Who is Cape (Ins) Services Limited?
Cape (Ins) Services Limited (also known as “Cape”, and also referred to as “us” or “we” in this Notice) is an insurance broker supporting clients in identifying insurance solutions.
This Privacy Notice details what personal information we collect about you, how we use it, what our lawful bases are for processing your information, who we share it with, how we protect it and how you can both access and control the information we hold about you.
If after reading the Notice you have any additional questions about how we use your information or wish to exercise any of your rights outlined in this Policy, please write to us at 9th Floor, Cornerblock, 2 Cornwall Street, Birmingham, B3 2DX.
Our Promise about your personal information
- We will not sell your personal information;
- We will maintain our security systems to keep your information safe;
- We will make it easy for you to access and control your information;
- We will comply with all relevant Regulatory requirements governing the use of personal information
Our status with the Information Commissioners Office (ICO)
Cape is registered with the ICO as a Data Controller under registration reference ZB024695. We review our registration status periodically to ensure it accurately reflects the information we collect and how we use it.
Collection of data about 3rd parties
We may collect information from you about other people for example joint applicants. If you give us information about another person it is your responsibility to ensure and confirm that:
- You have told the individual who we are and how we use personal information as set out in this Privacy Notice
- You have permission from the individual to provide that personal information to us and for us to use it, as set out in this Privacy Notice.
What personal information do we collect?
Personal data is any information that may identify a living individual. We collect information such as your name, contact information, date of birth, gender, marital status, financial details, documentation to confirm your identity or residential address, and employment details/status. We may also collect technical data from you when you use our website such as IP address, web browser type and version.
As an insurance broker, we may be asked by insurance companies and underwriting agencies for additional personal information in order for them to provide their services.
Personal information will be collected when you use our website, when you contact us by telephone (or when we contact you by telephone), and throughout the application or renewal process, when processing claims, or when you advise us of change in your status or requirements. Please note calls between us are recorded and securely retained for training and compliance purposes.
Information will usually be collected directly from you or someone you have authorised to provide information to us such as a joint applicant. Your name and contact information may, however, be collected from an Introducer or a Broker and passed to us. When we are approached by an Introducer or a Broker on your behalf we ensure that you have been made aware of how your information will be used.
Information may also be collected about you from the public domain such as Companies House records, in electoral roles and widely available on the internet.
Where we approach an insurance company on your behalf, the insurance company will become a joint Data Controller and we recommend that you read their Privacy Notice before submitting an Application as they may use your information in additional ways to ourselves for example automatic profiling.
We do not collect information classified as Special Category data, such as racial or ethnic origin, religious beliefs or criminal convictions etc unless it is lawful to collect such information and it is relevant to the transaction.
If you are an introducer of business into Cape, we will collect some identification data, contact information and employment information about you. We will also ask you to confirm your/your firms’ status with the Information Commissioners Office, and that the client you are introducing has been made aware of how you will process and share their data with us.
How do we use your personal information?
We collect, use and store your personal information in order to fulfil requests for quotes, to provide products and services as part our insurance broking including enabling you to enter into an insurance contract, and for claims handling.
It may also be used to verify your identity, to administer payments, to enable us to carry out anti-money laundering and other financial crime checks where required, to notify you about changes to our service and to help us in develop new products and services.
If you do not provide the information required we are unlikely to be able to arrange your insurance and may not be able to provide certain other services to you.
What lawful bases do we have for processing your information?
Where you approach us for a quote for an insurance product our lawful basis for processing your data is “contract” i.e. we are processing your data because you have asked us to do something before you enter into a contract.
For other elements of the data we process, we will have a “legitimate interest”, and / or a “legal obligation”. For example, we have both a “legitimate interest” and a “legal obligation” to process information to prevent financial crime. There will also be occasions where we rely on your “consent” to process your data.
Where you have made an enquiry with us we have a “legitimate interest” to keep you informed about relevant products and solutions that may be of interest to you. When we first collect information from you, we will give you the option to restrict this processing i.e. prevent any marketing material being received. Where you do not exercise your right to restrict this processing, all marketing literature we send to you will have an option to unsubscribe. You can also exercise your right to restrict processing for marketing purposes or withdraw any “consent” you have previously provided to us, at any time. Please see “how can you restrict us sending you marketing material?” below.
Who do we share your information with?
We will only supply your personal information to other parties where such a transfer is a necessary part of the activities that we undertake, where you give us consent or where we are required to do so by law or regulation (e.g. where the disclosure is necessary for the purposes of the prevention and/or detection of crime).
As a broker we must disclose personal information to insurance companies, underwriting agencies, business partners and other parties in order to provide our products and services and to enable you to enter into insurance contracts. Examples of other parties include other insurance intermediaries, loss adjusters, regulatory bodies, anti-money laundering and other fraud / financial crime prevention service providers, legal and accountancy firms involved in the claims handling process. We may also share your personal information with fraud prevention agencies such as the Claims and Underwriting Exchange Register. We may pass information relating to your insurance policy and any incident to the operators of these registers, their agents and suppliers.
We may also disclose your information to service providers engaged to perform services on our behalf. Such service providers are contractually restricted from using or disclosing the information we give them except as necessary to perform services on our behalf or to comply with legal requirements.
We only share your information if we are satisfied that our partners or suppliers have sufficient measures in place to protect your information in the same way that we do.
As a company within the ARMCo group of companies we may share information with associated companies within our group where we believe they can contribute to a competitive bespoke financial solution.
You understand that we may disclose the information you provide to relevant other parties for the purposes described in this Notice.
How long do we keep information about you?
Any personal information we collect will be retained by Cape for as long as you are a client of Cape. After you cease being a client of Cape we may retain your information for up to 6 years in order to respond to complaints or questions you may have, to demonstrate we have observed our Treating Customers Fairly principles and to fulfil any legal or regulatory requirements. For instance, it is a regulatory requirement to retain information we gathered about you regarding your identity and residency for a period of time after you cease being a client.
We may retain your information for longer than 6 years if we are required to do so by law, or for research and statistical purposes where we can prove a “legitimate interest”. Where we do retain your information for more than 6 years we will ensure your information is used only for these stated purposes.
How do we protect your information?
Information security is of great importance to Cape and to protect your information we have put in place suitable physical, electronic and managerial procedures whether your personal data is stored in physical files or computer systems (including hard drives and storage systems).
We also have policies in place to ensure we do not collect excessive or special category information from you and systems to securely dispose of information in line with our retention policy.
Cape also employs the services of third parties to control and protect your information and regularly reviews the security controls in place. Where we are considering appointing a new third party who would handle your personal information, we liaise closely with the ICO to ensure appropriate safeguards are in place. In the event your personal information is transferred outside of the UK, we ensure this is only done if the strict criteria regarding ‘International Transfers’ are met, and regular reviews of the safeguarding arrangements are undertaken.
How can you access and control the information we hold about you?
You can access the information we hold about you by writing to us at 9th Floor, Cornerblock, 2 Cornwall Street, Birmingham, B3 2DX. To respond to your request we may need to contact you to ensure we fully understand your request and we will also need to verify your identity to ensure we do not disclose information to a third party (unless you specifically authorise us to do so). Information will usually be provided to you free of charge unless defined as unfounded, excessive or repetitious in accordance with current regulations.
In certain circumstances, you can request us to:
- rectify any inaccurate data we hold,
- complete any incomplete data
- erase personal data (“the right to be forgotten”)
- restrict or object to the processing of your personal data.
In the event we do not believe your request meets the qualifying criteria or we are unable to comply with your request for any lawful reason, we will explain these reasons to you.
Your right to withhold information
If you choose not to give us personal data which is required by ourselves or an insurance company as part of your application, it may delay or prevent your application from progressing.
For information about how you can delete and control cookies, visit www.aboutcookies.org or www.allaboutcookies.org. Please note deleting cookies may mean you lose any information that enables you to access the Web Site more quickly. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your browser if you are unsure as to how to adjust your privacy settings.
How can you restrict us sending you marketing material?
You will be given the option to restrict processing for marketing purposes when we first collect personal information from you. If you do not exercise this right to restrict processing, every subsequent marketing message you receive will give you the option to unsubscribe. However, you can also restrict processing or withdraw your consent at any time by emailing email@example.com adding “STOP” to the email heading followed by the type of marketing you are seeking to stop i.e “STOP – email”, “STOP – telephone”, or “STOP – all”.
How do you make a complaint about how we have used your personal information?
If you are unhappy with how we have used your personal information you can submit a complaint to us by writing to us 9th Floor, Cornerblock, 2 Cornwall Street, Birmingham, B3 2DX, or contact us by phone on 0121 309 0111. You can also complain to the Information Commissioners Office via their website https://www.ico.org.uk/
Our use of third parties
Cape may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, provision of Customer Relationship Management systems, delivery of purchased items, search engine facilities, advertising and marketing. We also use third parties to provide IT security solutions.
Changes to our business ownership and control
We may also disclose personal information to new owners of our business in the event that we are subject to a merger or acquisition. Disclosure may also be made to enable company audits, regulatory inspections or to investigate a complaint, suspicion of fraud or a security threat.
Information you have provided to us will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the information for the purposes for which it was supplied by you.
In the event that any information you have provided to us will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your information deleted or withheld from the new owner or controller.
Our review of this Policy