This Privacy Notice is designed to help you understand how we use and process your personal data.
It was created on 25 May 2018 and will be reviewed by us every 6 months. Insurance market participants may link to, or refer to, this notice from their own information notices or consent wordings where they share your personal data with us.
Words in bold have specific meaning. Those meanings are found under Section 15 Key Terms.
1. Our Responsibilities to You and Your Personal Information
At ArgoGlobal, we collect and use personal information about individuals, including insured persons, claimants, business partners and other third parties. We take our responsibilities to handle your personal data in accordance with data protection laws very seriously. As part of our responsibility, it is important that we provide you with the information in this notice so that you understand how, why and when we collect, use and retain your personal information, your rights in relation to that information and the conditions under which we may disclose your personal information to third parties.
This Information Notice, together with our website terms and conditions, any other documents referred to in it and the London Market Core Uses Information Notice, sets out how we collect and use your personal data. Please contact us using the details set out in Section 13 Contact Details if you require access to the London Market Core Uses Information Notice in a different format.
Under data protection law, we are required to provide you with a lot of information about how we collect and use your personal data. It is easy for all this information to become confusing rather than helpful.
We therefore use a layered approach to provide you with the information required by law. This means that we may provide the information required in a number of different formats and documents. In particular, it means that, in our initial contact with you, we may provide you only with the most important information about how we will use your personal data; but we will always provide you with easy access to all the further information you need about our privacy practices.
Please read this Information Notice carefully.
2. Who Are We?
ArgoGlobal is the brand name used to refer to a group of international insurers and reinsurers. We underwrite through Syndicates 1200 and 1910 at Lloyd’s of London under Argo Managing Agency, Argo Direct Limited, ArgoGlobal SE and ArgoGlobal Assicurazioni S.p.A. We also work through a network of business relationships that we establish with insurance market participants who we may rely upon to underwrite and administer policies and adjudicate claims on our behalf.
The ArgoGlobal entity that originally collected information from you will be principally responsible for managing your personal information. If you have an insurance policy with us, this will be the ArgoGlobal entity named on that policy.
To find out the identity of any ArgoGlobal company that collects personal information about you as part of providing insurance coverage, check:
- If you purchased the policy yourself, the ArgoGlobal company or your broker (if purchased through a broker) will provide you with the details of the ArgoGlobal company.
- If your employer or other third party purchased the insurance for your benefit, contact your employer or third party to obtain details of the ArgoGlobal company.
- If your personal data is transferred to another entity (for example, a reinsurer or third-party claims administrator), contact your ArgoGlobal insurer for details of the other entity.
Our contact details are shown in Section 13 Contact Details. This Information Notice is also available on our web site at https://www.argo-global.com/pages/home.
3. What Information Do We Collect?
The type of personal information we collect about you will depend on your relationship with ArgoGlobal.
If you are an insured person or potential insured, we collect personal information of the policyholder, prospective insured and related individuals in order to determine eligibility to underwrite and administer insurance policies. In some instances, we may need to collect special category data such as health information or criminal history. For further details on the types of personal information we may collect about you, please see the London Market Core Uses Information Notice and see below to view the table.
If you are making a claim under your ArgoGlobal policy, we may need to collect your contact information, as well as information about your claim and previous claims. We may also need to collect special category data such as health information or criminal history, depending on the nature of your claim. For further details on the types of personal information we may collect about you, please see the London Market Core Uses Information Notice and see below to view the table.
If you are a witness and we receive your information in relation to a claim being made under an ArgoGlobal policy, we may need to collect your contact information, as well as further information about you. We may also need to collect special category data such as health information depending on the nature of the information you are providing us. For further details on the types of personal information we may collect about you, please see the London Market Core Uses Information Notice.
If you visit our websites, personal data collected by us may automatically include technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform. Personal data collected by us also may automatically include information about your visit, including the full Uniform Resource Locators (URL); clickstream to, through and from our site (including date and time); what you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks and mouse-overs); and methods used to browse away from the page.
If you are a business partner, we will collect your business contact details and other details that you provide to us.
The personal data we collect about you:
Type of Personal Data
||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 numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving licence number
||Bank account or payment card details, income or other financial information
|Information about you that we need to collect in order to assess the risk to be insured and provide a quote. This may include data relating to your health, criminal convictions or other special categories of personal data. For certain types of policy, this could also include telematics data.
||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
|Previous and current claims
||Information about previous and current claims (including other unrelated insurances), which may include data relating to your health, criminal convictions, or other special categories of personal data and, in some cases, surveillance reports
|Special categories of personal data
||Certain categories of personal data, which have additional protection under the GDPR. The categories are 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.
4. Where Do We Get Your Personal Data From?
We might collect your personal data from various sources, including:
- your family members, employer or representative;
- your use of our website;
- other insurance market participants;
- our business partners;
- credit reference agencies;
- anti-fraud databases, sanctions lists, court judgements and other databases;
- government agencies such as the DVLA and HMRC;
- open electoral register;
- regulators, including the Financial Conduct Authority (FCA), Information Commissioner’s Office (ICO) and the Prudential Regulation Authority (PRA); or
- in the event of a claim, third parties including the other party to the claim (claimant/defendant), witnesses, experts (including medical experts), loss adjustors, solicitors, and claims handlers
It will depend on your particular circumstances which source we will get your personal data from.
5. The Reasons Why We Collect Your Information
Quotation and inception
setting you up as a client, including possible fraud, sanctions, credit and anti-money laundering checks
evaluating the risks to be covered and matching to appropriate policy/premium
payment of premium where the Insured/policyholder is an individual
client care, including communicating with you and sending you updates
payments to and from individuals
managing insurance and reinsurance claims
defending or prosecuting legal claims
investigating or prosecuting fraud
- contacting the Insured/policyholder to renew the insurance policy
- evaluating the risks to be covered and matching to appropriate policy/premium
- payment of premium where the Insured/policyholder is an individual
- to provide information to our service providers, auditors, contractors, agents and group companies that perform activities on our behalf
- general risk modelling
- transferring books of business, company sales and reorganisations
- complying with our legal and regulatory obligations
- managing our business relationship with you
- direct marketing
6. Our Legal Grounds of Processing
We will only use your personal data when the law allows us to do so. In general, we will use your personal data:
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- where we need to comply with a legal or regulatory obligation;
- where we are processing your personal data for an insurance-specific exemption provided by laws enacted by specific European Union Member States, which permits us to collect and use your special category data (for example, where we need to use your information for an “insurance purpose” where the UK Data Protection Act 2018 applies); or
- where you have given your consent.
In some circumstances, applicable data protection laws may require us to obtain your consent to the processing of your personal data. Where this is the case, we will ask you for your consent in accordance with those laws. You may withdraw your consent to such processing at any time. This will not affect the lawfulness of any processing that took place before your consent was withdrawn.
Please note that if you withdraw your consent in relation to an insurance policy that we are administering or a claim that we are handling, then this is likely to impact our ability to administer that insurance policy and handle claims. In order to provide insurance cover and deal with insurance claims in certain circumstances, insurance market participants may need to process your special categories of personal data, such as medical and criminal convictions records, as set out against the relevant purpose.