Privacy Notice

In this Customer Privacy Notice the terms, 'we', 'us' and 'our' are references to First2Protect Limited (First2Protect) or where applicable when we provide service under the trading names listed below. First2Protect is part of the Pivotal Growth group of companies of which the ultimate parent company is Pivotal Growth Limited (Pivotal Growth). First2Protect is also an Appointed Representative of PRIMIS Mortgage Network which is a trading name of First Complete Limited (Our Network).

Why are we asking you to read this document?

During the course of dealing with us we will ask you to provide us with personal information relating to you (Your Information) via all the methods we communicate with you directly, including our website www.first2protect.co.uk (Our Site) or via a third party such as an Estate Agent or Financial Consultant. We would like to explain to you what we will need to do with Your Information, and the various rights you have.

We reserve the right to change the contents of this Privacy Notice at any time, and will publish changes on Our Site.

What do we mean by Your Information?

Your Information means any information describing or relating to you that we process in relation to your insurance requirements. A summary of the information we process is as follows:

your name, address, contact details, date of birth,
information about your employment, financial and insurance history
details of the property to be insured, property occupancy information, any pre-existing insurance policies and previous claims, details of where in the past you have had insurance refused, cancelled or special terms imposed
payment details e.g. bank account or credit/debit card details, required for taking payment or processing refunds for services and/or products, any third party associations which you have including details of your financial consultant, estate agent, solicitor and/or mortgage provider to allow us to either note their interest on the insurance policy and/or to contact them and communicate with them on your behalf e.g. Power of Attorney, documentation relating to the condition of the property such as a survey, details of any claims made by you once your policy is live, feedback which you provide to us in customer surveys, so that we can monitor the quality of the service we provide and make improvements.

The basis upon which we will deal with Your Information

When we speak with you about your insurance requirements we will do so on the basis that a contract for the supply of services is in place between us. In order to perform that contract, and to arrange the products you require, we have the right to use Your Information for the purposes we set out below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Information provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from insurance providers and Our Network relating to the advice we have given to you. If you would like to know more about the legal reasons or legitimate interests that apply to a particular way in which we use personal information you can contact us at any time.

On occasion, we will use Your Information to enable us to meet any contractual responsibilities we may owe Our Network, or for wider compliance with any legal or regulatory obligation to which we might be subject. If this were to arise we would be processing Your Information in order to meet a legal, compliance, fraud prevention or other regulatory obligation to which we are subject.

The basis upon which we will process certain parts of Your Information

In order to provide insurance, sometimes we will ask you for information which is of a sensitive nature. Sensitive personal information we may collect includes summary information of any criminal convictions or offences (Criminal Disclosures) and/or other sensitive personal information we may ask you to provide. (Your Special Category Data). We will record and use Your Special Category Data in order to provide you with advice regarding the suitability of insurance products and for claims and for fraud management.

We may also use this information, if needed, where we are able to make reasonable adjustments to our service and communications for you.

How do we collect Your Information?

We will collect and record Your Information from a variety of sources, the majority of the personal information will have been voluntarily provided by you or from;

third parties including credit reference agencies and law enforcement/regulatory bodies;
your mortgage advisor, estate agent, solicitor and/or mortgage provider or any other service provider who offers First2Protect insurance services to you; and
other publicly available sources.

What happens to Your Information when it is disclosed to us?

In the course of handling Your Information we will:

record and store Your Information on our computer systems (websites, email, hard drives, cloud facilities) and it will be accessed by employees and consultants within, or contractors engaged, by us as necessary to provide our service to you and to perform any administration tasks associated with, or incidental to that service;
provide access to Our Network as necessary for the purposes of supervision, training, quality audits, customer surveys and complaint handling or otherwise to comply with any other legal or regulatory obligation Our Network may have
submit Your Information to insurance product providers in order to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that may raise
use Your Information for the purposes of responding to any queries you may have in relation to any insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware
analyse Your Information so we better understand how you use our services in order to improve the service we offer to you;
to provide you with updates in relation to the insurance market and useful product information such as claims rejections, in accordance with your contact preferences.

Use of automated processing, automated decision making and profiling

Like many insurance providers, we may use automated processing and decision making in order to streamline the services we provide. We also use our customers’ data to understand how certain products are performing and to generate business strategy based on statistical analysis. Where we perform profiling of data, where possible this is anonymised to protect your identity. We can do this activity based on our legitimate interests and only where the profiling and other automated decision making does not have a legal or other significant effect on you.

Here are some examples of the types of automated decisions which may apply:

underwriting and pricing - the eligibility and pricing of insurance products and services, which is controlled by insurers, but based on what we know;
tailoring products and services - we may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them; and
detecting fraud and financial crime - we have a regulatory obligation to detect, prevent and deter financial crime.

Sharing and transferring Your Information

Your Information will be shared with or transferred to:

Our Network, to allow them to monitor the advice which we provide to you
insurers for the purpose of providing us or you with a quotation, to administer your insurance contract and provide services in relation to your insurance contract
payment service providers for the purpose of processing the payment of your premiums;
software providers who support the systems we use to provide our services;
your mortgage advisor, financial consultant, estate agent, solicitor and/or mortgage provider where they referred you to us for insurance services, for the purpose of providing them with progress and/or status updates on the services which we are providing to you and/or to contact them on your behalf;
third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs via Our service, including in the event of a claim or dispute relating to the use of our services.

Your Information is only transferred where we believe this to be required due to your particular circumstances and/or in each case for the purposes set out in this Customer Privacy Notice, i.e. to progress your insurance enquiry and to provide you with our services.

Please note that this sharing of Your Information does not entitle such third parties to send you marketing or promotional messages: it is shared for the purpose of ensuring we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

These parties may be located in the UK or elsewhere in the world where different privacy laws may apply which may not offer the same level of protection as UK law. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country and that the service provider acts at all times in compliance with applicable privacy laws.

The basis upon which Our Network will deal with Your Information, Your Special Category Data and Criminal Disclosures

Our Network is authorised and regulated by the Financial Conduct Authority (FCA). Our Network is responsible for the quality of the advice that we provide to you.

In the course of handling Your Information (including Your Special Category Data/Criminal Disclosures) Our Network will:

record and store this data on Network systems. It will be accessed by authorised employees and consultants within, or engaged, by the Network as necessary for the purposes of supervision, training, quality audits, customer surveys and complaint handling or otherwise to comply with any other legal or regulatory obligation the Network may have
use, and where appropriate transmit, this data to respond to any request from the FCA, the Financial Ombudsman Service, HMRC, the Office of the Information Commissioner or any other regulatory, law enforcement or governmental body; and
when we have provided advice to you, retain the data either electronically or in paper format for a minimum of six years and possibly for a longer period where this is required to enable the Network to fulfil its legal and regulatory obligations.

Please note that the above information is a summary of the Network Privacy Policy for customers. If, you wish to understand in more detail what the Network will do with Your Information and Special Data/Criminal Disclosures then please visit the Network Privacy Policy for customers located at http://www.primis.co.uk/privacy-policy-and-tcs

Security and retention of Your Information

Your privacy is important to us and we will keep Your Information secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard against Your Information being accessed unlawfully or maliciously by a third party, accidentally lost, destroyed or damaged.

The personal information that you provide will be retained by us in accordance with applicable laws and our internal retention policy. However, we will take reasonable steps to destroy or de-identify personal information we hold if it is no longer needed for the purposes set out above. We will only hold your personal information on our systems for as long as is necessary for the relevant purpose for which it was collected. A copy of our retention policy is available on request.

Your rights in relation to Your Information

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive and we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you.

You can:

request copies of Your Information that is under our control
ask us to further explain how we use Your Information
ask us to correct, delete or require us to restrict or stop using Your Information (details as to the extent to which we can do this will be provided at the time of any such request)
ask us to send an electronic copy of Your Information to another organisation should you wish
change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
you can ask that we do not make our decision based on the automated decision alone. We have a non-standard insurance team that have access to a wider range of insurers and products in the event that our standard insurance panel decline providing cover;
obtain a copy of personal information safeguards used for transfers outside the UK
lodge a complaint with the Information Commissioner’s Office

How to make contact with us in relation to the use of Your Information

If you have questions or comments about our Privacy Notice or if you wish to exercise your rights mentioned above, please contact our Data Protection Officer by:

Email: customercare@first2protect.co.uk

Post: Floor 4, 11 Leadenhall Street, London, EC3V 1LP

Telephone: 01392 849750

If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Information, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Information or Your Special Data/Criminal Disclosures you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.