1. Introduction
This privacy notice (“Notice”) explains how IQUW Administration Services Limited (“we”,” us”, ”our”) collects and uses personal information of individuals (“you”, “your”) who are employed by, work for, manage or own broker companies who conduct business with us (each “Company”). We are committed to protecting the privacy and security of your personal information.
This Notice applies where you interact with us by e-mail, by telephone, in writing, in person or through our online services including where you visit the ers.com website.
A separate ERS privacy policy www.ers.com/policy-pages/privacy-policy governs the way in which ERS collects and uses personal information relating to your customers.
This Notice should be read in conjunction with the Terms of Business Agreement (“TOBA”) which we have in place with your Company. It is important that you read this Notice so that you are aware of how and why we are using your information. We may update this Notice from time to time. If you have any questions about this Notice or how we handle your personal information, please contact the Data Protection Officer at the address and contact details below.
2. Who we are
Data Controller: IQUW Administration Services Limited, 30 Fenchurch Street, London EC3M 3BD
Data Protection Officer: Anthony Davies, Data Protection Officer, 30 Fenchurch Street, London EC3M 3BD,
E-mail: dpo@iquw.com
IQUW and ERS are now part of Starr. Starr is the global marketing name for the insurance and travel assistance companies of Starr International Company, Inc. and investment business of C. V. Starr & Co., Inc. and their subsidiaries.’
3. Data Protection Principles
We take our data protection responsibilities seriously and are committed to holding your personal data transparently and in accordance with the applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We acknowledge that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
4. The kind of information we hold about you
Personal information means any information about an individual from which that person can be identified. We collect, store, and process a range of personal information about you. This may include:
- Your name, address and contact details such as email address and telephone number
- Details of your job title, role and image
- Date of birth, national insurance number and current and previous three years addresses (if you are a director or partner of your Company)
- Account registration details such as username and password
- Technical details such as your device information and Internet connection details such as IP address
- Marketing preferences such as opt-in / Opt-out selections
5. How we collect your personal information.
We may collect personal information about you when:
- You or your Company does business with us
- You register for or use our online services or visit the ers.com website.
- You register for our newsletter.
- You participate in any ERS broker competitions.
- You contact or communicate with us - you should note that some telephone calls may be recorded or monitored for the following purposes:
- Training and quality control
- As evidence of conversations
6. Purposes and Legal Basis for processing your information
We process your personal data for the following purposes
6.1 Necessary for the Performance of the Contract
We process personal information where it is necessary to enter into or fulfil ERS’ obligations under the contract between us, or the TOBA we have in place with your Company and in the interest of providing an efficient service to you and your customers. This includes:
- Set up an account.
- Maintain that account.
- Allow you to access and make use of ERS online services.
- Administer and manage products that your customers have with us.
- Manage quotations, enquiries, queries, and complaints.
- Conduct necessary background checks to make sure you are a legitimate person to do business with.
6.2 Legitimate Interests
- To keep you informed about our products and services subject to your marketing preferences.
- To administer the promotion and to deliver any prizes If you participate in our marketing promotions, or events.
- For research and statistical purposes to analyse how brokers use our website, our products, and other services so we can improve our understanding of user needs and enhance our products.
- To obtain feedback on the services we provide to you.
6.3 Legal Obligation
- For compliance with tax, legal and regulatory requirements
- Carry out appropriate verification and credit checks (where you are a Director or Partner of your Company)
- Fraud detection and prevention and anti-money laundering obligations
- For compliance with Financial Conduct rules
6.4 Consent
In some circumstances, we may ask for your consent to allow us to process certain personal information. for a particular purpose. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You are free to withhold your consent or withdraw it at any time.
7. If you fail to provide personal information
It is important that you provide information when requested, otherwise we may not be able to fulfil the contract we have entered into with you or your Company, or we may be prevented from complying with our legal obligations. We will make it clear if the provision of personal information is voluntary.
8. Change of purpose
We will only use your personal information for the purposes for which it is collected, unless we reasonably consider that we need to use it for any other reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
9. Use of third-party information
We obtain information about you from third party service providers and databases for assurance purposes. Below is a list of third-party service providers from whom we obtain information about you to help us provide our services:
Third Parties |
Reason |
Credit Check Companies |
To do business with yourselves we will run a credit score report which will show your financial behaviour over the last few years to help us decide whether to give you credit. |
Insurance Software Houses |
We obtain information from software houses operating a trading platform between us and you to enable you to obtain quotations and insurance premiums for policies underwritten by us. |
10. Disclosing and sharing your information
If you request a quote, or purchase a product on behalf of your customer, information about you and your Company may be shared with and processed by our Third-Party service providers who help us facilitate the administration of our business. We enter into contracts with our service providers to make sure they protect you and your customers’ personal information by using appropriate security measures. Below is a list of service providers that have access to personal information to help us to provide our products and services.
Third Parties |
Reason |
Fraud Prevention agencies and databases |
|
Out of Hours Suppliers |
|
Motor Insurance Bureau (MIB) |
|
Administrative Support |
|
Document management |
|
Professional Advisers |
|
IT and Related Providers |
|
For further details regarding how we share information related to our products on behalf of your customers, please visit our privacy policy at www.ers.com/policy-pages/privacy-policy
We may also share information about you with:
- Our regulators and law enforcement bodies as necessary for purposes of fraud prevention and detection and legal or regulatory requirements.
- Your customers if they have queries about the services between you, them, and us.
- Our social media for competitions where we may publish names, images, and company name of winners.
- Social media companies that you use, so that they can deliver marketing content to you on our behalf through their platforms (see Marketing and Cookies below).
Any request for information received from regulatory or law enforcement agencies is carefully validated before any personal data is disclosed.
11. Marketing and Cookies
To protect your privacy rights and your choice and control over the use of your personal information, we will always allow you the opportunity to opt-out of marketing communications when you register your contact information with us. In addition, you can always ‘opt out’ of receiving direct marketing by using the unsubscribe links you will find on our marketing emails. You can also change your marketing preferences in the Broker preference centre in the profile settings of your online account at any time.
12. International Transfers
Some of the organisations we share information with may be located outside of the UK and European Economic Area ("EEA"). We will always take steps to ensure that any transfer of information outside the UK and EEA is carefully managed to protect your privacy rights. We will only transfer personal information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.
Where we transfer your data to third parties providing us with a service, we will obtain contractual commitments and assurances from them to protect your personal information. Some of these assurances include the standard contractual clauses approved by the European Commission or other contracts which provide equivalent protection. Please contact us, if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK or EEA.
13. Data Retention
We will keep your personal data only for as long as is necessary for the purpose for which it was collected. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, any statutory retention requirements that apply, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and any other archiving or historical record-keeping obligations.
Where possible we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information indefinitely without further notice to you. Any information which is no longer needed will be destroyed securely.
14. Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know they will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a data breach where we are legally required to do so.
15. Your Rights
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us, or if you discover any errors or omissions.
Subject to the provisions of the Data Protection Act, you may have the following rights:
- Request access to your personal information (commonly known as “Data subject access request”). This enables you to receive a copy of the personal information we hold about you.
- Request rectification of any inaccurate information that we hold about you.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no lawful reason for us to continue to process it.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and you have a particular justification for objecting to processing on this ground.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information.
- Request the transfer of your information to another party in a structured, (known as “data portability”)
- Where you have provided personal data voluntarily, or otherwise consented to its use, the right to withdraw your consent.
We may ask for proof of your identity before we can respond to your request. This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you wish to exercise any of your rights, contact our Data Protection Officer at ERS, 30 Fenchurch Street, London EC3M 3BD or dpo@iquw.com
16. Changes to this Notice
We may amend this Notice from time to time, for example to keep it up to date or to comply with legal requirements. You should regularly check this Notice for updates. If there will be any significant changes made to the use of your personal information in a manner different from that stated at the time of collection, we will notify you by posting a notice on www.ers.com.
17. Contact us
If you have any questions about this Notice or how to exercise your rights, please contact our Data Protection Officer either through email or the address listed below
Email us: dpo@iquw.com
Address: Data Protection Officer, ERS,30 Fenchurch Street, London, EC3M 3BD.
18. Your right to complain
If you are not satisfied with our use of your personal data or our response to any request by you to exercise your rights in relation to your personal data, please contact complaints@iquw.com
You also have a right to make a complaint to the Information Commissioner:
In the UK this is the Information Commissioner’s Office. (www.ico.org.uk)
Information Commissioner’s Office
Wycliffe House Water Lane Wilmslow Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) Email: icocasework@ico.org.uk