Trade Direct Insurance Services Ltd Privacy Notice

Trade Direct Insurance Services Ltd acts in the capacity of the data controller and will treat all your personal information as private and confidential, even when you are no longer a customer in accordance with the Data Protection Act 2018 and subsequent legislation.

Our contact details for data protection purposes are:

Trade Direct Insurance Services Ltd
Mill Pool House
Mill Lane
Godalming
Surrey
GU7 1EY

Tel: 01483 521 650
E-mail: dpo@tradeinsurance.co.uk 

How we collect personal information

We may collect personal information directly from you when you:

• request a quotation;
• purchase, amend or renew an insurance policy;
• submit an enquiry through our website;
• contact us by telephone, email or post;
• register for marketing communications;
• make a complaint; or
• notify or submit a claim.

We may also obtain personal information from third parties where permitted by law, including insurers, delegated authorities, premium finance providers, fraud prevention agencies, credit reference agencies, claims handlers, loss adjusters and publicly available sources.

Personal information we may collect

Depending on the products and services you use, we may collect and process:

• identity and contact information, including your name, address, date of birth, telephone number and email address;
• quotation, policy, underwriting, renewal and claims information;
• financial and payment information, including details needed to arrange premium finance;
• credit and fraud-prevention information;
• technical information, including IP address, device information and website usage data;
• correspondence, call recordings and communication records;
• complaint information; and
• special category personal data or criminal offence data where relevant and lawful for insurance purposes.

Further information regarding website cookies and tracking technologies is available within our Cookie Policy.

Why we use personal information and our lawful basis

We use personal information only where there is a lawful basis. The basis may vary according to the activity and circumstances.

 

Purpose	Examples	Lawful Basis
Quotation and placement	Obtaining information, assessing needs, providing quotes and arranging cover.	Steps before entering into a contract; performance of a contract.
Policy administration	Issuing documents, processing payments, renewals, amendments and customer service.	Performance of a contract; legitimate interests.
Legal and regulatory compliance	FCA obligations, complaints, financial crime controls, tax, audit and record keeping.	Legal obligation; legitimate interests.
Claims and dispute handling	Supporting notification, investigation and administration of claims and disputes.	Performance of a contract; legal obligation; legitimate interests.
Credit and fraud checks	Assessing instalment-payment requests and preventing or detecting fraud.	Legitimate interests; legal obligation; contract where applicable.
Service improvement	Quality assurance, call monitoring, analytics and improving products and services.	Legitimate interests.
Marketing	Providing information about relevant products and services.	Consent, or legitimate interests where permitted by law.

 

Where we rely on legitimate interests, these include operating and improving our business, fraud prevention, information security, customer service, quality monitoring, defending legal claims and ensuring regulatory compliance. We balance these interests against your rights and freedoms before processing takes place.

Where we process special category personal data or criminal offence data, we will rely on an additional condition permitted by UK data protection law, including where processing is necessary for insurance purposes, the establishment, exercise or defence of legal claims, or where another relevant legal condition applies.

If you do not provide information that is required to provide a quotation, arrange cover, administer a policy or comply with legal or regulatory obligations, we may be unable to provide the relevant product or service.

Credit reference and insurer checks

We may share information with credit reference agencies for the purpose of arranging payment by instalments and may provide information about your payment record. Insurers may also use information supplied during the quotation process to carry out credit or other checks through credit reference agencies or similar sources. A search may appear on your credit record even if you do not proceed with a policy.

Who we may share personal information with

Where necessary and lawful, we may share personal information with:

• insurers, underwriters and delegated authorities;
• premium finance providers, banks and payment service providers;
• credit reference and fraud prevention agencies;
• claims handlers, loss adjusters, repairers, medical experts and legal representatives;
• professional advisers, auditors and technology or administration service providers;
• regulators, law enforcement bodies, courts and other public authorities where required;
• other companies within the Kelliher Insurance Group where relevant to the service provided; and
• customer feedback and service providers acting on our behalf, including Trustpilot and Optimise, where applicable.

Recipients must process personal information for the agreed purpose and in accordance with applicable data protection requirements. We will not sell personal information.

International transfers

Most personal information is processed within the UK and EEA, although some technology providers and service partners may process information internationally. Where personal information is transferred internationally, we will use a lawful transfer mechanism and appropriate safeguards, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another mechanism permitted by UK data protection law.

Email and electronic communications

Where you provide an email address, we may use it to communicate with you about quotations, policies, renewals and other insurance-related matters. This processing is undertaken as part of providing the requested service and is not based solely on consent.

Email is not a completely secure means of transmission. If you have concerns about sending information electronically or would prefer another communication method, please contact us so that available alternatives can be discussed.

How long we keep personal information

We retain personal information only for as long as necessary for the purpose for which it was collected and to meet legal, regulatory and legitimate business requirements. Retention periods vary according to the type of record, policy, claim, complaint and applicable limitation or regulatory period.

At the end of the applicable retention period, personal information will be securely deleted or anonymised unless a lawful reason requires it to be kept for longer. Requests for erasure are considered in light of these obligations and do not create an automatic right to deletion in every case.

Accuracy and renewals

We may ask you to confirm that the personal information we hold is accurate when a policy is renewed or otherwise reviewed. Please tell us promptly if your information changes or if you believe any information we hold is inaccurate or incomplete.

Your data protection rights

Subject to the conditions and exemptions in UK data protection law, you may have the right to:

• request access to personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request erasure of personal information in certain circumstances;
• request restriction of processing in certain circumstances;
• object to processing based on legitimate interests;
• object at any time to direct marketing;
• request data portability where the right applies;
• withdraw consent at any time where processing relies on consent, without affecting processing carried out before withdrawal; and
• request human intervention or challenge a decision where applicable safeguards relating to solely automated decision-making apply.

To exercise a right, contact us using the details in section 1. We may need to verify your identity before acting on a request.

Automated decision-making and profiling

Insurers, premium finance providers, fraud prevention agencies or other providers may use automated processes as part of underwriting, pricing, credit assessment or fraud prevention. Where a decision is made solely by automated means and produces legal or similarly significant effects, you will be provided with information about the process and the safeguards and rights that apply.

Marketing communications

Where you have consented, or where another lawful basis permits, we may contact you by email, telephone, post or SMS/text with information about insurance products and services that may be relevant to you. This may include communications from Business Direct Insurance Services Limited or, where you have agreed, other Kelliher Insurance Group companies.

You can withdraw consent, object to direct marketing or update your preferences at any time by contacting us or using the unsubscribe method provided in a marketing communication. Stopping marketing will not affect service messages concerning an existing quotation, policy, claim or complaint.

Complaints

If you are unhappy with how your personal information has been handled, please contact Trade Direct Insurance Services Ltd at complaints@kelliherinsurance.co.uk or on 020 7623 4957. We will handle the matter under our Complaints Policy and Procedure.

You also have the right to complain to the Information Commissioner’s Office. The Information Commissioner’s Office can be contacted through its website, by telephone or by post. You may complain to the Information Commissioner’s Office without first complaining to us, although we would welcome the opportunity to address your concern.

For data protection enquiries please contact our Data Protection Team at dpo@tradeinsurance.co.uk.