We, GS Group, a trading name of George Stubbs Financial Services Ltd and of George Stubbs Insurance Services Ltd (also referred to as “we”, “us”, or “our”) are a registered company in Scotland, GSIS (SC177962) and GSFS (SC150771). Our registered address is South Inch Business Centre, Shore Road, Perth, PH2 8BW.
The purpose of this notice
This Notice is designed to help you understand what kind of information we collect in connection with our products and services and how we will process and use this information. In the course of providing you with products and services we will collect and process information that is commonly known as personal data.
This Notice describes how we collect, use, share, retain and safeguard personal data.
This Notice sets out your individual rights; we explain these later in the Notice but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
What is personal data?
Personal data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, their gender and contact details.
Personal data may contain information which is known as special categories of personal data. This may be information relating to an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to or sexual orientation.
Personal data may also contain data relating to criminal convictions and offences.
For the purposes of safeguarding and processing criminal conviction and offence data responsibly, this data is treated in the same manner as special categories of personal data, where we are legally required to comply with specific data processing requirements.
Personal data we collect
In order for us to arrange and administer insurance for you we will collect and process personal data about you. We will also collect your personal data where you request information about our services, customer events, promotions and campaigns.
We may also need to collect personal data relating to others in order to arrange and administer insurance. In most circumstances, you will provide us with this information. Where you disclose the personal data of others, you must ensure you are entitled to do so.
You may provide us with personal data when completing online quote or contact forms, when you contact us via the telephone, when writing to us directly or where we provide you with paper based forms for completion or we complete a form in conjunction with you.
We will share your personal data within our group and with business partners. This is normal practice within the insurance industry where it is necessary to share information in order to place, quantify and underwrite risks, to assess overall risk exposure and to process claims. It is also necessary to determine the premium payable and to administer our business.
We also share personal data with authorised third parties, this is necessary where we are required to do so by law, where we need to administer our business, to quote for, source, place and administer your insurances including arranging insurance premium finance to perform underwriting activities and to process claims. Some examples follow:
We will collect your personal data when you visit our website, where we will collect your unique online electronic identifier; this is commonly known as an IP address.
We may record your communications with us when contacting our customer care, complaints and other customer focused functions. We also collect personal data through the use of telematics or similar locational tracking services, where you have agreed to the use of this particular service.
Where we collect data directly from you, we are considered to be the controller of that data i.e. we are the data controller. Where we use third parties to process your data, these parties are known as processors of your personal data. Where there are other parties involved in underwriting or administering your insurance they may also process your data in which circumstance we will be a joint data controller of your personal data.
A data ‘controller’ means the individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data.
A data ‘processor’ means the individual or organisation which processes personal data on behalf of the controller.
As a provider of insurance services, we will process the following categories of data:
If you object to the collection, sharing and use of your personal data we may be unable to provide you with our products and services.
For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the named territory where the processing of personal data takes place.
If you require more information about our insurance processes or further details on how we collect personal data and with whom we share data with, please contact our data privacy representative by e-mailing Siobhan.Fogarty@gs-group.uk.com
Why do we need your personal data?
We will use your personal data for the performance of our contract with you, to quote for and provide you with insurance products and services, to process claims and renewals, to administer your policy and our business, to respond to any requests from you about services we provide and to process complaints.
We will also use your personal data to manage your account, perform statistical analysis on the data we collect, for financial planning and business forecasting purposes and to develop new and market existing products and services.
We will use the special category and criminal conviction data we collect about you for the performance of our contract with you which is deemed to be necessary for reasons of substantial public interest. This allows us to quote for and provide you with insurance products and services, to process claims and renewals and to administer your policy.
In purchasing our products and services you should understand that you are forming a contract with us. If you contact us for a quote or request details on the services we provide, we consider ourselves as having a legitimate business interest to provide you with further information about our services.
In some situations we may request your consent to market our products and services to you, to share your data. Where we require consent, your rights and what you are consenting to will be clearly communicated to you. Where you provide consent, you can withdraw this at any time by contacting our data privacy representative Siobhan.Fogarty@gs-group.uk.com
We will retain your personal data at the end of any contractual agreement for a period of 1 year. We will retain special category and criminal conviction data for a period of 10 years. Where you have submitted a claim, we will retain your data for a period of 6 years if it is a non-injury claim; where an individual has been injured (physical and physiological), we will retain your data for 3 years. Where you have requested a quote, we will retain your personal data for 12 months, where you have contacted us for details of our services and products, we will retain your personal data for 12 months. Where you make a complaint we will retain the data for 12 months. Where you or law enforcement agencies inform us about any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data.
The retaining of data is necessary where required for contractual, legal or regulatory purposes or for our legitimate business interests for statistical analysis (profiling) and product development and marketing purposes.
Sometimes we may need to retain your data for longer, for example if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future claim may occur.
Please contact our data privacy representative Siobhan.Fogarty@gs-group.uk.com if you object to the use of, or you have any questions relating to the use of, your data, the retention of your personal data You can opt out of receiving marketing services by e-mailing Siobhan.Fogarty@gs-group.uk.com
Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.
These rights are known as Individual Rights under the Data Protection Act 2018. The following list details these rights:
Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests, however if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.
In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request, for example if you make a request for us to delete all your personal data, we may be required to retain some data for taxation, prevention of crime and for regulatory and other statutory purposes.
You should understand that when exercising your rights, a substantial public or vital interest may take precedence over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health related matters.
The flow of data within the insurance sector is complex and we ask you to keep this in mind when exercising your ‘rights of access’ to your information. Where we may be reliant on other organisations to help satisfy your request this may impact on timescales.
If you require further information on your Individual Rights or you wish to exercise your Individual Rights, please contact our data privacy representative by e-mailing Siobhan.Fogarty@gs-group.uk.com or by writing to Siobhan Fogarty, GS Group, 5th Floor, 98 W George St, Glasgow G2 1PJ
Protecting your data
We will take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data within our group of companies, business, including affiliates, subsidiaries and authorised third parties.
Data Privacy Representative
To ensure data privacy and protection has appropriate focus within our organisation we have a Data Privacy Representative who reports to our senior management team. The Data Privacy Representative’s contact details are as follows: Siobhan Fogarty on 0141 404 5416 or 07470 576 223 or at Siobhan.Fogarty@gs-group.uk.com
If you are dissatisfied with any aspect of the way in which we process your personal data please contact data privacy representative. You also have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office(ICO). The ICO may be contacted via its website which is https://ico.org.uk/concerns/, by live chat or by calling their helpline on 0303 123 1113.
How to contact us
If you have any questions regarding this Notice, the use of your data or your Individual Rights please contact our data privacy representative Norrelle King at The Exchange, 142 St Vincent Street, Glasgow, G2 5LA or by e-mailing Siobhan.Fogarty@gs-group.uk.com or telephoning on 0141 404 5416 or 07470 576 223.