Introduction
John Neville Insurances Limited is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.
It is the intention of this privacy statement to explain to you the information practices of John Neville Insurances Limited in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
- John Neville Insurances Limited
- Phone: 061 392 224
- E-mail: [email protected]
- When we refer to ‘we’ it is John Neville Insurances Limited
Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Where you have purchased an insurance policy through John Neville Insurances Limited, the insurance provider also becomes the controller of your personal data for the purposes outlined in their privacy policies. This will normally be to perform their contractual obligations under, and to underwrite, your insurance policy. You can find the insurance provider’s privacy policies on their websites.
Who are we?
- We, our, us refers to John Neville Insurances Limited. John Neville Insurances Limited is a private company incorporated in Ireland with company number 213381 and having its registered office at Main Street, Askeaton, Co. Limerick, V94 T9E5, Ireland. We are a registered insurance intermediary and provide both Life and Non-Life Insurances services. We are members of Brokers Ireland.
Our GDPR Owner and data protection representatives can be contacted directly here:
- John Neville
- [email protected]
- 061 392 224
Information Collection
| Data Category | Data Type | Where we collect the data from |
|---|---|---|
| Identity Data | Name, address, email address, phone number, gender, marital status, date of birth, Official identification documents and numbers including PPS, passport number and VAT number.
For motor insurance policies, this also includes your driving licence number and vehicle registration number. |
– You; – Joint policy holder; – Any representative nominated by you to act on your behalf such as a family member or legal representative; – Your insurance company; – Anti-fraud databases, sanctions lists, court judgements and other databases; |
| Policy Data | Identity data, employment status and occupation, previous insurance history, details of any previous claims and claims occurring during the term of a policy arranged by us.
For motor insurance policies, this also includes driving history (including motoring convictions, disqualifications / penalty points, health data, vehicle details. |
– You; – Joint policy holder; – Any representative nominated by you to act on your behalf such as a family member or legal representative; – Your insurance company; – Other insurance market participants; – Law enforcement agencies such as An Garda Síochána, Criminal Assets Bureau; – Anti-fraud databases, sanctions lists, court judgements and other databases; – Publicly available information including social media websites, electoral register, online content, TV, radio, and other media content; – 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 |
| Financial Data | Your financial information: including bank and payment card details, payment transaction history, and information on income or turnover. | – You; – Joint policy holder; – Any representative nominated by you to act on your behalf such as a family member or legal representative; – Your insurance company; – Your loan provider (for the purpose of arranging and managing premium finance with Close Brother Premium Finance through John Neville Insurances Limited) |
| Special Category Data – Health Data |
Information about your health | – You; – Joint policy holder; – Any representative nominated by you to act on your behalf such as a family member or legal representative; – Your insurance company; |
| Criminal Convictions Data | Details of any unspent motoring (including penalty points) or non-motoring convictions (if any) | – You; – Joint policy holder; – Any representative nominated by you to act on your behalf such as a family member or legal representative; – Your insurance company; – Law enforcement agencies such as An Garda Síochána, Criminal Assets Bureau; – Anti-fraud databases, sanctions lists, court judgements and other databases; |
| Technical Data | 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, operating system and platform, how often you use the application and other performance data; and | – Your device when you access and use our website. |
| Usage Data | Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), product you viewed or searched for, page response times, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page, and any phone number used to call us. | – Your device when you access and use our website. |
Purposes for which we hold your Information
The main purposes for which we use your personal information are to provide a quote, setup, administer and manage your policy and to carry out marketing and analytics. In any event, John Neville Insurances Limited are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. The following section provides more detail on the purposes for which we process your personal data and the legal basis by which we do this.
| Purpose/Activity | Legal basis for proceeding |
|---|---|
| To provide you with a quote for insurance | Performance of a contract with you |
| To administer your insurance policy | Performance of a contract with you |
| To respond to your queries and to provide you with the information you request from us in relation to our services. | – Performance of a contract with you – Necessary to comply with a legal obligation – Necessary for our legitimate interests (to respond to new or existing customer queries and grow our business) |
| To manage payments, fees and charges in respect of insurance premiums, and to collect and recover money owed to us. | – Performance of a contract with you – Necessary for our legitimate interests (to recover debts due to us) – Necessary to comply with legal obligation |
| To manage our relationship with you, including notifying you about changes to the Services, or our Privacy Policy. | – Performance of a contract – Necessary to comply with legal obligation – Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services). |
| To provide you with marketing communication about other services we feel may interest you | – For non-customers: Consent – For existing or past customers: Legitimate interests (to develop and grow our business) unless you have opted out. |
| To ensure that content is presented in the most effective manner for you and for your computer or device | Necessary for our legitimate interest (to keep our site and the services updated and relevant to develop and grow our business). |
| To administer and protect our business, our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. | Necessary for our legitimate interests (for running our business and as part of our efforts to keep our site and the services safe and secure) |
| To use data analytics to improve or optimise our site, marketing, customer relationships and experiences | – Necessary for our legitimate interests (to study how customers use our products or services, to develop them, to grow our business and to inform our marketing strategy). – For non-customers-consent |
| To prevent, detect and report fraud, money laundering and other offences to protect our business, risk management | – Necessary to comply with legal obligation – Necessary for our legitimate interests (for our risk management purposes, security and compliance purposes) |
Who are we sharing your data with?
We may pass your personal data on to third-party service providers contracted to John Neville Insurances Limited in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with John Neville Insurances Limited procedures.
If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise.
We may share your personal data with outside organisations, below is a list of the categories of recipients of organisations we share your personal data with:
- Insurance Companies and Brokers
When you request a quote from us we will need to share your personal data with our panel of insurance providers. As outlined earlier, the insurance provider is also a controller of your personal data. Further information on how they protect your personal data may be found in their privacy policies. We may also continue to share personal data such as identity data and policy data with insurance providers to manage and administer your policy and for the prevention and detection of fraud.
- Your Representatives
Any party you have given us permission to speak to in relation to your policy of insurance (such as relative, friend or legal advisor), in certain circumstances other people insured under your policy of insurance (such as named driver) and other people or companies associated with you.
- Our Representatives
Our employees and contractors including companies that provide services in relation to telecommunications and postage, data storage, document production and destruction, IT and IT security, fraud detection, making and receiving payments, data analysis and management information, credit checking, risk analysis, complaints handling, marketing and market research.
- Government, Statutory and Regulatory Bodies
State regulators and authorities such as the Data Protection Commission, the Revenue Commissioners, the Central Bank of Ireland and the Financial Services and Pension Ombudsman; Law Enforcement Agencies such as An Garda Síochána and The Criminal Assets Bureau. Industry bodies such as Motor Insurers Bureau of Ireland and Personal Injuries Assessment Board.
We may also disclose your personal data to the following recipients or categories of recipients:
- If we are under a duty to disclose or share your personal data in order to comply with any law, legal obligation or court order, or in order to enforce rights under the GDPR or other agreements.
- To protect our rights, property or safety, our customers, or others.
We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions.
If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.
Data Subjects Rights:
John Neville Insurances Limited facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why.
All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.
Additional information we are providing you with to ensure we are transparent and fair with our processing
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. John Neville Insurances Limited will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body and our internal governance.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by John Neville Insurances Limited, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and John Neville Insurances Limited data protection representatives / GDPR Owner.
Failure to provide further information
If we are collecting your data for a contract and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.
Profiling – automatic decision making
Profiling – automatic decision making
Profiling;
Financial and mortgage advisors using profiling in their business. The main categories are
- Risk profiling.
- Profiling for marketing purposes.
- Establishing affordability and providing quotations for financial services and mortgage product
- 1) Risk Profiling
To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customers attitude to various levels of risk having answered a series of questions.
- 2) Profiling for marketing purposes.
When we seek to contact you about other services, as outlined above * we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.
- 3) Establishing affordability and providing quotations for financial services products.
Additional Processing
If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.
Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on (061) 392 224 or e-mail us at [email protected]
Privacy policy statement changes
John Neville Insurances Limited may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services you agree to this privacy policy.
This privacy policy was last reviewed in May 2018