document or other documents made available to you.
Legal basis for processing
The legal basis that Wright Group Brokers Ltd will rely on for processing your personal data in relation to the above are as follows:
- Where processing is necessary for the performance of the contract to which the data subject has agree to the terms and conditions of the policy
- Where processing of information is required for the creation of a quote. This will apply to all quotes, even those which have not been taken up by the data subject.
- Where processing is necessary to comply with all local and EU regulations
- Where the processing is of legitimate interest to us to bring value to our customers and the market as a whole. This may include:
- To aid in the creation of product throughs market research
- To adapt a product or service we offer and allows to evolve within the market to ensure customers will receive value.
- To prevent fraud or other illegal activities
- Aids in the overall effectiveness of business services to aid Customers
One of the following grounds must be satisfied in order to process Sensitive Data such as Race, Health, Trade Union membership, information on proceedings in relation to a review an ongoing criminal offence :
- Explicit Consent – Explicit consent of the data subject;
- Vital Interests – Necessary to protect the vital interests of the data subject where the data subject is incapable of giving consent;
- Insurance– Necessary and proportionate for the purposes of providing an insurance product;
- Medical Assessment/Diagnosis/Treatment – Necessary to assess risk or add context to an ongoing claim.
- Legal Advice and Legal Proceedings – Necessary for obtaining legal advice whether or not in the context of a claim (or prospective claim);
In providing our services to you, Wright Group Brokers Limited may need to share personal data with various third parties to carry out its regulatory duties, as well as fulfilling it contact to you. These third parties may include:
- Your representatives, such as a relative, a named individual on the policy, your broker or any legal representatives you may appoint
- Our own representatives, such as appointed legal counsel or third-party services providers for actions such as data storage, fraud detection, credit checking, motor assessors, risk analysis, etc
- Other individuals, such as third-party claimants and their representatives, other insurance companies, anti-fraud data bases (e.g. Insurance link)
- Product reinsurers
- External Auditors, either third party or regulatory i.e. Central Bank of Ireland
- Government departments, such as An Garda Siochana and Motor insurers’ Bureau of Ireland.
The information we collect may be used, store and processed in the EU, or in any other country in which Wright Group Brokers Ltd transacts business. By providing the information via the website, you are consenting to the transfer of the information outside of your country to any country (including countries which may not have adequate levels of protection).
The table below contains examples of the types of data we collect for the purposes set out in this document.
|Information Category||Type of Collected Data|
|Policy Information||Name, address, dare of birth, gender, licence details, payment details, vehicle details, property details, driving history, claims history, criminal convictions, penalty points, named driver details, business information,|
|Information provided by third party sources||Address Look ups, Eircode, vehicle details, vehicle history, penalty points, previous convictions, credit scores, risk details, etc|
|Current/Previous Claims information||Incident details, details provided by claimants, current/previous health issues, criminal convictions, property details, vehicle details,|
Information will be retained for no longer than is necessary for the purpose for which it was obtained by us or as required by legal and regulatory purposes and for legitimate business purposes.
Automated Decision Making
Wright Group Brokers Limited use automated decision making when quoting for you, by using information provided by you. Wright Group Brokers Ltd uses automated software to review and calculate a premium for a given risk based on the information provided to us, which allows for the fast tracking of accepting or declining risks based on the information provided. Where an automated decision-making process is in place, you are entitled to query the process to ensure that all information provided is correct and the quote provided (if any) is fair.
As a data subject, you are entitled to:
- Withdraw your consent at any point where we are processing data.
- Request a copy of the data that Wrights Insurance Brokers holds on you and the reasons we process this data
- Request that data concerning you be updated or corrected if inaccurate. Note that you are required to update Wright Insurance Brokers on any changes to the material facts of the policy
Further Rights Provided by GDPR
Customers will be entitled to make the following requests from 25th May 2018.
Right to be Erased
Data Subject may request that all personal data related to them to be removed from Wright Group Brokers Limited’ systems.
Right to Refuse Automated Decision Making
Data subject may request to not have decisions made on the processing of their data solely based on an automated electronic process without any human intervention.
Right to Data Portability
Data subject may request that all personal information be copied and transferred to another company in a readable and functional format.
Right to Object to Processing
Data Subject may request that any processing of personal data to be ceased outside of requirements that fulfil the contract between Wright Insurance Brokers and the customer, unless there is legitimate grounds for further processing e.g. regulatory
Right to Restrict Processing
Data Subject may request to restrict the processing of data that they feel is inaccurate, processed unlawfully, that is irrelevant to the contract, or have invoked their right to object.
Changes to Website Privacy Notice