Last Updated 8th February 2018
TLO Risk Services Limited (“TLO” also referred to as "we", "us", or "our") are committed to protecting the privacy of the individuals we interact with in the conduct of our business.
We collect personal information to offer and administer our services and products. These include insurance broking, claims management, risk management, and other forms of insurance services (including underwriting of insurance products).
“Personal Information” is information that identifies and relates to you or other individuals (such as your dependants).
Who to Contact about Personal Information?
If you have any questions about our use of your Personal Information or Data you can e-mail: firstname.lastname@example.org or write to us at TLO Risk Services, 40 St James’s Place, London, SW1A 1NS.
What Personal Information do we collect?
Personal Information collected about you and your dependants may include:
- General identification and contact information
Your name; address; e-mail and telephone details; gender; marital status; family status; date and place of birth; passwords (including on our systems); educational background; activity records, such as driving records; photos; employment history, skills and experience; and professional licenses and affiliations.
- Identification numbers issued by government bodies or agencies
National Insurance or other social security number; passport number; tax identification number; military identification number; or driver’s or other license number.
- Financial information and account details
Payment card number; bank account number and account details; credit history and credit score; assets; income; and other financial information.
- Medical condition and health status
Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits, prescription information; and medical history.
- Other sensitive information
In certain cases, we may receive sensitive information about your trade union membership, religious beliefs, political opinions, family medical history or genetic information. In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud. We may also obtain sensitive information if you voluntarily provide it to us.
- Telephone recordings
Recordings of telephone calls to our offices.
- Information enabling us to provide products and services
Location and identification of property insured; travel arrangements; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organisation; and other insurance you hold.
- Marketing preferences and customer feedback
You may let us know your marketing preferences, enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey.
- Social media account and information from Apps
We may receive certain Personal Information about you when you use or interact with our Social Media Content, including your social media account ID and profile picture, and other Personal Information that you provide to us.
How do we use this Personal Information?
We use this Personal Information to:
- Communicate with you and others as part of our business and provide information and services as requested by you, including client communication, service, billing and administration;
- Understand and assess your ongoing needs and offer products and services to meet those needs;
- Determine eligibility and process applications for products and services and where appropriate make decisions about whether to provide insurance, including claim assessment, processing and settlement; and, where applicable, manage claim disputes.
- Assess your eligibility for payment plans and process your premium and other payments.
- Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
- Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks.
- Carry out market research and analysis, including satisfaction surveys.
Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.
- Facilitate social media sharing functionality.
- Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management.
- Resolve complaints, and handle requests for data access or correction. Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public & governmental authorities (including those outside your country of residence).
- Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.
Do we transfer your Personal Information across geographies?
TLO may transfer certain Personal Information across geographical borders to service providers in other countries working on our behalf in accordance with applicable law.
By providing us with your information or using our websites, you consent to the collection, international transfer, storage, and processing of your information. These transfers are governed by European Union (EU) standard contractual clauses or equivalent data transfer agreements to protect the security and confidentiality of Personal Information. We will ensure any organisation receiving the personal data has provided adequate safeguards.
Do we disclose or share your personal information?
We disclose Personal Information to business partners that are necessary to provide our products and services. Examples include:
- credit and fraud reporting agencies, debt collection agencies, insurers, reinsurers, and managed fund organisations for financial planning, investment products and trustee or custodial services in which you invest
- insurance broking and insurance products - insurers, reinsurers, other insurance intermediaries, insurance reference bureaus, fraud detection agencies, our advisers such as loss adjusters, lawyers and accountants and others involved in the claims handling process
We may also disclose your information to service providers we have retained to perform services on our behalf. These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements.
We may disclose personal information (i) if we are required to do so by law or legal process, (ii) in response to law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity or (v) in the event that TLO is subject to a merger or acquisition to the new owner of the business. Disclosure may also be required for company audits or to investigate a complaint or security threat.
Do we have security measures in place to protect your information?
TLO has implemented reasonable physical, technical and administrative security standards to protect Personal Information from loss, misuse, alteration or destruction. Our service providers and agents are contractually bound to maintain the confidentiality of personal information and may not use the information for any unauthorised purpose. If you have reason to believe that your interaction with us is not secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us.
How long do we retain Personal Information?
Access to Data and Corrections
You have the right to access, correct or object to the use of, or request deletion or suppression of Personal Information on certain grounds. Please contact us with any such requests or if you have any questions or concerns about how we process Personal Information. Please note that some Personal Information may be exempt from access, correction, objection, deletion or suppression rights in accordance with local privacy and data protection laws.
What are your options to manage the information you provide and your Marketing Preferences?
You have several options to manage Personal Information you provide to us. In general, you are not required to submit Personal Information when you visit our websites. However, we may ask you to provide certain Personal Information in order for you to receive additional information about our products, services and events. If you request electronic communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in the communication.