Introduction
Bespoke Benefit Solutions Limited is an appointed representative of Beckett Financial Services Ltd, a company authorised and regulated by the Financial Conduct Authority (FCA) FRN: 138104.
Services to Clients
Bespoke Benefit Solutions Limited provides services to clients in the following ways:
- Bespoke Benefit Solutions Ltd provides advisory services to its clients. In these circumstances, Bespoke Benefits Solutions Ltd is a data controller of any personal data which we collect from or about our clients in connection with the provision of our services.
- Bespoke Benefit Solutions Ltd operates as an appointed representative of Beckett Financial Services Ltd under an appointed representative contract for services, trading under their own business name. Bespoke Benefit Solutions Ltd is an appointed representative of Beckett Financial Services Ltd as authorised and regulated by the FCA. We are data controllers in relation to the work we carry out for our clients (Data Subjects). In our contractual relationship with Beckett Financial Services Ltd, we are Joint Data Controllers as both parties have a degree of independence in processing the Data Subjects’ personal data.
For the purposes of this notice, the Data Controller is defined as a person that determines the purposes for which, and the manner for which, any personal data are processed, in line with article 4(7) of the General Data Protection Regulation ((EU) 2016/679).
Where other companies and/or third parties provide support services to Bespoke Benefit Solutions Ltd and Beckett Financial Services Ltd, such as I.T. development and maintenance, there may be occasions where data is accessible to such parties. Bespoke Benefit Solutions Ltd and Beckett Financial Services Ltd have the appropriate safeguards and agreements in place with each service provider to ensure data is protected and meets General Data Protection Regulation requirements.
Information We Collect and From Whom
We will receive personal information about you when you contact us, for example, by requesting or obtaining a quote, seeking our guidance on your insurance options, or using our websites. The information could include:
- Individual details: Name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to you.
- Identification details: Identification numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving licence number.
- Financial information: Bank account, income or other financial information.
- Risk details: Information about you (and others insured under the policy) which we need to collect in order to assess the risk to be insured and provide a quote. This may include data relating to health, criminal convictions, or other special categories of personal data (see below). For certain types of policy, this could also include telematics data.
- Policy information: Information about the quotes you receive and policies you take out.
- Credit and anti-fraud data: Credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to you.
In certain circumstances, we collect special categories of data including health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation.
We will collect personal information about you from you directly but also potentially from your family members, employer or representative, other insurance market participants, credit reference agencies, anti-fraud databases, sanctions lists, court judgements and other judicial databases, government agencies such as the HMRC, open electoral register and any other publicly available data sources.
Cookies – Where You Visit Our Website
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 site. For example, cookies are used to remember users’ preferences and to help navigate between pages efficiently. Our websites may use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For more information about Cookies visit www.allaboutcookies.org. Further information on how we use cookies please refer to our website Terms & Conditions.
How and Why We Use This Information
We will process any personal data lawfully under one or more of the following bases:
- Performance of a Contract: The processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
- Compliance with a Legal Obligation: The processing is necessary for us to comply with the law (not including contractual obligations).
- Legitimate Interests: The processing is necessary for our legitimate interests pursued by us. In such cases, our legitimate interests are as follows:
- To add value to your product by offering you other general insurance products
- To provide excellent advice to our customers by ensuring they are fully informed about all of our services
- To engage in activities to improve and adapt the range of products and services we offer and to help our business grow
- To investigate and prevent potential fraudulent and other illegal activity
- Consent: Where you have given clear consent for us to process your personal data for a specific purpose. In circumstances where we need your consent to process data, we will make this clear and unambiguous, and you will have to pro-actively agree to the processing. We can seek your consent within a written or electronic document or verbally. Where processing is based on consent, you can withdraw your consent to processing at any time so that we stop that particular processing.
- Necessary for Reasons of Substantial Public Interest: Under the UK Data Protection Act 2018, processing for an insurance purpose is included within this basis when processing special category and conviction data. This enables us to process certain special category data without your explicit consent.
We will use personal information about you primarily in connection with the provision of insurance, namely:
- Establishing and maintaining communications with you
- Arranging insurance cover (issuing quotations, renewals, policy administration)
- Handling claims
- Undertaking anti-fraud, sanction, anti-money laundering and other checks to protect against fraud, suspicious or other illegal activities
- Processing transactions through service providers
- Credit assessments and other background checks
- Where we believe it is necessary to meet legal, security, processing and regulatory requirements
- Business transfers where we sell whole or part of our business and/or assets to a third party purchaser to allow the purchaser to administer your insurances
- Marketing and client profiling
- Allowing our group and associated companies to notify you of certain products or services offered by them
- Research and statistical analysis
- Building databases for use by us and others we may share information with
We may monitor calls, emails, text messages and other communications with you. When you contact us, we may keep a record of that correspondence and any information provided to us during that or any subsequent communication.
Please make sure that anyone else who is insured under your policy has provided you with consent to provide their personal information to us. It is important that you show this Privacy Notice to anyone else who is insured under your policy, including, for example, any dependents covered under a main member on a medical insurance, or Cash Plan policy.
How We Share This Information
In using personal data for the above purposes, we will disclose personal data to third parties including insurers, reinsurers, intermediaries or other brokers; outsourcers, sub-contractors, agents and service providers; claim handlers; professional advisers and auditors. Third parties to whom we disclose personal data are required by law and contractual undertakings to keep personal data confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation.
Retention of Your Personal Data
We will keep your personal data only for so long as is necessary and for the purpose for which it was originally collected. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim under this insurance, or where we are required to keep your personal data due to legal or regulatory reasons.
We will endeavour to keep your information accurate and whenever you inform us about any changes, we will update this information at the earliest opportunity. Please help us to do this by letting us know whenever there are changes to your personal data. If you are providing information about someone else, you confirm that they have appointed you to act for them, to consent to the processing of their personal data, including special categories of personal data, and that you have informed them of our identity and the purposes (as set out in this Privacy Notice) for which their personal data will be processed.
Data Transfers
We may need to transfer your data to other organisations located outside of the European Economic Area (EEA). These countries’ data protection laws may not offer the same level of protection for personal data as offered in the EEA. Those transfers would always be made in compliance with relevant data protection legislation, and we would ensure that appropriate safeguards to protect your personal data were put in place.
Your Rights and Contact Details of the ICO
If you have any questions or complaints in relation to our use of your personal data or you wish to withdraw your consent to processing, please contact the data protection contact at gareth.carroll@bespokebenefits.co.uk. Alternatively, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk / 0303 1231113 (local rate), or you can write to them at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Under certain conditions, you have the right to require us to:
- Provide you with further details on the use we make of your personal data/special category of data
- Provide you with a copy of the personal data that you have provided to us
- Update any inaccuracies in the personal data we hold
- Provide you with your personal data in a structured format
- Delete any special category of data/personal data that we no longer have a lawful ground to use
- Where processing is based on consent, withdraw your consent so that we stop that particular processing
- Object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
- Restrict how we use your personal data whilst a complaint is being investigated
In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).
Changes to Our Privacy Notice
Any changes we may make to our Privacy Notice in the future will be posted on our website. Please check back frequently to see any updates or changes to our Privacy Notice.
Confidentiality
At Bespoke Benefits, we take your privacy seriously. Any personal information you provide to us is treated with the utmost confidentiality and is securely stored in accordance with data protection regulations.
Purpose
The information you provide is used solely for the purpose of assessing your insurance needs and providing you with appropriate coverage options. We do not share your information with third parties for marketing purposes without your explicit consent.
Accuracy
It’s important that the information you provide is accurate and up to date. This ensures that we can offer you the most suitable insurance products and avoid any complications during the claims process.
Consent
By contacting Bespoke Benefits and providing your information, you consent to us using that information to assist you with your insurance requirements. Rest assured that we will always seek your consent before sharing your information with any third parties.
Security
We employ industry-standard security measures to safeguard your personal information against unauthorized access, disclosure, alteration, or destruction.
Retention
We retain your information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal and regulatory requirements.
Access and Correction
You have the right to access, correct, or delete your personal information held by Bespoke Benefits. If you would like to exercise any of these rights or have any concerns about how your information is being used, please contact us.
Last updated 02/08/2021
