Data Protection, privacy and file retention policies – July 2018
BACKGROUND:
Renewable Risk Advisers Ltd. understands that your privacy is important to you andthat you care about how your personal data is used. We respect and value theprivacy of all of our clients and will only collect and use personal data in ways that aredescribed here, and in a way that is consistent with our obligations and your rights
under the law.
1.

Information About Us
Renewable Risk Advisers Ltd..
Limited Company registered in England and Wales under company number07327529.
Registered address: Terrace Cottage, Newtown, Newbury RG20 9AP
Responsible for Data Protection : Michael Bullock.
Email address: mjb@renewablerisk.com.
Telephone number: 07584572070.
Postal Address: As registered office.
We are authorised and regulated by the Financial Conduct Authority, Reference no.
574930.

2.

What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected,
how it is held, and how it is processed. It also explains your rights under the law
relating to your personal data.

3.

What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation
2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who canbe directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to beidentified. Personal data covers obvious information such as your name and contact
details, but it also covers less obvious information such as identification numbers,
electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.

4.

What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:© Simply-Docs - BS.DAT.PRIV.07 Privacy Notice1a)

The right to be informed about our collection and use of your personal data.
This Privacy Notice should tell you everything you need to know, but you canalways contact us to find out more or to ask any questions using the details inPart 11.

b)

The right to access the personal data we hold about you. Part 10 will tell you
how to do this.

c)

The right to have your personal data rectified if any of your personal data heldby us is inaccurate or incomplete. Please contact us using the details in Part
11 to find out more.

d)

The right to be forgotten, i.e. the right to ask us to delete or otherwise disposeof any of your personal data that we have. Please contact us using the details
in Part 11 to find out more.

e)

The right to restrict (i.e. prevent) the processing of your personal data.

f)

The right to object to us using your personal data for a particular purpose orpurposes.

g)

The right to data portability. This means that, if you have provided personal
data to us directly, we are using it with your consent or for the performance ofa contract, and that data is processed using automated means, you can ask
us for a copy of that personal data to re-use with another service or businessin many cases.

h)Rights relating to automated decision-making and profiling. we do not use yourpersonal data in this way.

For more information about our use of your personal data or exercising your rights asoutlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information
Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you havethe right to lodge a complaint with the Information Commissioner’s Office.
5.

What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to
your relationship with us):Name; Date of birth; Gender; Address; Email address; Telephone number; Business
name; Job title; Profession; Payment information; Information about your preferences
and interests; Salary Level; Medical history; Insurance Claims history; and Other
information relevant to the risk(s) to be insured.

6.

How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. Thismay be because the data is necessary for our performance of a contract with you,because you have consented to our use of your personal data, or because it is in ourlegitimate business interests to use it. Your personal data may be used for one of thefollowing purposes:•Understanding your insurance needs;•Providing and managing your insurance policy(ies)© Simply-Docs - BS.DAT.PRIV.07 Privacy Notice2•Supplying our services to you. Your personal details are required in order for
us to enter into a contract with you.]•Personalising and tailoring our services for you.

•

Communicating with you. This may include responding to emails or calls fromyou.

•Supplying you with information by email in regard to advising on and meetingyour insurance needs

With your permission and/or where permitted by law, we may also use your personal
data for marketing purposes, which may include contacting you by email AND/OR
telephone with information and news on our services. You will not be sent any
unlawful marketing or spam. We will always work to fully protect your rights andcomply with our obligations under the GDPR and the Privacy and Electronic
Communications (EC Directive) Regulations 2003, and you will always have theopportunity to opt-out.
7.

How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of thereason(s) for which it was first collected. Your personal data will therefore be kept forthe following periods (or, where there is no fixed period, the following factors will be
used to determine how long it is kept):8.

•In respect of the detail of your insurance policies and the correspondence
relating to it, and information declared to insurers, a minimum of seven years– i.e. we will delete relevant files during the year following the seventh
anniversary of the expiry of all relevant policies and renewals thereof, orcorrespondence pertaining thereto including in respect of claims, whichever isthe latest;•Where we have not placed any insurance policies on your behalf, a minimumof three years, i.e. we will delete relevant files during the year following thethird anniversary of the latest correspondence pertaining thereto.

How and Where Do You Store or Transfer My Personal Data?
We use a cloud storage system (via Microsoft Office 365) using commonly acceptedfirewalls and anti-virus software and certain information will be locally stored oncomputer hard drives and back-ups.
The security of your personal data is essential to us, and to protect your data, wepassword protect access to our data system and limit access to key personnel only.

9.

Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes
other than our service providers such as insurance companies, Lloyd’s syndicates,
sub-brokers, loss adjustors and other related parties in fulfilling our duties to you in
the performance of the assessment, placing and management of your insurance
policies in accordance with our Terms of Business Agreement, subject to one
important exception.
In some limited circumstances, we may be legally required to share certain personaldata, which might include yours, if we are involved in legal proceedings or complying© Simply-Docs - BS.DAT.PRIV.07 Privacy Notice3

with legal obligations, a court order, or the instructions of a government authority.
.
If any of your personal data is required by a third party, as described above, we willtake steps to ensure that your personal data is handled safely, securely, and inaccordance with your rights, our obligations, and the third party’s obligations under
the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps inorder to ensure that your personal data is treated just as safely and securely as itwould be within the UK and under the GDPR, as explained above in Part 8.
10.

How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for detailsof that personal data and for a copy of it (where any such personal data is held). Thisis known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal
addresses shown in Part 11. To make this as easy as possible for you, a Subject
Access Request Form is available for you to use. You do not have to use this form,
but it is the easiest way to tell us everything we need to know to respond to yourrequest as quickly as possible.
There is not normally any charge for a subject access request. If your request is‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) afee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 14 days and, in any case, notmore than one month of receiving it. Normally, we aim to provide a complete
response, including a copy of your personal data within that time. In some cases,
however, particularly if your request is more complex, more time may be required up
to a maximum of three months from the date we receive your request. You will be
kept fully informed of our progress.

11.

How Do I Contact You?
To contact us about anything to do with your personal data and data protection,including to make a subject access request, please use the following details (for theattention of Michael Bullock):
Email address: mjb@renewablerisk.com.
Telephone number: +447584572070.
Postal Address: Terrace Cottage, Newtown, Newbury, Berkshire RG20 9AP.

12.

Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, forexample, if the law changes, or if we change our business in a way that affects
personal data protection.
Any changes will be made available by e-mail to clients.

© Simply-Docs - BS.DAT.PRIV.07 Privacy Notice4