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EN
1. Home•
2. Privacy and cookies
About this website
PRIVACY AND COOKIES
1. About Liberty Specialty Markets
2. About the insurance market
3. Our processing of your personal and special category data
3.1. Prospective policyholders or beneficiaries
3.2. Policyholder or beneficiary under an insurance policy
3.3. Third party claimant
3.4. Witnesses to an incident
3.5. Brokers, appointed representatives, suppliers and other business partners
3.6. Users of the Liberty Specialty Markets websites or platforms and event
attendees
3.7. Prospective job applicants
4. What marketing and/or profiling activities do we carry out?
5. How long do we keep personal data for?
6. What is our approach to sending your personal data overseas?
7. How do we protect your personal data?
8. Your rights
9. Cookies
10. Contacting us
11. Updates to this privacy & cookies notice
Liberty Specialty Markets takes the protection of your personal data seriously
and is committed to protecting your privacy. This Privacy Notice sets out
details of the information that we may collect from you and how we may use that
information. Please take your time to read this notice carefully. When using a
Liberty Specialty Markets website, this notice should be read alongside the
website terms and conditions.
1. ABOUT LIBERTY SPECIALTY MARKETS
Liberty Specialty Markets is an international insurance business. We offer
insurance to individuals, companies and other insurers.
In order for us to deliver insurance services which involve providing you with a
quote and then insurance, and dealing with any claims or complaints that might
arise, we need to collect and process data. We also collect your information
for recruitment purposes, in our contractual relationships with you and for
relationship development, where appropriate. This makes us a "data controller".
Liberty Specialty Markets is comprised of a number of data controllers depending
on the interaction you have with us or the policy written.
* If you are contacting us for recruitment purposes then Liberty Specialty
Markets Limited and/or Liberty Specialty Markets Europe Sarl will be the data
controllers for your personal data.
* If you are a broker, customer, supplier, contractual counterparty or other
third party then one of the following will be the data controllers of your
personal data:
* Liberty Managing Agency Limited (for and on behalf of the Underwriting
Members of Lloyd’s Syndicate 4472) and/or
* Liberty Mutual Insurance Europe SE and/or
* Liberty Specialty Markets Europe S.a.r.L and/or
* Liberty Specialty Markets Europe Two S.a.r.L and/or
* Liberty Mutual Reinsurance (a division of Liberty Mutual Insurance Company)
and/or
* Liberty Specialty Markets MENA Limited and/or
* Liberty Specialty Markets Bermuda Limited and/or
* Liberty Specialty Markets Agency Limited.
Any documentation you receive may state any of our trading names, including
Liberty Specialty Markets, Liberty Mutual Reinsurance, Global Transaction
Solutions or Liberty Mutual Surety. The specific company acting as a data
controller of your personal data will be listed in the in the documentation we
provide to you.
If you are a customer residing in California, please view the relevant
supplementary privacy notice here.
If you are unsure about who the data controller of your personal data is, you
can also contact us at any time by e-mailing us at
dataprotectionofficer@libertyglobalgroup.com or by writing to Data Protection
Officer, Liberty Specialty Markets, 20 Fenchurch Street, London, EC3M 3AW.
2. ABOUT THE INSURANCE MARKET
Insurance involves the use and disclosure of your personal data by various
insurance market participants such as intermediaries, insurers and reinsurers.
The London Insurance Market Core Uses Information Notice sets out those core
necessary personal data uses and disclosures. Our core uses and disclosures are
consistent with the London Market Core Uses Information Notice. We recommend you
review this notice (by clicking the link above).
3. OUR PROCESSING OF YOUR PERSONAL AND SPECIAL CATEGORY DATA
The types of personal data that we collect and our uses of that personal data
will depend on our relationship with you. For example, we will collect different
personal data depending on whether you are a policyholder, a beneficiary under
an insurance policy, a claimant, a witness, a broker, a potential employee or
another third party.
Sometimes we will request or receive your “sensitive personal data” (which is
information relating to your health, genetic or biometric data, criminal
convictions, sex life, sexual orientation, racial or ethnic origin, political
opinions, religious or philosophical beliefs, trade union membership). For
example we may need access to information about your health in order to provide
you with a quote, provide your insurance policy, or process any claims you make.
We may also need details of any unspent criminal convictions you have for fraud
prevention purposes.
This notice sets out the legal grounds enabling us to process your personal and
special category data. There are different requirements in different
jurisdictions for processing special category data. For example, in England, we
are able to process special category data where it is necessary to provide
insurance services to you. In other jurisdictions, we require your explicit
consent. Where the tables below note that special category data will be
processed for the purposes of providing insurance, this only applies to our data
controllers subject to English, Irish, Dutch or Spanish law law (this will be
clear from the documentation supplied to you).
Where the provision of information is legally or contractually required, we will
tell you this at the time of collection.
Where you provide personal data to us about other individuals (for example,
members of your family) we will also be data controller of and responsible for
their personal data. You should refer them to this notice before supplying us
data on behalf of others.
We may amend the personal data so that you cannot be identified from the data
either by itself or when combined with any other data we hold. That data will
then not be subject to this notice or data protection law.
In order to make this notice as user friendly as possible, we have split it into
different sections. The notice is available in different languages to reflect
our global presence. Please click on the section below that best describes
your relationship with us.
3.1. PROSPECTIVE POLICYHOLDERS OR BENEFICIARIES
If you apply for an insurance policy or where someone else (such as a family
member or your employer) applies for an insurance policy which will benefit you,
this section will be relevant to you and sets out our uses of your personal
data.
What personal data will we collect?
* General information such as your name, address, contact phone numbers and
email addresses, date of birth and gender.
* Information about your relationship to the policyholder where you are the
beneficiary.
* Identification information such as passport details, driving licence and
national insurance number.
* Your bank and payment details.
* If relevant, information about your job such as job title, employment history
and professional accreditations.
* Any financial information about you which we have obtained as a result of
conducting credit checks such as bankruptcy orders, individual voluntary
arrangements or country court judgments.
* Information which we obtain as part of checking sanctions lists, such as
those published by United Nations, European Union, UK Treasury, the U.S.
Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce,
Bureau of Industry and Security .
* Any information which is relevant to your insurance application such as
previous insurance policies you have held and claims you have made. This will
also include any information specific to the type of policy you are applying
for, for example, if you are applying for a fine art policy we may collect
and use information which relates to your art collection.
* Information which we have gathered from publically available sources such as
the electoral roll, newspapers and social media sites.
* Any other information passed on from you, your insurance broker or someone
else applying on your behalf.
What sensitive personal data will we collect?
* Details about your criminal convictions and any related information. This
will include information relating to any offences or alleged offences you
have committed or any court sentences which you are subject to.
* Details about your physical and mental health which are relevant to your
application (e.g. if you take out or are covered by a personal accident
policy, we may need details of pre-existing medical conditions). This may
take the form of medical reports or underlying medical data such as x-rays or
blood tests.
* We may also collect information because it is relevant to your application,
which reveals or is likely to reveal your race or ethnicity, religious or
philosophical beliefs; political opinions; trade union membership; genetic or
biometric data; or data concerning your sex life or sexual orientation. For
example, we may process information relating to your trade union membership
if you take out a policy with us via your trade union body, as we can
determine that you are a member of a trade union or where you specify certain
medical treatments, this could indicate your religious beliefs.
How will we collect your personal data?
We will collect information directly from you:
* when you apply for or renew a policy;
* when we are providing you with a quotation;
* when you contact us by email, telephone and through other written and verbal
communications; and
* when you contact our third party administrators by telephone (please note
that call recording may be used).
As well as obtaining information directly from you, we will collect information
from:
* The applicant where you are a beneficiary or named under an insurance policy;
* Third parties involved in the insurance application process (such as our
business partners and representatives, brokers or other insurers).
* Publically available sources such as the electoral roll, court judgments,
insolvency registers, internet search engines, news articles and social media
sites.
* Other Liberty Mutual Insurance Group companies.
* Credit reference agencies in relevant jurisdictions e.g. CallCredit, Equifax
and Experian are the credit reference agencies in the UK
Financial crime detection agencies and insurance industry databases (such as for
fraud prevention and checking against international sanctions) including the
Claims Underwriting Exchange (known as "CUE") operated by IDS and the Motor
Insurance Anti-Fraud and Theft Register operated by the Association of British
Insurers.
What will we use your personal data for?
We may use your personal data for a number of different purposes. In each case,
we must have a "legal ground" to do so. We will rely on the following “legal
grounds”, when we process your "personal data":
* We need to use your personal data to enter into or perform the insurance
contract that we hold with you. For example, we need to use your personal
data to provide you with a quote.
* We have a legal or regulatory obligation to use such personal data. For
example, our regulators require us to hold certain records of our dealings
with you.
* We need to use your personal data for a legitimate interest (e.g. to keep a
record of the decisions we make when different types of applications are
made, to keep business records, to carry out strategic business analysis,
review our business planning and to develop and improve our products and
services). When using your personal data for these purposes, we will always
consider your rights and interests.
When the information that we process is classed as “sensitive personal data", we
must have an additional “legal ground". We will rely on the following legal
grounds when we process your "sensitive personal data":
* We need to use your sensitive personal data for purposes relating to an
insurance policy or claim and there is a substantial public interest in such
use. Such purposes include assessing your insurance application, managing
claims and preventing and detecting fraud.
* We need to use such sensitive personal data to establish, exercise or defend
legal rights. This might happen when we are faced with legal proceedings or
want to bring legal proceedings ourselves or when we are investigating a
legal claim that a third party brings against you.
* We need to use such special category data for a justifiable public interest
purpose on the basis of a legal requirement (e.g. security scanning of email
contents to detect cyber threats)
* You have provided your consent to our use of your sensitive personal data
(e.g. in relation to your claim). In some circumstances, we may need your
consent to process sensitive personal data (e.g. health information). Without
it, we may be unable to offer you an insurance policy. We will always explain
why your consent is necessary.
Purpose for processing
Legal grounds for using your personal data
Legal grounds for using your sensitive personal data
Purpose for processing
To evaluate prospective clients, including carrying out fraud, credit and
anti-money laundering checks.
Legal grounds for using your personal data
* It is necessary to enter into your insurance contract.
* We have a legitimate interest (to assess the insurance application).
Legal grounds for using your sensitive personal data
* It is in the substantial public interest to prevent or detect unlawful acts
(where we suspect fraud).
* Such use is necessary for insurance purposes.
* We need to establish, exercise or defend legal rights.
* You have given us your explicit consent.
Purpose for processing
To manage and handle your insurance application and queries.
Legal grounds for using your personal data
* It is necessary to enter into or perform your insurance contract.
* We have a legitimate interest (to assess the insurance application).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent. We will need your consent before we
can provide your policy.
* Such use is necessary for insurance purposes.
Purpose for processing
To provide improved quality, training and security (for example, through
recorded or monitored phone calls to our contact numbers, or carrying out
customer satisfaction surveys).
Legal grounds for using your personal data
We have a legitimate interest (to develop and improve the products and services
we offer).
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Purpose for processing
To comply with our legal or regulatory obligations.
Legal grounds for using your personal data
We need to use your information in order to comply with our legal obligations.
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* We need to use your information in order to establish, exercise or defend
legal rights.
Purpose for processing
For business and management processes and activities including analysis, review,
planning, business transaction and IT hosting, support and security.
Legal grounds for using your personal data
We have a legitimate interest (to effectively manage our business).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* We need to use your information in order to establish, exercise or defend
legal rights.
* Such use is necessary in the substantial public interest.
Purpose for processing
For insurance administration purposes including analysis of trends, carrying
out actuarial work, planning service delivery, risk assessment and costs and
charges.
Legal grounds for using your personal data
We have a legitimate interest (to develop and improve the products and services
we offer).
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Who will we share your personal data with?
We will keep your personal data confidential and we will only share it where
necessary for the purposes set out above with the following parties:
* Other Liberty Mutual Insurance Group companies (both inside and outside the
European Economic Area) and their service providers.
* Third parties involved in the administration of your insurance application.
These include surveyors, valuers and other experts.
* Other insurers (e.g. where another insurer has previous provided you with a
policy or handled a claim).
* Insurance brokers and other intermediaries.
* Other insurers who provide our own insurance (reinsurers) and companies who
arrange such reinsurance.
* Credit reference agencies in relevant jurisdictions e.g. CallCredit, Equifax
and Experian are the credit reference agencies in the UK
* Third parties who provide sanctions checking services.
* Insurance industry bodies (including the Employers’ Liability Tracing Office
and the Association of British Insurers).
* Financial crime detection agencies and insurance industry databases (such as
for fraud prevention and checking against international sanctions) including
the Claims Underwriting Exchange (known as "CUE") operated by IDS and the
Motor Insurance Anti-Fraud and Theft Register operated by the Association of
British Insurers.
* Our regulators including the Financial Conduct Authority, the Prudential
Regulation Authority and the Information Commissioner's Office.
* If relevant, your policy details will also be added to the Motor Insurance
Database (MID), run by the Motor Insurers’ Information Centre (MIIC).
* The police, HMRC and other crime prevention and detection agencies.
* Third party suppliers, agents and contractors appointed by Liberty Specialty
Markets or the Liberty Mutual Group to help us carry out our everyday
business activities including IT suppliers, actuaries, auditors, lawyers,
document management providers, outsourced business process management
providers, our subcontractors and tax advisers.
* Selected third parties in connection with any sale, transfer or disposal of
our business.
* Any agent or representative acting for you.
* Any other person where necessary to perform any insurance contract with you,
in order to protect ourselves from risk or to ensure regulatory compliance or
good governance.
3.2. POLICYHOLDER OR BENEFICIARY UNDER AN INSURANCE POLICY
If you take out an insurance policy with us (e.g. a fine art policy) or if you
are listed as an applicant or beneficiary under a policy that someone else has
with us (such as a named director under a Directors & Officers policy), this
section will be relevant to you and sets out our uses of your personal data.
What personal data will we collect?
* General information such as your name, address, contact phone numbers and
email addresses, date of birth and gender.
* Information about your relationship to the policyholder where you are the
beneficiary.
* Identification information such as passport details, driving licence and
national insurance number.
* Your bank and payment details.
* If relevant, information about your job such as job title, employment history
and professional accreditations.
* Any financial information about you which we have obtained as a result of
conducting credit checks, such as bankruptcy orders, individual voluntary
arrangements or county court judgments.
* Information which we obtain as part of checking sanctions lists, such as
those published by United Nations, European Union, UK Treasury, the U.S.
Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce,
Bureau of Industry and Security .
* Any information which is relevant to your insurance application such as
previous insurance policies you have held and claims you have made. This will
also include any information specific to the type of policy you are applying
for, for example, if you hold a property protection policy, we will collect
and use information about your property or if you hold a fine art policy, we
will collect and use information about your fine art or jewellery collection.
* Information (including photographic evidence) which is relevant to your
policy or claim. For example, if you make a claim following damage to your
property, we may use information relating to your property or if you make a
claim following a road traffic accident, we may use personal data relating to
your vehicle and named drivers.
* Information which we have gathered from publically available sources such as
the electoral roll, newspapers and social media sites.
* Any other information passed on from you, your insurance broker or someone
else applying on your behalf.
What sensitive personal data will we collect?
* Details about your criminal convictions and any related information. This
will include information relating to any offences or alleged offences you
have committed or any court sentences which you are subject to.
* Details about your physical and mental health which are relevant to your
policy or claim (e.g. if you are a pilot and take out or are covered by an
aviation policy, we may need details of pre-existing medical conditions).
This may take the form of medical reports or underlying medical data such as
x-rays or blood tests.
* We may also collect information because it is relevant to your policy or
claim, which reveals or is likely to reveal your race or ethnicity, religious
or philosophical beliefs; political opinions; trade union membership; genetic
or biometric data; or data concerning your sex life or sexual orientation.
For example, we may process information relating to your trade union
membership if you take out a policy with us via your trade union body, as we
can determine that you are a member of a trade union or where you specify
certain medical treatments, this could indicate your religious beliefs.
How will we collect your personal data?
We will collect information directly from you:
* when you apply for or renew a policy;
* when we are providing you with a quotation;
* when you make a claim on your policy;
* when you contact us by email, telephone and through other written and verbal
communications;
* when you contact our third party administrators by telephone (please note
that call recording may be used).
* when you make a complaint.
As well as obtaining information directly from you, we will collect information
from:
* The named policyholder where you are a beneficiary.
* Third parties involved in the relevant insurance policy or claim (such as our
business partners and representatives, brokers or other insurers, claimants,
defendants or witnesses to an incident).
* Third parties who provide a service in relation to the relevant insurance
policy or claim (such as loss adjusters, claims handlers, and medical
experts).
* Publically available sources such as the electoral roll, court judgments,
insolvency registers, internet search engines, news articles and social media
sites.
* Other Liberty Mutual Insurance Group companies.
* Third parties who provide sanctions checking services.
* Insurance industry bodies (including the Employers’ Liability Tracing Office
and the Association of British Insurers).
* Financial crime detection agencies and insurance industry databases (such as
for fraud prevention and checking against international sanctions) including
the Claims Underwriting Exchange (known as "CUE") operated by IDS and the
Motor Insurance Anti-Fraud and Theft Register operated by the Association of
British Insurers.
* Our regulators including the Financial Conduct Authority, the Prudential
Regulation Authority and the Information Commissioner's Office.
* If relevant, your policy details will also be added to the Motor Insurance
Database (MID), run by the Motor Insurers’ Information Centre (MIIC).
* The police, HMRC and other crime prevention and detection agencies.
* Third party suppliers we appoint to help us carry out our everyday business
activities including IT suppliers, actuaries, auditors, lawyers, document
management providers, outsourced business process management providers, our
subcontractors and tax advisers.
* Selected third parties in connection with any sale, transfer or disposal of
our business.
What will we use your personal data for?
We may use your personal data for a number of different purposes. In each case,
we must have a "legal ground" to do so. We will rely on the following “legal
grounds”, when we process your "personal data":
* We need to use your personal data to enter into or perform the insurance
contract that we hold with you. For example, we need to use your personal
data to provide you with a quote or to provide your insurance policy and
other associated products (e.g. legal expenses cover). We will rely on this
for activities such as assessing your application, managing your insurance
policy, handling claims and providing other products to you.
* We have a legal or regulatory obligation to use such personal data. For
example, our regulators require us to hold certain records of our dealings
with you.
* We need to use your personal data for a legitimate interest (e.g. to properly
investigate incidents which are the subject of a claim, to keep business
records, to carry out strategic business analysis, review our business
planning and to develop and improve our products and services). When using
your personal data for these purposes, we will always consider your rights
and interests.
When the information that we process is classed as “sensitive personal data", we
must have an additional “legal ground". We will rely on the following legal
grounds when we process your "sensitive personal data":
* In the UK, we need to use your sensitive personal data for purposes relating
to an insurance policy or claim and there is a substantial public interest in
such use. Such purposes include assessing your insurance application,
managing claims and preventing and detecting fraud.
* We need to use such sensitive personal data to establish, exercise or defend
legal rights. This might happen when we are faced with legal proceedings or
want to bring legal proceedings ourselves or when we are investigating a
legal claim that a third party brings against you.
* We need to use such special category data for a justifiable public interest
purpose on the basis of a legal requirement (e.g. security scanning of email
contents to detect cyber threats)
* You have provided your consent to our use of your sensitive personal data
(e.g. in relation to your claim). In some circumstances, we may need your
consent to process sensitive personal data (e.g. health information). Without
it, we may be unable to provide your policy or handle claims. We will always
explain why your consent is necessary.
Purpose for processing
Legal grounds for using your personal data
Legal grounds for using your sensitive personal data
Purpose for processing
To evaluate clients, including carrying out fraud, credit and anti-money
laundering checks on you.
Legal grounds for using your personal data
* It is necessary to enter into your insurance contract.
* We have a legitimate interest (to prevent fraud and other financial crime).
Legal grounds for using your sensitive personal data
* It is in the substantial public interest to prevent or detect unlawful acts
(where we suspect fraud).
* Such use is necessary for insurance purposes.
* We need to establish, exercise or defend legal rights.
* You have given us your explicit consent.
Purpose for processing
To manage and handle your insurance application and queries.
Legal grounds for using your personal data
* It is necessary to enter into or perform your insurance contract.
* We have a legitimate interest (to assess the insurance application and manage
the application process).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent. In some circumstances, we will need
your consent before we can provide your policy.
* Such use is necessary for insurance purposes.
Purpose for processing
To manage any claims you make under your insurance policy.
Legal grounds for using your personal data
* It is necessary to enter into or perform your insurance contract
* We have a legitimate interest (to assess and pay your claim and manage the
claims process).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent. In some circumstances, we will need
your consent before we can pay your claim.
* We need to use your information in order to establish, exercise or defend
legal rights.
* Such use is necessary for insurance purposes.
Purpose for processing
To prevent and investigate fraud.
Legal grounds for using your personal data
* It is necessary to enter into or perform your insurance contract.
* We have a legitimate interest (to prevent and detect fraud and other
financial crime).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent. In some circumstances, we will need
your consent before we can provide your policy or pay your claim.
* We need to use your information in order to establish, exercise or defend
legal rights.
Purpose for processing
To comply with our legal or regulatory obligations.
Legal grounds for using your personal data
* We need to use your information in order to comply with our legal
obligations.
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* We need to use your information in order to establish, exercise or defend
legal rights.
Purpose for processing
To communicate with you and resolve any complaints that you might have.
Legal grounds for using your personal data
* It is necessary to enter into or perform your insurance contract.
* We have a legitimate interest (to send you communications, record and
investigate complaints and ensure that future complaints and handled
appropriately).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* We need to use your information in order to establish, exercise or defend
legal rights.
* Such use is necessary for insurance purposes.
Purpose for processing
FTo provide improved quality, training and security (for example, through
recorded or monitored phone calls to our contact numbers, or carrying out
customer satisfaction surveys).
Legal grounds for using your personal data
* We have a legitimate interest (to develop and improve the products and
services we offer).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
Purpose for processing
For business and management processes and activities including analysis, review,
planning, business transaction and IT hosting, support and security.
Legal grounds for using your personal data
* We have a legitimate interest (to effectively manage our business).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* Such use is necessary in the substantial public interest
Purpose for processing
For insurance administration purposes including analysis of trends, carrying out
actuarial work, planning service delivery, risk assessment and costs and
charges.
Legal grounds for using your personal data
* We have a legitimate interest (to develop and improve the products and
services we offer).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
Purpose for processing
To apply for and claim on our insurance.
Legal grounds for using your personal data
* We have a legitimate interest (to ensure that we have appropriate insurance
in place).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent
* We need to use your information in order to establish, exercise or defend
legal rights.
Who will we share your personal data with?
We will keep your personal data confidential and we will only share it where
necessary for the purposes set out above with the following parties.
* Other Liberty Mutual Group companies and their service providers (both inside
and outside the European Economic Area).
* Third parties involved in the administration of the relevant insurance policy
or claim. These include loss adjusters, claims handlers, private
investigators, accountants, auditors, banks, lawyers and other experts
including medical experts.
* Other insurers (e.g. where another insurer has previous provided you with a
policy or handled a claim).
* Insurance brokers and other intermediaries.
* Other insurers who provide our own insurance (reinsurers) and companies who
arrange such reinsurance.
* Credit reference agencies in relevant jurisdictions e.g. CallCredit, Equifax
and Experian are the credit reference agencies in the UK
* Third parties who provide sanctions checking services.
* Insurance industry bodies (including the Employers’ Liability Tracing
Office).
* Financial crime detection agencies and insurance industry databases (such as
for fraud prevention and checking against international sanctions) including
the Claims Underwriting Exchange (known as "CUE") operated by IDS and the
Motor Insurance Anti-Fraud and Theft Register operated by the Association of
British Insurers.
* Our regulators including the Financial Conduct Authority, the Prudential
Regulation Authority and the Information Commissioner's Office.
* The police, HMRC and other crime prevention and detection agencies.
* If relevant, your policy details will also be added to the Motor Insurance
Database (MID), run by the Motor Insurers’ Information Centre (MIIC).
* Third party suppliers, agents and contractors appointed by Liberty Specialty
Markets or the Liberty Mutual Group to help us carry out our everyday
business activities including IT suppliers, actuaries, auditors, lawyers,
document management providers, outsourced business process management
providers, our subcontractors and tax advisers.
* Selected third parties in connection with any sale, transfer or disposal of
our business.
* Any agent or representative acting for you.
* Any other person where necessary to perform any insurance contract with you,
in order to protect ourselves from risk or to ensure regulatory compliance or
good governance.
3.3. THIRD PARTY CLAIMANT
If you make a claim against a third party who has an insurance policy with us,
this section will be relevant to you and sets out our uses of your personal
data.
What personal data will we collect?
* General information such as your name, address, contact phone numbers and
email addresses, date of birth and gender.
* Identification information such as passport details, driving licence and
national insurance number.
* Your bank and payment details.
* If relevant to your claim, we may collect information about your job such as
job title, employment history and professional accreditations.
* Information which we obtain as part of checking sanctions lists, such as
those published by United Nations, European Union, UK Treasury, the U.S.
Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce,
Bureau of Industry and Security .
* Information relating to previous insurance policies you have held and claims
you have made.
* Information (including photographic evidence) which is relevant to your
claim. For example, if you make a claim following damage to your property, we
may use information relating to your property or if you make a claim
following a road traffic accident, we may use personal data relating to your
vehicle and named drivers.
* Information which we have gathered from publically available sources such as
the electoral roll, newspapers and social media sites.
* Any other information passed on from you, your representative or someone else
making the claim on your behalf.
What sensitive personal data will we collect?
* Details about your criminal convictions and any related information. This
will include information relating to any offences or alleged offences you
have committed or any court sentences which you are subject to.
* Details about your physical and mental health which are relevant to your
claim (e.g. because you have been injured whilst at a property insured by
us). This may take the form of medical reports or underlying medical data
such as x-rays or blood tests.
* We may also collect information because it is relevant to your claim, which
reveals or is likely to reveal your race or ethnicity, religious or
philosophical beliefs; political opinions; trade union membership; genetic or
biometric data; or data concerning your sex life or sexual orientation.
How will we collect your personal data?
We will collect information directly from you:
* when you make a claim;
* when you contact us by email, telephone and through other written and verbal
communications;
* when you contact our third party administrators by telephone (please note
that call recording may be used).
* when you make a complaint.
As well as obtaining information directly from you, we will collect information
from:
* The party who holds a policy with us.
* Third parties involved in the insurance policy or claim (such as our business
partners and representatives, brokers or other insurers, claimants,
defendants or witnesses to an incident).
* Third parties who provide a service in relation to the claim (such as loss
adjusters, claims handlers, and experts).
* Publically available sources such as the electoral roll, court judgements,
insolvency registers, internet search engines, news articles and social media
sites.
* Other Liberty Mutual Insurance Group companies.
* Financial crime detection agencies and insurance industry databases (such as
for fraud prevention and checking against international sanctions) including
the Claims Underwriting Exchange (known as "CUE") operated by IDS and the
Motor Insurance Anti-Fraud and Theft Register operated by the Association of
British Insurers. Government agencies such as the police, the National Crime
Agency, the DVLA or HMRC.
* In limited circumstances, private investigators.
What will we use your personal data for?
We may use your personal data for a number of different purposes. In each case,
we must have a "legal ground" to do so. We will rely on the following “legal
grounds”, when we process your "personal data":
* We have a legal or regulatory obligation to use such personal data. For
example, our regulators require us to hold certain records of our dealings
with you.
* We need to use your personal data for a legitimate interest (e.g. to properly
investigate incidents which are the subject of a claim, to keep business
records, to carry out strategic business analysis, review our business
planning and to develop and improve our products and services). When using
your personal data for these purposes, we will always consider your rights
and interests.
When the information that we process is classed as “sensitive personal data", we
must have an additional “legal ground". We will rely on the following legal
grounds when we process your "sensitive personal data":
* In the UK, we need to use your sensitive personal data for purposes relating
to an insurance policy or claim and there is a substantial public interest in
such use. Such purposes include managing claims and preventing and detecting
fraud.
* We need to use such sensitive personal data to establish, exercise or defend
legal rights. This might happen when we are faced with legal proceedings or
want to bring legal proceedings ourselves or we are considering the claim
that has been made against our policyholder.
* We need to use such special category data for a justifiable public interest
purpose on the basis of a legal requirement (e.g. security scanning of email
contents to detect cyber threats)
* You have provided your consent to our use of your personal data. In some
circumstances, we may need your consent to process sensitive personal data
(e.g. health information). Without it, we may be unable to handle your
claims. We will always explain why your consent is necessary.
Purpose for processing
Legal grounds for using your personal data
Legal grounds for using your sensitive personal data
Purpose for processing
To manage claims.
Legal grounds for using your personal data
* We have a legitimate interest (to assess and pay your claim and manage the
claims process).
* We need to use your information in order to comply with our legal
obligations.
Legal grounds for using your sensitive personal data
* You have given us your explicit consent. In some cases, we will need your
consent before we can pay your claim.
* We need to use your information in order to establish, exercise or defend
legal rights
* Such use is necessary for insurance purposes.
Purpose for processing
To prevent and investigate fraud.
Legal grounds for using your personal data
We have a legitimate interest (to prevent and detect fraud and other financial
crime).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent. In some cases, we will need your
consent before we can pay your claim.
* We need to use your information in order to establish, exercise or defend
legal rights.
Purpose for processing
To comply with our legal or regulatory obligations.
Legal grounds for using your personal data
We need to use your information in order to comply with our legal obligations.
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* We need to use your information in order to establish, exercise or defend
legal rights.
* Such use is necessary for insurance purposes.
Purpose for processing
To provide improved quality, training and security (for example, through
recorded or monitored phone calls to our contact numbers, or carrying out
customer satisfaction surveys).
Legal grounds for using your personal data
We have a legitimate interest (to develop and improve the products and services
we offer).
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Purpose for processing
For business and management processes and activities including analysis, review,
planning, business transaction and IT hosting, support and security.
Legal grounds for using your personal data
* We have a legitimate interest (to effectively manage our business).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* Such use is necessary in the substantial public interest.
Purpose for processing
For insurance administration purposes including analysis of trends, carrying out
actuarial work, planning service delivery, risk assessment and costs and
charges.
Legal grounds for using your personal data
We have a legitimate interest (to effectively manage our business).
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Purpose for processing
To apply for and claim on our own insurance.
Legal grounds for using your personal data
We have a legitimate interest (to ensure that we have appropriate insurance in
place).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* We need to use your information in order to establish, exercise or defend
legal rights.
Who will we share your personal data with?
We will keep your personal data confidential and we will only share it where
necessary for the purposes set out above with the following parties.
* Other Liberty Mutual Insurance Group companies (both inside and outside the
European Economic Area) and their service providers.
* Third parties involved in the administration of your claim such as loss
adjusters, claims handlers, private investigators, accountants, auditors,
banks, lawyers and other experts including medical experts.
* Other insurers (e.g. where another insurer is also involved in a claim that
you are making).
* Insurance brokers and other intermediaries.
* Other insurers who provide our own insurance (reinsurers) and companies who
arrange such reinsurance.
* Insurance industry bodies (including the Employers’ Liability Tracing
Office).
* Third parties who provide sanctions checking services.
* Insurance industry bodies (including the Employers’ Liability Tracing
Office).
* Financial crime detection agencies and insurance industry databases (such as
for fraud prevention and checking against international sanctions) including
the Claims Underwriting Exchange (known as "CUE") operated by IDS and the
Motor Insurance Anti-Fraud and Theft Register operated by the Association of
British Insurers.
* Our regulators including the Financial Conduct Authority, the Prudential
Regulation Authority and the Information Commissioner's Office.
* The police, HMRC and other crime prevention and detection agencies.
* If relevant, your policy details will also be added to the Motor Insurance
Database (MID), run by the Motor Insurers’ Information Centre (MIIC).
* Third party suppliers, agents and contractors appointed by Liberty Specialty
Markets and the Liberty Mutual Group to help us carry out our everyday
business activities including IT suppliers, actuaries, auditors, lawyers,
document management providers, outsourced business process management
providers, our subcontractors and tax advisers.
* Selected third parties in connection with any sale, transfer or disposal of
our business.
* Any agent or representative acting for you.
* Any other person where necessary to perform any insurance contract with you,
in order to protect ourselves from risk or to ensure regulatory compliance or
good governance.
3.4. WITNESSES TO AN INCIDENT
If you are a witness to an incident which is the subject of a claim, this
section will be relevant to you and sets out our uses of your personal data.
What personal data will we collect?
* General information such as your name, address, contact phone numbers and
email addresses, date of birth and gender.
* Information relevant to the incident that you have witnessed.
What sensitive personal data will we collect?
It is not standard practice to collect special category data of witnesses to an
accident. However, if you are involved in the accident and your details are
supplied to us (for example, within a medical report) we might process your
sensitive personal data.
How will we collect your information?
As well as obtaining information directly from you, we will collect information
from:
* Third parties involved in the incident you witnessed (such as brokers or
other insurers, claimants, defendants or other witnesses).
* Other third parties who provide a service in relation to the claim which
relates to the incident you witnessed (such as loss adjusters, claims
handlers, and experts).
* Publically available sources such as the electoral roll, court judgments,
insolvency registers, insurance industry databases, internet search engines,
news articles and social media sites.
* Other companies within the Liberty Mutual Insurance Group.
What will we use your personal data for?
We may use your personal data for a number of different purposes. In each case,
we must have a "legal ground" to do so. We will rely on the following “legal
grounds”, when we process your "personal data":
* We have a legal or regulatory obligation to use such personal data. For
example, our regulators require us to hold certain records of our dealings
with you.
* We need to use your personal data for a legitimate interest (e.g. to properly
investigate incidents which are the subject of a claim, to keep business
records, to carry out strategic business analysis, review our business
planning and to develop and improve our products and services). When using
your personal data for these purposes, we will always consider your rights
and interests.
When the information that we process is classed as “sensitive personal data", we
must have an additional “legal ground". We will rely on the following legal
grounds when we process your "sensitive personal data":
* In the UK, we need to use your sensitive personal data for purposes relating
to an insurance policy or claim and there is a substantial public interest in
such use. Such purposes include managing claims and preventing and detecting
fraud.
* We need to use such sensitive personal data to establish, exercise or defend
legal rights. This might happen when we are faced with legal proceedings or
want to bring legal proceedings ourselves.
* We need to use such special category data for a justifiable public interest
purpose on the basis of a legal requirement (e.g. security scanning of email
contents to detect cyber threats)
* You have provided your consent to our use of your sensitive personal data.
Purpose for processing
Legal grounds for using your personal data
Legal grounds for using your sensitive personal data
Purpose for processing
To investigate and manage claims made under an insurance policy.
Legal grounds for using your personal data
We have a legitimate interest (to assess and pay claims and manage the claims
process).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* We need to use your information in order to establish, exercise or defend
legal rights
* Such use is necessary for insurance purposes.
Purpose for processing
For business and management processes and activities including analysis, review,
planning, business transaction and IT hosting, support and security.
Legal grounds for using your personal data
We have a legitimate interest (to effectively manage our business).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* Such use is necessary in the substantial public interest.
Purpose for processing
To comply with our legal or regulatory obligations.
Legal grounds for using your personal data
We need to use your information in order to comply with our legal obligations.
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* We need to use your information in order to establish, exercise or defend
legal rights.
Purpose for processing
To prevent and investigate fraud.
Legal grounds for using your personal data
We have a legitimate interest (to prevent and detect fraud and other financial
crime).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* We need to use your information in order to establish, exercise or defend
legal rights.
* Such use is necessary for insurance purposes.
Who will we share your personal data with?
We will keep your personal data confidential and we will only share it where
necessary for the purposes set out above with the following parties:
* Other Liberty Group companies.
* Third parties involved in the administration of an insurance policy or claim.
These include loss adjusters, claims handlers, private investigators,
accountants, auditors, banks, lawyers and other experts including medical
experts.
* Other insurers (e.g. where another insurer is also involved in the claim
which relates to the incident you witnessed).
* Insurance brokers and other intermediaries.
* Other insurers who provide our own insurance (reinsurers) and companies who
arrange such reinsurance.
* Insurance industry bodies (including the Employers’ Liability Tracing
Office).
* Financial crime detection agencies and insurance industry databases (such as
for fraud prevention and checking against international sanctions) including
the Claims Underwriting Exchange (known as "CUE") operated by IDS and the
Motor Insurance Anti-Fraud and Theft Register operated by the Association of
British Insurers.
* Our regulators including the Financial Conduct Authority and the Prudential
Regulation Authority.
* The police, HMRC and other crime prevention and detection agencies.
* If relevant, your policy details will also be added to the Motor Insurance
Database (MID), run by the Motor Insurers’ Information Centre (MIIC).
* Third party suppliers, agents and contractors appointed by Liberty Specialty
Markets or the Liberty Mutual Group to help us carry out our everyday
business activities including IT suppliers, actuaries, auditors, lawyers,
document management providers, outsourced business process management
providers, our subcontractors and tax advisers.
* Selected third parties in connection with any sale, transfer or disposal of
our business.
* Any agent or representative acting for you.
* Any other person where necessary to perform any insurance contract with you,
in order to protect ourselves from risk or to ensure regulatory compliance or
good governance.
3.5. BROKERS, APPOINTED REPRESENTATIVES, SUPPLIERS AND OTHER BUSINESS PARTNERS
If you are a broker doing business with us, an appointed representative or other
business partner such as an introducer or supplier, this section will be
relevant to you and sets out our uses of your personal data.
What personal data will we collect?
* General information such as your name, address, contact phone numbers and
email addresses, date of birth and gender.
* Identification information such as passport details, driving licence and
national insurance number.
* Information about your job such as job title and previous roles.
* Information which we obtain as part of checking sanctions lists, such as
those published by United Nations, European Union, UK Treasury, the U.S.
Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce,
Bureau of Industry and Security .
* Other information (including publically available information) obtained as
part of our due diligence checks.
* If you attend an event with us, we may collect relevant details such as your
event preferences and dietary requirements.
What sensitive personal data will we collect?
* Information relating to your criminal convictions (including offences and
alleged offences and any court sentence or unspent criminal convictions).
* If you attend an event with us, we may collect dietary requirements which
could indicate a health condition or religious belief
How will we collect your information?
As well as obtaining information directly from you, we will collect information
from:
* Invoices, contracts, policies, correspondence and business cards
* Other Liberty Mutual Insurance Group companies.
* Publically available sources such as internet search engines.
* From service providers who carry out sanctions checks.
What will we use your personal data for?
We may use your personal data for a number of different purposes. In each case,
we must have a "legal ground" to do so. We will rely on the following “legal
grounds”, when we process your "personal data":
* We need to use your personal data to enter into or perform the contract that
we hold with you. For example, we may need certain information in order to
operate our business partnership arrangement.
* We have a legal or regulatory obligation to use such personal data. For
example, we may be required to carry out certain background checks.
* We need to use your personal data for a legitimate interest (e.g. to keep
business records, to carry out strategic business analysis, review our
business planning and to develop and improve our products and services). When
using your personal data for these purposes, we will always consider your
rights and interests.
When the information that we process is classed as “sensitive personal data", we
must have an additional “legal ground". We will rely on the following legal
grounds when we process your "sensitive personal data":
* We need to use your sensitive personal data for purposes relating to an
insurance policy or claim and there is a substantial public interest in such
use. Such purposes include assessing an insurance application, managing
claims and preventing and detecting fraud.
* We need to use your sensitive personal data to establish, exercise or defend
legal rights. This might happen when we are faced with legal proceedings or
want to bring legal proceedings ourselves.
* We need to use such special category data for a justifiable public interest
purpose on the basis of a legal requirement (e.g. security scanning of email
contents to detect cyber threats)
* You have provided your consent to our use of your sensitive personal data.
Purpose for processing
Legal grounds for using your personal data
Legal grounds for using your sensitive personal data
Purpose for processing
For business and management processes and activities including analysis, review,
planning, business transactions and IT hosting, support and security.
Legal grounds for using your personal data
We have a legitimate interest (to effectively manage our business).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* Such use is necessary in the substantial public interest.
Purpose for processing
To comply with our legal or regulatory obligations.
Legal grounds for using your personal data
We need to use your information in order to comply with our legal obligations.
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* We need to use your information in order to establish, exercise or defend
legal rights.
Purpose for processing
To write business and for claims handling.
Legal grounds for using your personal data
We have a legitimate interest (to effectively write policies and manage claims).
Legal grounds for using your sensitive personal data
Purpose for processing
For business development and relationship purposes.
Legal grounds for using your personal data
We have a legitimate interest (relationship management and business analysis).
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Purpose for processing
Providing improved quality, training and security (for example, through recorded
or monitored phone calls to our contact numbers).
Legal grounds for using your personal data
We have a legitimate interest (to develop and improve the products and services
we offer).
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Purpose for processing
To manage and handle your queries.
Legal grounds for using your personal data
* We have a legitimate interest (to effectively manage our business and
respond to queries).
* It is necessary to enter into or perform our contract with you.
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Purpose for processing
For insurance administration purposes including analysis of trends, carrying out
actuarial work, planning service delivery, risk assessment and costs and
charges.
Legal grounds for using your personal data
We have a legitimate interest (to develop and improve the products and services
we offer).
Legal grounds for using your sensitive personal data
Who will we share your personal data with?
We will keep your personal data confidential and we will only share it where
necessary for the purposes set out above with the following parties:
* Our policyholders and other third parties such as claimants where relevant.
* Other Liberty Mutual Insurance Group companies.
* Third parties involved in the administration of an insurance policy or claim.
These include loss adjusters, claims handlers, private investigators,
accountants, auditors, banks, lawyers and other experts including medical
experts.
* Our insurance partners such as other brokers and insurers.
* Other insurers who provide our own insurance (reinsurers) and companies who
arrange such reinsurance.
* Third parties who provide sanctions checking services.
* Financial crime and fraud detection agencies and other third parties who
operate and maintain fraud detection registers.
* Our regulators including the Financial Conduct Authority and the Prudential
Regulation Authority.
* The police, HMRC and other crime prevention and detection agencies.
* If relevant, your policy details will also be added to the Motor Insurance
Database (MID), run by the Motor Insurers’ Information Centre (MIIC).
* Third party suppliers, agents and contractors appointed by Liberty Specialty
Markets or the Liberty Mutual Insurance Group to help us carry out our
everyday business activities including IT suppliers, actuaries, auditors,
lawyers, document management providers, client relationship system providers,
outsourced business process management providers, our subcontractors and tax
advisers.
* Selected third parties in connection with any sale, transfer or disposal of
our business.
* Any agent or representative acting for you.
* Any other person where necessary to perform any insurance contract, in order
to protect ourselves from risk or to ensure regulatory compliance or good
governance.
3.6. USERS OF THE LIBERTY SPECIALTY MARKETS WEBSITES OR PLATFORMS AND EVENT
ATTENDEES
If you are a user of the Liberty Specialty Markets website (or a platform that
links through to this Notice), this section will be relevant to you and sets out
our uses of your personal data.
What personal data will we collect?
* General information submitted via the website or platform, for example where
you provide your details in the contact section such as your name, contact
details and company name.
* Information obtained through our use of cookies. You can find more
information about this in our cookies policy in the Cookies section below.
* Information obtained through a sign up form for an event or promotion.
What sensitive personal data will we collect?
We do not anticipate collecting special category data through the website.
However, where relevant, we may collect dietary requirements for an event or you
might submit special category data through a query or complaint.
How will we collect your personal data?
* We will collect your information directly from our website or a platform that
links you through to our website.
* Our websites may also collect your device's unique identifier, such as an IP
address.
What will we use your personal data for?
We may use your personal data for a number of different purposes. In each case,
we must have a "legal ground" to do so. We will rely on the following “legal
grounds”, when we process your "personal data":
* We need to use your personal data to enter into or perform the insurance
contract that we hold with you. For example, we need to use your personal
data to respond to your enquiry about a quote.
* We have a legal or regulatory obligation to use such personal data. For
example, our regulators require us to hold certain records of our dealings
with you.
* We need to use your personal data for a legitimate interest (e.g. to monitor
the number of visitors to our website, to keep business records and to
develop and improve our products and services). When using your personal data
for these purposes, we will always consider your rights and interests.
When the information that we process is classed as “sensitive personal data", we
must have an additional “legal ground". We will rely on the following legal
grounds when we process your "sensitive personal data":
* We need to use your sensitive personal data for purposes relating to an
insurance policy or claim and there is a substantial public interest in such
use. Such purposes include assessing an insurance application, managing
claims and preventing and detecting fraud.
* We need to use your sensitive personal data to establish, exercise or defend
legal rights. This might happen when we are faced with legal proceedings or
want to bring legal proceedings ourselves.
* You have provided your consent to our use of your sensitive personal data
(e.g. in relation to your marketing preferences).
Purpose for processing
Legal grounds for using your personal data
Legal grounds for using your sensitive personal data
Purpose for processing
To register you as a user of the website (including recording information on
our server logs from your browser, including your IP address and the page you
requested).
Legal grounds for using your personal data
We have a legitimate interest (to allow you to use the website and ensure its
proper functionality).
Legal grounds for using your sensitive personal data
Purpose for processing
To follow up on enquiries you make.
Legal grounds for using your personal data
We have a legitimate interest (to respond to your queries).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* Such use is necessary for insurance purposes.
Purpose for processing
To provide marketing information to you.
Legal grounds for using your personal data
We have a legitimate interest (to send you selected communications about other
products and services we offer).
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Purpose for processing
To allow you to apply for a recruitment opportunity and for our subsequent
management of your application.
Legal grounds for using your personal data
We have a legitimate interest (to ensure that your application is processed and
managed effectively).
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Purpose for processing
To allow you to apply for an event and out subsequent management of the event.
Legal grounds for using your personal data
We have a legitimate interest (to enable you to register for the event).
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Purpose for processing
To store your details on our Customer Relationship Management systems.
Legal grounds for using your personal data
We have a legitimate interest (to improve our relationship with you)
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Who will we share your personal data with?
We will keep your personal data confidential and we will only share it where
necessary for the purposes set out above with our Liberty Mutual Insurance Group
companies, our agents or contractors.
3.7. PROSPECTIVE JOB APPLICANTS
If you are applying for a job with us, this section will be relevant to you and
sets out our uses of your personal data.
What personal data will we collect?
* General information such as your name, address, contact phone numbers and
email addresses, date of birth and gender.
* Information about your job such as job title and previous roles.
* Information about your right to work
* Other information (including publically available information) obtained as
part of our due diligence checks.
* In the event you attend events with us, we may collect relevant details e.g.
your event preferences, dietary requirements etc.
What sensitive personal data will we collect?
* Information relating to your criminal convictions (including offences and
alleged offences and any court sentence or unspent criminal convictions). In
the event you attend events with us, we may collect dietary requirements. If
your CV contains any trade union memberships these will be collected
How will we collect your information?
As well as obtaining information directly from you, we will collect information
from service providers e.g. recruitment companies you have instructed.
Note, if you email us your CV or speculative application we will store it in our
recruitment portal for 2 years unless you object.
What will we use your personal data for?
We may use your personal data for a number of different purposes. In each case,
we must have a "legal ground" to do so. We will rely on the following “legal
grounds”, when we process your "personal data":
* We need to use your personal data to enter into or perform the employment
contract that we hold with you. For example, we may need certain information
draft an offer of employment.
* We have a legal or regulatory obligation to use such personal data. For
example, we may be required to carry out certain background checks.
* We need to use your personal data for a legitimate interest (e.g. to keep
your CV on file in case future opportunities arise). When using your personal
data for these purposes, we will always consider your rights and interests.
When the information that we process is classed as “sensitive personal data", we
must have an additional “legal ground". We will rely on the following legal
grounds when we process your "sensitive personal data":
* We need to use such special category data for a justifiable public interest
purpose on the basis of a legal requirement (e.g. security scanning of email
contents to detect cyber threats)
* You have provided your consent to our use of your sensitive personal data.
Purpose for processing
Legal grounds for using your personal data
Legal grounds for using your sensitive personal data
Purpose for processing
For business and management processes and activities including analysis, review,
planning, business transactions and IT (hosting, support and security).
Legal grounds for using your personal data
* We have a legitimate interest (to effectively manage our business).
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* Such use is necessary in the substantial public interest.
Purpose for processing
To comply with our legal or regulatory obligations.
Legal grounds for using your personal data
We need to use your information in order to comply with our legal obligations.
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* We need to use your information in order to establish, exercise or defend
legal rights.
Purpose for processing
To manage and handle your queries.
Legal grounds for using your personal data
* We have a legitimate interest (to effectively manage our business and respond
to queries).
* It is necessary to enter into or perform our contract with you.
Legal grounds for using your sensitive personal data
* You have given us your explicit consent.
* Such use is necessary for insurance purposes.
Purpose for processing
For recruitment administration purposes.
Legal grounds for using your personal data
We have a legitimate interest (to operate our recruitment function).
Legal grounds for using your sensitive personal data
You have given us your explicit consent.
Who will we share your personal data with?
We will keep your personal data confidential and we will only share it where
necessary for the purposes set out above with the following parties:
* Other Liberty Mutual Insurance Group companies (both inside and outside the
European Economic Area) and their service providers.
* Third parties involved in the hosting, analysis and supply of recruitment
services
* Credit reference agencies in relevant jurisdictions e.g. CallCredit, Equifax
and Experian are the credit reference agencies in the UK
* Our regulators including the Financial Conduct Authority, the Prudential
Regulation Authority and the Information Commissioner's Office.
* The police, HMRC and other crime prevention and detection agencies.
* If relevant, your policy details will also be added to the Motor Insurance
Database (MID), run by the Motor Insurers’ Information Centre (MIIC).
* Third party suppliers, agents and contractors appointed by Liberty Specialty
Markets or the Liberty Mutual Group to help us carry out our everyday
business activities including IT suppliers, auditors, lawyers, document
management providers, outsourced business process management providers, our
subcontractors and tax advisers.
* Selected third parties in connection with any sale, transfer or disposal of
our business.
* Any agent or representative acting for you.
A select group of third party suppliers used to host and manage our recruitment
portals ( based in the USA)
4. WHAT MARKETING AND/OR PROFILING ACTIVITIES DO WE CARRY OUT?
Marketing:
We will only send marketing communications to our business contacts. This may be
done by post, email or telephone.
In each case, we will give you the opportunity to opt out. You can also opt out
at any time by contacting us using the details set out in section 10.
Profiling:
Profiling is integral to the offering of insurance. We assess the risk that you
would like to insure (e.g. the risk of your home being damaged by a flood)
against the likelihood of that event occurring (e.g. based on the geographical
location of your property and history of floods in the area). We use this
profiling to help us decide whether or not to offer you insurance, the terms and
the price of your policy.
Whilst we use profiling to help us make our decisions, it is always a member of
our team who makes a decision taking into account the profiling outcome and
other relevant factors.
5. HOW LONG DO WE KEEP PERSONAL DATA FOR?
We will keep your personal data for as long as reasonably necessary to fulfil
the purposes set out in section 3 above and to comply with our legal and
regulatory obligations.
We have a detailed retention policy in place which governs how long we will hold
different types of information for. The exact time period will depend on your
relationship with us and the type of personal data we hold, for example:
* if we provide quote for a policy but this is not taken up by you (or on your
behalf) then we hold the associated information for 36 months.
* if you make a claim under a policy we provide, we will keep your personal
data for 10 years from the date on which the claim is closed.
If you would like further information regarding the periods for which your
personal data will be stored, please contact us using the details set out in
section 10.
6. WHAT IS OUR APPROACH TO SENDING YOUR PERSONAL DATA OVERSEAS?
Sometimes we (or third parties acting on our behalf) will transfer personal data
that we collect about you to countries outside of the United Kingdom ("UK") or
the European Economic Area ("EEA").
Where a transfer occurs, we will take steps to ensure that your personal data is
protected. We will do this using a number of different methods including:
putting in place appropriate contracts. We will use a set of contract wording
known as the "standard contractual clauses" which has been approved by the data
protection authorities.
Depending on our relationship and your particular circumstances, we might
transfer personal data anywhere in the world. For example, if you have a
personal accident policy with us and are injured, we may need to instruct
medical experts or other service providers in the country you are injured in. A
summary of our regular data transfers outside the UK/EEA is set out below:
Country of transfer
Reason for the transfer
Method we use to protect your information
Country of transfer
United States
Reason for the transfer
Transfer to Liberty Mutual Group Companies in the US - Reporting to our parent
company, IT support and hosting, centralised business functions in the United
States.
Method we use to protect your information
Robust IT Security Standards employed and Standard Contractual Clauses.
Country of transfer
United States
Reason for the transfer
Transfer to service providers to enable us to perform our business.
Method we use to protect your information
Supplier due diligence, contracts, audits and Standard Contractual Clauses.
Country of transfer
India
Reason for the transfer
Transfer to service providers to enable us to perform our business.
Method we use to protect your information
Supplier due diligence, contracts, audits and Standard Contractual Clauses.
Country of transfer
Dubai
Reason for the transfer
Liberty Specialty Markets MENA Limited is a Liberty Specialty Markets company
registered in the Dubai International Financial Centre.
Method we use to protect your information
IT Security Standards employed and Standard Contractual Clauses.
Country of transfer
Brazil , Columbia and China
Reason for the transfer
Service providers have access to certain applications for risk analysis and
policy processing.
Method we use to protect your information
IT Security Standards employed and Standard Contractual Clauses.
If you would like further information regarding our data transfers and the steps
we take to safeguard your personal data, please contact us using the details set
out in section 10.
7. HOW DO WE PROTECT YOUR PERSONAL DATA?
Liberty Specialty Markets takes security of your information very seriously. We
maintain appropriate technical, organisational, and physical safeguards designed
to protect the personal data we process in accordance with client instructions
and in line with our legal and regulatory obligations. The security measures in
place on our website and computer systems are in place to protect the loss,
misuse or alteration of the information you provide to us. We keep your personal
data only for as long as reasonably necessary for the purpose for which it was
collected or to comply with any applicable legal or ethical reporting or
document retention requirements.
The Liberty Mutual Group has a number of Information Security Standards that
apply depending on the data type and data location. These standards cover access
controls, encryption, network and host security, physical security, data
recovery and business continuity. Our standards change from time to time as we
react to market challenges and changing regulatory requirements.
Because e-mails submitted via this website are not protected by the same
security measures we use in other areas where we actively collect information,
you should be particularly careful in deciding what information you wish to send
to us via e-mail.
In the event that you become aware of any actual or potential misuse of any such
information or for more information on IT Security please contact us using the
details set out in section 10.
8. YOUR RIGHTS
Under data protection law you have a number of rights in relation to the
personal data that we hold about you which we set out below. You can exercise
your rights by contacting us at any time using the details set out in section
10. We will not usually charge you in relation to a request.
Please note that although we take your rights seriously, there may be some
circumstances where we cannot comply with your request such as where complying
with it would mean that we couldn't comply with our own legal or regulatory
requirements. In these instances we will let you know why we cannot comply with
your request.
In some circumstances, complying with your request may result in your insurance
policy being cancelled or your claim being discontinued. For example, if you
request erasure of your personal data, we would not have the information
required to pay your claim. We will inform you of this at the time you make a
request.
* The right to access your personal data
You are entitled to a copy of the personal data we hold about you and certain
details of how we use it.
We will usually provide your personal data to you in writing unless you request
otherwise. Where your request has been made electronically (e.g. by email), a
copy of your personal data will be provided to you by electronic means where
possible.
* The right to rectification
We take reasonable steps to ensure that the information we hold about you is
accurate and where necessary up to date and complete. If you believe that there
are any inaccuracies, discrepancies or gaps in the information we hold about
you, you can contact us and ask us to update or amend it.
* The right to restriction of processing
In certain circumstances, you are entitled to ask us to stop using your personal
data, for example where you think that the personal data we hold about you may
be inaccurate or where you think that we no longer need to use your personal
data.
* The right to withdraw your consent
Where we rely on your consent in order to process your personal data, you have
the right to withdraw such consent to further use of your personal data.
Please note that for some purposes, we need your consent in order to provide
your policy. If you withdraw your consent, we may need to cancel your policy or
we may be unable to pay your claim. We will advise you of this at the point you
seek to withdraw your consent.
* The right to erasure
This is sometimes known as the 'right to be forgotten'. It entitles you, in
certain circumstances, to request deletion of your personal data. For example,
where we no longer need your personal data for the original purpose we collected
it for or where you have exercised your right to withdrawn consent.
Whilst we will assess every request, there are other factors that will need to
be taken into consideration. For example we may be unable to erase your
information as you have requested because we have a regulatory obligation to
keep it.
* The right to object
Marketing: You have control over the extent to which we market to you and you
have the right to request that we stop sending you marketing messages at any
time. You can do this either by clicking on the "unsubscribe" button in any
email that we send to you or by contacting us using the details set out in
section 10.
Please note that even if you exercise this right because you do not want to
receive marketing messages, we may still send you service related communications
where necessary.
Processing based on our legitimate interests: Where we process your personal
data based on our legitimate interests, you can object to our processing. We
will consider your objection and determine whether or not our legitimate
interests prejudice your privacy rights.
* The right to data portability
In certain circumstances, you can request that we transfer personal data that
you have provided to us to a third party.
* Rights relating to automated decision-making
We do not carry out any automated decision making. If this changes in the
future, we will provide you with an updated notice setting out our decision
making process.
* The right to make a complaint with the Regulator
You have a right to complain to the Information Commissioner's Office (ICO) or
any other local Data Protection Regulator if you believe that we have breached
data protection laws when using your personal data.
You can visit the ICO's website at https://ico.org.uk/ for more information.
Please note that lodging a complaint will not affect any other legal rights or
remedies that you have.
9. COOKIES
By accessing and using this website you indicate that you accept Liberty
Specialty Market’s use of cookies.
The website uses cookies which are small files of letters and numbers that
Liberty Specialty Markets puts on your computer if you allow it. After your
visit to the website, the cookies will remember your language selection during
your visit. They also allow us to recognise and count the number of visitors and
to see how visitors move around the site. Some of the cookies are required to
provide you with access to the website and to make your browsing experience more
user-friendly.
This website may link through to third party websites (including websites of
companies within the Liberty Mutual Insurance Group) which may also use cookies
over which we have no control. We recommend that you check the relevant third
parties’ privacy policies for information about any cookies that they may use.
You can configure your web browser to refuse cookies, to delete cookies, or to
be informed if a cookie is set. The “Help” section on the menu bar of most
internet browsers will tell you how to do so. You may delete and block all
cookies but, if you do so, our website may not function correctly and you may
not be able to access certain areas. For more information about cookies and how
to delete them, visit http://www.allaboutcookies.org/.
If you want to know more about the cookies we use on this website please click
here.
10. CONTACTING US
If you would like further information about any of the matters in this notice or
if have any other questions about how we collect, store or use your personal
data, you may contact our Data Protection Officer at
dataprotectionofficer@libertyglobalgroup.com or by writing to Data Protection
Officer, Liberty Specialty Markets, 20 Fenchurch Street, London, EC3M 3AW or
click here.
Please note that we are not responsible for the privacy policies or content of
any websites linked to this website, (including websites of companies within the
Liberty Mutual Insurance Group).
11. UPDATES TO THIS PRIVACY & COOKIES NOTICE
From time to time we may need to make changes to this notice, for example, as
the result of changes to law, technologies, or other developments. We will
provide you with the most up-to-date notice and you can check our website here
periodically to view it.
This notice was last updated on 13 March2020.
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1. About Liberty Specialty Markets
2. About the insurance market
3. Our processing of your personal and special category data
3.1. Prospective policyholders or beneficiaries
3.2. Policyholder or beneficiary under an insurance policy
3.3. Third party claimant
3.4. Witnesses to an incident
3.5. Brokers, appointed representatives, suppliers and other business partners
3.6. Users of the Liberty Specialty Markets websites or platforms and event
attendees
3.7. Prospective job applicants
4. What marketing and/or profiling activities do we carry out?
5. How long do we keep personal data for?
6. What is our approach to sending your personal data overseas?
7. How do we protect your personal data?
8. Your rights
9. Cookies
10. Contacting us
11. Updates to this privacy & cookies notice