Please take time to read this document carefully as it contains details of the basis on which we will process (collect, use, share, transfer) and store your information. You should show this notice to all parties related to this insurance arrangement. If you have given us information about someone else, you are deemed to have their permission to do so.
If you have any questions or need further information you can e-mail firstname.lastname@example.org.
USE OF INFORMATION
We, LOWKEY FILMS LTD. will, at all times, treat all data strictly in accordance with The General Data Protection Regulations (GDPR) with effect from 25th May 2018.
DATA CONTROLLER AND DATA PROCESSOR
We will ensure data is processed lawfully, fairly and in an open and transparent manner and ensure appropriate security measures are in place against unauthorised or unlawful processing or accidental loss, destruction or damage using appropriate technical or organisational measures. (such as restricting access to key people within our organisation for certain aspects of your information; and periodically checking the level of security we apply to prevent unauthorised use, accidental loss, or misuse of your information)
The contractual arrangements we have in place with our suppliers are governed by and shall be deemed to operate strictly in accordance with the terms of such contracts. Importantly, these contracts set out to define how data will be processed between us, and providers of services to us, including circumstances when we act as a processor or controller as is required by the GDPR.
When we act as a controller of your data, we will, in certain circumstances also process your data and as a controller also determine the purposes and means of processing that data.
COLLECTING INFORMATION ABOUT YOU
When we collect information about individuals, we may collect personal data which may include a variety of information about an individual (e.g. their name, address of residence, communication and contact details, and other personal information, such as a date of birth). Where relevant to do so we may also collect information relating to an individual, indirectly by reference to an identifier (e.g. an IP address, which is a unique number identifying your computer, laptop or similar portable device).
Where required and appropriate to so, we will also collect more sensitive personal information (such as details about an individual’s motoring or criminal convictions, details of health, credit worthiness and other similarly sensitive information).
In certain circumstances we will collect information from a variety of different sources (e.g. publicly available sources, such as social media and networking sites; third party databases generally available to the financial services sector, and the wider commerce and industry including, MGA’s, Lloyd’s of London, claims management firms, loss adjusters and or other suppliers appointed in the process of handling a claim or credit reference and similar agencies).
USING INFORMATION ABOUT YOU
We will use information, including sensitive information, about individuals, and other parties related to our activities, because it is principally:
it is necessary for compliance with a legal obligation; or
it is necessary to protect the vital interests of a data subject or another person; and
necessary for our own legitimate interests or those of other controllers or third parties (e.g. to search at credit reference agencies, monitor e-mails, calls and other communications or for market research, analysis and developing statistics) except where such interests are overridden by the interests, rights or freedoms of the data subject.
We will also use your information when there is a justifiable reason for doing so, such as compliance with legal obligation (e.g. for the prevention and detection of fraud and financial crime, which may include processes which profile you); and for the recording and monitoring of telephone calls for auditing reasons.
SHARING YOUR INFORMATION
We will share information, including sensitive information, about you, and other parties related to this insurance because it is:
necessary for compliance with a legal obligation; or
necessary to protect your vital interests; or
necessary for our own legitimate interests or those of other controllers or third parties; and
necessary for a task carried out in the public interest or for an exercise of an official authority (e.g. a regulatory body).
This includes sharing your information with carefully selected third parties providing a service to us or on our behalf.
WHAT WE WILL NOT DO WITH YOUR INFORMATION
Unless required to do so by law, or for other similar reasons, other than those outlined (see sharing your information) we will never otherwise share personal information without good reason and without ensuring the appropriate care and necessary safeguards are in place; we will in any other event ask for your consent to share that information and explain the reasons.
HOW LONG WE WILL KEEP INFORMATION
We will only keep and or maintain information about an individual for as long as is necessary in providing our products and services or for compliance with a legal or regulatory obligation, including our legitimate interests or of a controller.
This means, we will only keep, information that is necessary to keep so that we can sufficiently deal with administrative issues & queries and or for compliance with legal reasons; usually we will keep information for a minimum retention period of 7 years and or maximum period of 40 years, after cessation of a product or service we have provided.
However, we will keep information for much shorter periods if that information related merely to a quotation which did not then result in a contract of our services being arranged; in these circumstances we will keep information for a minimum retention period of 12 months and or maximum period of 18 months unless such information becomes manifestly out-of-date in which case we may keep quotation information for shorter periods.
In any event all information shall be stored in strict compliance with the GDPR legislation at all times; and using appropriate technical or organisational measures we will regularly:
review the length of time we keep and or maintain information about you;
consider the purpose or purposes why we hold the information about you in deciding whether (and for how long) to retain it;
securely delete information about you that is no longer needed for this purpose or these purposes; and
update, archive or securely delete information about you if it goes out of date.
In carrying out our duties as Data Controller and Data Processor we will collect sensitive information, about you, and other parties related to this insurance because it is:
necessary for compliance with a legal obligation
necessary to protect your vital interests;
necessary for our own legitimate interests or those of other controllers or third parties; and
necessary for a task carried out in the public interest or for an exercise of an official authority (e.g. a regulatory body)
What we mean by sensitive data includes information such as:
about an individual’s health including medical conditions;
motoring or other criminal convictions; and
racial or ethnic origin or religious beliefs.
We will always apply additional organisational and technical measures for this category of data, including restrictions to access this data (this is where data may be secured with additional layers of security to prevent misuse and protect personally identifiable information).
USE AND STORAGE OF YOUR INFORMATION OVERSEAS
We will never knowingly transfer, store, or process information about you or an individual, outside the European Economic Area (EEA). In any event, if we are compelled to transfer your information outside the EEA it shall be in compliance with the conditions for transfer set out in the GDPR and or restricted to a country which is considered to have adequate data protection laws. All reasonable steps shall typically have been undertaken to ensure the firm to which information is being transferred has suitable standards in place to protect such information.
Individuals have a number of rights relating to the information we hold these rights include but are not limited to:
a copy of the personal information we hold (once requested, we have a maximum of one month to give an individual such information);
rectify information, if it is inaccurate or incomplete;
request the deletion or removal of an individual’s personal data where there is no compelling reason for its continued processing;
suppress processing of an individual’s personal data, when processing is restricted, we are permitted to store the personal data, but not carry out further processes. We will retain sufficient information about the individual to ensure that the restriction is respected in future (see Marketing);
object to certain uses of an individual’s personal information (see Marketing);
in certain circumstance to not be subject to a decision when it is based on automated processing; and or it produces a legal effect or a similarly significant effect on an individual;
withdraw any permission you or an individual may have previously provided; and
complain to the Information Commissioner’s Office at any time if you or an individual is not satisfied with our use of such information.
Individuals can request a copy of the personally identifiable information we hold by contacting us about them, including the right to have such information in a portable form ‘a right to data portability’ so we will normally, not only provide the information free of charge (however we may apply a charge where information requests are excessive) but we will provide that information in a format that is easily accessible, sometimes in a CSV format, should an individual require it in that format to ensure information can be exchanged easily with other organisations.
If you would like further information or wish to make a Subject Access Request (SAR) you can e-mail email@example.com.
When marketing to you as an individual (including, individual sole traders and partnerships), we will either rely on the permission we have (if we are able to do so) or we will ask for your permission (consent) to contact you, including the means to contact you (such as by phone, or e-mail, push notifications, SMS text, or post) to tell you about;
new products or services we have or are developing;
trialling products and services which we think may improve our service to you or our business processes;
offer you rewards;
enter you into a competition;
We will typically ask for permission when you first contact us, (usually but not limited to our websites), however, you will maintain the right to easily withdraw such consent when-ever you wish (unsubscribe).
We will regularly review any such consent to check that your relationship with us and any processing including the purposes have not changed.
In all situations where we market to a business we will observe both the market standards and those rules and guidelines of the Privacy and Electronic Communication regulations (PECR).
We have in place such a process to ensure we refresh your consent at appropriate intervals, including any parental, or third-party consents (where relied upon) and act on withdrawals of consent (unsubscribe) as soon as we can and not penalise you if you not choose to give and later decide to withdraw your consent.