Munich Re Specialty – North America – Binding Authorities (MRSNA) Privacy Notice
Munich Re Specialty – North America ("MRSNA") is a trading name of Bell & Clements Limited
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This Privacy Notice is designed to help you, as a customer of MRSNA, to understand how we process your personal data.
You are a customer of MRSNA (“we” or “us”) and we are the insurance intermediary of your policy. However, you may have purchased your insurance through another party, e.g. through another insurance broker or through an intermediary. MRSNA may also act as a Managing General Agent or Underwriter where specific delegated authority has been granted to us by one or more Insurers.
The insurance lifecycle may involve the sharing of your personal data with other insurance market participants, some of which, you may not have direct contact with. You can find out more information about these processors by contacting the intermediary that you purchased your policy from.
The Data Controller for MRSNA is:
The Data Protection Officer for MRSNA is:
1 Fen Court
London
EC3M 5BN
Tel: +44 (0) 207 283 622
Website: www.munichre.com/bindingauthorities
Bell & Clements Limited
1 Fen Court
London
EC3M 5BN
Tel: +44 (0) 203 003 7000
Email: dataprotection@bellandclements.co.uk
Please contact the Data Protection Officer if you have questions concerning this Privacy Notice or your Data Subject Rights. These include:
- Subject Access Request: To request access to your personal data and information around its processing.
- Erasure: To have your personal data removed or deleted.
- Rectification: To have your personal data corrected if it is inaccurate.
- Restrict Processing: To restrict processing where your personal data is inaccurate, or the processing is unlawful.
- Data Portability: To transfer your personal data to another Data Controller in a machine-readable format.
- To object to processing based on legitimate interest
- To object to direct marketing (Note: we do not do direct marketing).
If you are unhappy with any response or have a complaint, you can raise this with:
The Information Commissioner
Wycliffe House Water Lane Wilmslow Cheshire
SK9 5AF
Tel: +44 (0) 303 123 1113
Who your data is shared with
The following are data controllers that we share your personal data with:
- Insurers including Lloyd’s of London, Great Lakes Insurance SE and various insurance companies.
- Agents including Managing General Agents and Wholesalers who can offer specific insurance products.
- Brokers that may have access to specific insurers or products.
- Government and Regulatory Agencies.
- Legal Advisers.
The following are data processors that we disclose your personal data to:
- Third Parties providing services for Payment of Insurers, Banking, Claims Handling, Insurance Administration and IT Services.
Please contact the Data Protection Officer (dataprotection@bellandclements.co.uk) if you require further information on who your data is shared with.
What information do we collect about you
Personal Data
| Categories of data | Type of information processed | Where the data may come from | Who we may disclose the data to | Potential purpose of processing | Lawful basis of processing |
|---|---|---|---|---|---|
| Individual information | • Name • Address • Marital status • Date and place of birth • Nationality • Employer • Job title • Employment history • Family details and their relationship to you. | • Insurance intermediaries or other insurance market participants. • You and your family. • Your employer. | • Group companies. • Insurers. • Our agents and brokers. • Other intermediaries or market participants. • Anti-fraud databases. | • Setting you up as a client including arranging and administering insurance cover, underwriting, evaluating and pricing the risks to be insured and calculating, validating and collecting any appropriate premium. | • Performance of our contract with you. |
| • Improve our processes and tools and monitor business performance. | • Legitimate Interest | ||||
| Policy information | • Information about the quotes and insurance policies you have applied for or taken out. | • Insurance intermediaries or other insurance market participants. • You and your family. • Your employer. | • Group companies. • Insurers. • Our agents and brokers. • Other intermediaries or market participants. • Anti-fraud databases. | • Managing you as a client including, arranging and administrating insurance cover, underwriting, evaluating and pricing the risks to be insured and calculating, validating and collecting any appropriate premium. | • Performance of our contract with you. |
| Financial information | • Premiums and claims paid on your policies. • Bank account or payment card details. • Income and other financial information | • Insurance intermediaries or other insurance market participants. • Your family. • Your employer. • Credit reference agencies. | • Group companies. • Insurers. • Our agents and brokers. • Other intermediaries or market participants. • Credit reference agencies. Anti-fraud databases. | • Managing you as a client including administrating insurance cover, underwriting, evaluating and pricing the risks to be insured and calculating, validating and collecting any appropriate premium. | • Performance of our contract with you. |
| Statutory and anti-fraud information | • Sanctions and information from anti-fraud databases concerning you. | • Insurance intermediaries or other insurance market participants. • You and your family. • Your employer. • Anti-fraud databases, sanctions lists, court judgements and other government agencies. | • Group companies. • Insurers. • Our agents and brokers. • Other intermediaries or market participants. • Anti-fraud databases. | • Setting you up as a client including checks for possible fraud, sanctions and anti-money laundering. | • Compliance with a legal obligation. |
| • Managing you as a client including, arranging and administrating insurance cover, underwriting, evaluating and pricing the risks to be insured and calculating, validating and collecting any appropriate premium. | • Performance of our contract with you. | ||||
| Claim information | • Information about • previous and current claims. | • Insurance intermediaries or other insurance market participants. • Your family. • Your employer. • Anti-fraud databases, claimants, defendants, witnesses, experts inc. medical experts, loss adjustors, solicitors and claims handlers. | • Group companies. • Insurers and reinsurers. • Our agents and brokers. • Other intermediaries or market participants. • Anti-fraud databases. • Medical doctors and specialists. | • Managing insurance claims. | • Performance of our contract with you. |
| • Defending or prosecuting legal claims. | • Processing is necessary for the defence of legal claims. | ||||
| • Investigating or prosecuting fraud. | • Compliance with a legal obligation. |
| Categories of data | Type of information processed | Source of the data | Who we disclose the data To | Purpose of processing | Lawful basis of processing |
|---|---|---|---|---|---|
| Individual Information | • Information about previous and current policies / claims. • Health information and medical reports. • Surveillance reports. | • Insurance intermediaries or other insurance market participants. • You and your family. • Your employer. • Anti-fraud databases, claimants, defendants, witnesses, experts inc. medical experts, loss adjustors and solicitors. | • Group companies. • Insurers. • Our agents and brokers. • Other intermediaries or market participants. • Anti-fraud databases. • Medical doctors and specialists. • Loss adjustors and solicitors. | • Setting you up and managing you as a client. • Managing insurance claims. | • Processing is necessary for insurance purposes. |
| • Defending or prosecuting legal claims. | • Processing is necessary for the defence of legal claims. | ||||
| • Investigating or prosecuting fraud. | • Compliance with a legal obligation. | ||||
| Statutory and anti-fraud information | • Information about previous and current policies / claims. • Criminal records and convictions. • Surveillance reports. | • Insurance intermediaries or other insurance market participants. • You and your family. • Your employer. • Anti-fraud databases, sanctions lists, court judgements and other government agencies. | • Group companies. • Insurers. • Our agents and brokers. • Other intermediaries or market participants. • Anti-fraud databases. • Loss adjustors and solicitors. | • Setting you up and managing you as a client. | • Processing is necessary for insurance purposes. |
| • Defending or prosecuting legal claims. | • Processing is necessary for the defence of legal claims. | ||||
| • Investigating or prosecuting fraud. | • Compliance with a legal obligation. with a legal obligation. | ||||
Protection of your information
Your privacy is important to us, and we follow strict security and organisational procedures in the processing, storage, destruction and disclosure of your information. This is to prevent unauthorised access or loss of your information.
Use of your Consent to process Special Categories of Personal Data
To provide insurance, in certain circumstances we may need to process special categories of personal data, such as medical records or criminal convictions.
We follow the lawful basis that your insurer has used in processing and disclosing your special categories of personal data to us. This may be for the performance of the insurance contract or consent. If consent is used, you will not have given your consent directly to us but to the insurance intermediary that you purchased your policy from. You may withdraw your consent for us to process your special categories of personal data at any time by contacting the Data Protection Officer (details as above). However, if you withdraw your consent this will impact on our ability to provide or continue to provide for your insurance policy or pay claims.
Marketing
If you have opted in to receive marketing material, MRSNA or group companies will contact you from time to time by telephone, post, newsletter, email or SMS to keep you informed with news, products or services, including but not limited to insurance together with carefully selected offers or promotions which we feel may be of interest to you. Other carefully selected companies may also contact you.
If you would like to receive marketing material or you have opted in and want it to stop, please contact us by using the email address dataprotection@bellandclements.co.uk, or write to The Data Protection Officer at the above address.
Data Retention
Your personal data will only be kept for as long as it is necessary for the purpose it was collected for.
| Data | Statutory Retention Period | B&C Retention Period |
|---|---|---|
| Insurance Scheduled | No statutory retention period exists | 12 years |
| Insurance Settlements | No statutory retention period exists | 12 years |
| Rating Documents | No statutory retention period exists | 12 years |
| Cash Journals | No statutory retention period exists | 12 years |
| Cash / Daily Ledgers | No statutory retention period exists | 12 years |
| Insurance Contracts (treaties, slips, wordings, endorsements) – Short Tail | No statutory retention period exists | 7 years |
| Insurance Contracts (treaties, slips, wordings, endorsements) – Long Tail (e.g. Liability business) | No statutory retention period exists | 40 years |
| Claims Records for Bordereaux and Loss Funds | No statutory retention period exists | 7 years from closure date |
| Claims Records for Property Business | No statutory retention period exists | 7 years from closure date |
| Claims Records for Liability Business | No statutory retention period exists | 40 years |
| Insurance Policies (Short) | No statutory retention period exists | 7 years |
| Coverholder Annual compliance Questionnaires | No statutory retention period exists | 7 Years from end of year received |
| Insurance Policies (Liability) | No statutory retention period exists | 40 years |
| Insurance Quotes / Enquiries / Indications / Submissions (not taken up) | No statutory retention period exists | 13 months from receipt |
| Underwriting Guidelines | No statutory retention period exists | 12 years |
| In the event of claims litigation, either threatened or instigated, all document destruction / anonymisation protocols of the claim will cease, and the relevant files will be held in a secure area pending legal advice. | ||
Transfer of Data
We may transfer your personal data outside the UK or EEA where there may not be an equivalent level of data protection. We will always ensure compliance with any local data protection legislation.
These transfers will only be made where it is for the performance of our contract with you.
Your personal data may be disclosed to companies within our Group or to Service Providers outside the UK or EEA.
You can find out the details about any other party we have shared your personal data with by contacting the Data Protection Officer at the address provided at the top of this Privacy Notice.
Changes to this MRSNA - Privacy Notice
If we make changes to this Privacy Notice that affects how we process your information, we will revise the Privacy Notice and publish it on our website.