Privacy Notice
Important notice
This is the privacy notice of Greenwood Insurance Consultants Limited (registration number: SC268105) whose registered office is at Prospect House,
Hamilton International Technology Park, Blantyre, G72 0BN. Telephone: 01698 456500- Email: [email protected] and our other
Trading Styles are Greenwood Moreland Insurance Brokers, HRIB London, Hamilton Robertson Insurance Brokers, C and A Mackie Insurance Brokers and
Taveo referred to as we, us or our in this privacy notice.
This privacy notice sets out how we collect and process your personal data. This privacy notice also provides certain information that is legally required and
lists your rights in relation to your personal data.
This privacy notice relates to personal information that identifies you as a natural person (whether you are an actual or potential customer, an individual
who browses our website or an individual outside our organisation with whom we interact). We refer to this information throughout this privacy notice as
personal data or personal information and further detail of what this includes are set out in this privacy notice below.
The privacy and security of your personal information is very important to us so we want to assure you that your information will be properly managed and
protected by us at all times. Please read this privacy notice carefully as it explains how we may collect and use your personal data.
This privacy notice may vary from time to time so please check it regularly. This privacy notice was last reviewed/updated in March 2026.
Version Ref: V8.4
How to contact us (Controller and contact details)
For the purposes of relevant data protection legislation, we are a controller of your personal data. As a controller, we use (or process) the personal data we
hold about you in accordance with this privacy notice.
If you need to contact us in connection with the use or processing of your personal data, then you can do so via the email address noted above.
What information we hold about you and where we obtain this from
The personal data that we collect about you may include the following information:
• Personal data you provide to us in person, via our website or by telephone
• Personal data you provide when you enquire about insurance, or when you purchase a policy, through us, including information about what
and/or who you want to insure, such as vehicle details, business activities, your home or travel details
• General information about you, such as your name, address, contact details and date of birth
• Personal data you provide if you subscribe to any of our mailing or newsletter services
• Your claims and credit history
• Financial details, such as your bank account and card details
• Criminal convictions
• Information about your use of our website such as your IP address, which is a unique number identifying your computer, including personal data
gathered using cookies
In addition, we may obtain certain special categories of your data (special categories of data) and data about criminal convictions, and this privacy notice
specifically sets out how we may process these types of personal data. The special categories of data are data concerning health.
We collect your personal data from you as a controller when we obtain quotations for insurance for you, when we set up your policy for you and when we
make changes to your policy for you. This may also involve the collection of data from or about others who are associated with you and your insurance policy
such as other persons insured on your policies or your employees or representatives. By giving us information about someone else for the purpose of
arranging insurance for them under your policy such as named driver, employee or travel companion etc. you confirm that you have their permission to do
so and that you have shared this privacy notice with them.
By asking us to arrange a contract of insurance for you where this involves passing information to us relating to children, you confirm to us that in doing so
you are the responsible guardian of the child.
We also collect information from publicly available sources and third party databases made available to the insurance industry for the purposes of reducing
fraud and financial crime as well as any other third party databases where your personal data may be held, provided such third parties have lawful bases on
which to share such personal data with us.
How we use your personal data and the lawful basis for doing so
Where we are relying on a basis other than consent
We may rely on one or more of the following legal bases when processing your personal data for the following purposes:
| Purposes for which we process your personal data | The basis on which we can do this (this is what the law allows) |
|---|---|
| In order to perform our contractual obligations to you. This would include fulfilling your requests for insurance services (including obtaining insurance for you, fulfilling requests for mid-term adjustments and obtaining renewals) | The processing is necessary in connection with any contract that you may enter into with us |
| To administer your account, including financial transactions for insurance broking | The processing is necessary in connection with any contract that you may enter into with us |
| To assist in the prevention and reduction of fraud and other financial crime | The processing is necessary for us to comply with the law and our legal requirements |
| In the interests of security and to improve our service, telephone calls you make to us may be monitored and/or recorded | The processing is necessary to pursue our legitimate interest in the management and operation of our business |
| To let you know about products and services available from our other Group companies (Regulated Legal Entities) which may be of interest or beneficial to you | The processing is necessary to pursue our legitimate interest in operating our business |
| To request feedback on the service you have received from us | The processing is necessary to pursue our legitimate interest in ensuring high standards of customer service and satisfaction |
| To make automated decisions, automated profiling and fraud detection | The processing is necessary in connection with some contracts that you may enter into with us |
Special categories of data and criminal convictions
We may also need to collect special categories of data from you such as information about your health, personal data revealing racial or ethnic origin,
religious or philosophical beliefs or trade union membership and generic data. We may also collect information on criminal convictions which we may share
with third parties. The lawful basis on which we can do this is the processing is necessary for reasons of substantial public interest relating to insurance
purposes.
Insurance purposes mean (a) advising on, arranging, underwriting or administering an insurance contract (b) administering a claim under an insurance
contract or (c) exercising a right or complying with an obligation, arising in connection with an insurance contract, including a right or obligation arising under
an enactment or a rule of law.
Who we pass your personal data to
We may need to pass your personal data to other companies which may include:
• Other companies or brands within our group of companies, for example if we are unable to provide a suitable insurance policy on request or at
renewal we will check if any of our associated group companies can provide you with suitable cover
• The insurers, intermediaries and third party service providers that we use for the purpose of arranging and administering your insurance policy.
This may also include risk management assessors, uninsured loss recovery agencies, premium finance providers and other third parties involved
(directly or indirectly) in the administration of your insurance and its associated benefits
• Firms that provide administration and processing services to us or on our behalf under contract in order to complete activities such as claims
handling, IT systems and administrative services and other activities set out in this privacy notice, as well as support activities such as finance
and auditing services
• Organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies
• Other organisations where we have a duty to or are permitted to disclose your personal information by law, for example if we received a valid
request from the police or other third party organisation in the interest of preventing and detecting crime
• Fraud prevention agencies and operators of registers available to the insurance industry to check information and prevent fraud
• Credit reference agencies to check your credit history. This check will be recorded on your credit reference file without affecting your ability to
apply for credit or other financial products
• Third parties we use to recover money you may owe us or to whom we may sell your debt
• Another company, if our business or part of it is bought or taken over by that company to make sure your insurance policy can continue to be
serviced or as part of preliminary discussions with that company about a possible sale or take over
The information you share with us may be transferred by us or any of the types of firms or organisations we have noted above, to other countries in order
for processing to take place, including locations outside of the UK. We will only do so if there are adequate levels of protection in place as required by
applicable data protection laws.
Accessing our website and cookies
When you visit one of our websites, we may collect information from you such as your email address, IP address and other online identifiers. This helps us
to track unique visits and monitor patterns of customer website traffic, such as who visits and why they visit. We may use third parties to collate IP addresses
to help us understand our Internet traffic data and data regarding your browser type and computer. We may also use web usage information to create
statistical data regarding the use of our website. We may then use or disclose that statistical data to others for marketing and strategic development
purposes, but no individuals will be identified in such statistical data.
We may use cookies and/or pixel tags on some pages of our website. A cookie is a small text file sent to your computer, mobile phone or tablet depending
on the device used to access our website. A pixel tag is an invisible tag placed on certain pages of our website, but not on your computer. Pixel tags usually
work together with cookies to help us to give you a more tailored service. We may also use cookies and pixel tags in our email communication to personalise
the email and track whether the email has been opened and whether the recipient has used any website links contained in the email communication. This
allows us to monitor and improve our email communications and website. Useful information about cookies, including how to remove them, can be found
at http://allaboutcookies.org.
Internet browsers normally accept cookies by default, although it's possible to set a browser to reject cookies. However, refusing to accept cookies may
restrict your use of our website and/or delay or affect the way in which our website operates. You can find more information on cookies when you visit our
website.
The open nature of the internet is such that data may flow over networks without security measures and may be accessed and used by people other than
those for whom the data is intended. While this is outside of our control, we do take the protection of your information very seriously and aim to apply
appropriate levels of security at all times.
Sanctions List Checks
We are required to confirm that our customers are not on the Sanctions List maintained by HM Treasury and other overseas authorities. We use
SanctionsSearch provided by Professional Office Ltd to perform these checks both on initial appointment and on an ongoing basis whilst we act on your
behalf.
Remote Working/Working from Home
Certain members of the business may be authorised by the company to work remotely, usually from home, and we have specific rules and controls to which
those members of the business must adhere. Failure to comply with these requirements must be reported to the company’s data protection officer without
delay so that alternative arrangements can be considered and, where appropriate, agreed and put into place.
Closed circuit television (CCTV)
Where CCTV is used, we have identified and documented the potential impact on individuals’ privacy and have taken this into account when installing and
operating the CCTV system. We regularly review whether CCTV is still the best security solution.
We will clearly inform individuals of our use of CCTV and we only retain recorded CCTV images for long enough to allow for any incident to come to light
(e.g. for a theft to be noticed) and to investigate it. We will respond to individuals or organisations making requests for copies of their images on our CCTV
footage and will seek prompt advice from the Information Commissioner where there is any uncertainty. We securely store CCTV images, limit access to
authorised individuals and regularly check that the CCTV system is working correctly. We have a nominated individual who is responsible for the operation
of the CCTV system.
Telephone Recording
When engaging in phone conversations, we want to inform you that we record calls. Calls are recorded for both internal departmental calls and external
calls. This is done for quality assurance purposes, and we encourage you to share any concerns right away. Rest assured, these recordings are kept securely
for a limited duration, and you have the option to request a copy if it's still available. Please note that we only share call recordings with third parties when
it's legally required or permitted. Additionally, we take stringent measures to safeguard payment card information in compliance with the Payment Card
Industry Data Security Standard (PCI DSS). Our system is designed to avoid recording Sensitive Authentication Data (SAD), and if this is unavoidable, such
data is promptly deleted after card authorisation.
Your rights
We will only store your data for as long as is necessary to comply with the requirements of your insurance contract(s) and any legal obligations or lawful
processing conditions that may exist as a result. You have a number of rights concerning the personal information we use, which you may ask us to observe.
In some cases, even when you make a request concerning your personal information, we may not be required, or be able to carry out your request as this
may result in us not being able to fulfil our legal and regulatory obligations under the lawful processing conditions under which we hold your data or because
there is a minimum statutory period of time for which we have to keep your information. If this is the case, we'll let you know our reasons.
You can ask us to:
• Provide a copy of your personal information
• Correct or delete unnecessary or inaccurate personal information
• Restrict or to object to the use of your personal information at any time
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• Object to any automated decision, including profiling which may have been used by insurers when underwriting your quotation. Where an
automated decision has been made we will advise you of this and of your rights
• Provide your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another
controller. This right only applies where our processing of your personal data is automated and the processing took place initially with your consent
or for the performance of a contract with you
• Where we rely on your consent to use your personal information, you can withdraw that consent at any time. Where your consent is withdrawn,
your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing material
has been sent prior to you advising that you don’t want us to contact you again.
If you have any questions or concerns about this privacy notice or your data protection rights, please contact us using our details set out at the beginning of
this privacy notice.
You also have the right to make an enquiry or to complain to the Information Commissioner’s Office (ICO) if you are unhappy with our use of your data, or
if you think we have breached a legal requirement. Further details about the ICO are available at: www.ico.org.uk.
How we contact you about other products and services
We may from time to time process your personal data to let you know about products and services that are available from our other Group companies
(Regulated Legal Entities) which may be of interest and beneficial to you. Any initial approach will only be through your usual contact. This is because we
value your custom and we pride ourselves in offering professional and tailored advice which meets your specific insurance needs. This includes keeping
you informed on the latest insurance and industry information and details of any offers or promotions relating to the insurance services we provide to you.
Our lawful basis for processing your personal data in this way is as is necessary to pursue the legitimate interests of our business, unless we have
otherwise obtained your consent to do so.
We use your personal data to obtain quotations, arrange and administer insurance. To do this, we may share relevant information with insurers,
MGAs/underwriting agents, other intermediaries, and our group companies where this helps us identify suitable cover. We rely on contractual necessity
and/or legitimate interests for this sharing. We only share what is necessary, protect your information, and do not allow recipients to use it for unrelated
purposes.
We may contact you by post, telephone, or e-mail. You will be given the option to stop receiving any communications from us in this regard at any time
however please note that this will not affect us contacting you about the servicing of products that you have specifically requested from us.
We may also contact you to request feedback on the service you have received from us. This helps us monitor the quality of our service and make
improvements where needed. We do this on the basis of our legitimate interest in ensuring high standards of customer service and satisfaction. You are
under no obligation to respond, and you can opt out of receiving these requests at any time by contacting us using the details in the ‘How to contact us’
section of this notice.
Greenwood Moreland Insurance Brokers is authorised and regulated by the Financial Conduct Authority (FCA). FRN 310565.
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