J C Roxburgh Insurance Brokers Ltd

Privacy Notice

About this Privacy Policy

J C Roxburgh Insurance Brokers Ltd takes your data privacy seriously. In order to provide you with our services we collect and use personal data which means that we are a ‘Data Controller’ and we are responsible for complying with Data Protection Laws and the General Data Protection Regulations (GDPR) which apply in your country of residence.

We are an Independent Insurance Broker, providing advice on risk and preparing tailored insurance arrangements for Individuals and Businesses. We collect and process information about you in order to arrange insurance policies and to process claims. Your information is also used for business purposes such as fraud prevention and detection and financial management. This may involve sharing your information with third parties such as insurers, reinsurers, other brokers, claims handlers, loss adjusters, credit reference agencies, service providers, professional advisors, our regulators, police and government agencies or fraud prevention agencies.

In this Privacy Notice, we want to inform you what information we collect, how we use it and what rights individuals have in relation to the collection and processing of their personal data.

If you are providing personal data of another individual to us, you must tell them you are providing their information to us and show them a copy of this notice.

Our Contact Details

If you have any questions in respect of this Privacy Notice or how we manage your personal data, please contact:

J C Roxburgh Insurance Brokers Ltd
151 Glasgow Road
Clydebank
G81 1LQ

Tel: 0141 952 0371
Email: info@roxburgh-group.co.uk

Why we do we collect your information?

Where we collect and process personal data, we identify both the purpose and legal basis for doing so. The legal bases which are:

Consent – where we have consent from the individual to the processing of his or her personal data for one or more specific purpose

Contract – where the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legal Obligation – The processing is necessary for compliance with a legal obligation to which we are subject
Vital Interests – Where the processing is necessary in order to protect the vital interests of the data subject or another natural person

Public Interest – Where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

Legitimate Interests - Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal date, in particular where the data subject is a child.

Our Processing of Your Personal Information

The information we collect and our lawful basis for processing it will depend on the type of service we provide for you. Please review the section which is most applicable to our relationship with you.

What personal data we collect – select the option most suited to you

• Prospective, New or Existing Customers or parties covered under an Insurance Policy we have arranged (Click To Show)

  Where you are enquiring about or have arranged an insurance policy and / or entered into a contract for our services, we can collect, store or use the following types of personal data which is regularly reviewed throughout the lifespan of your relationship with us:

  • General contact details such as, Name, Address, email address, Telephone number
  • General Identity Information such as Driving Licence Number, National Insurance Number
  • Business Activities of the person who’s personal information we are processing
  • Details of previous insurance arrangements including claims history
  • Details of your demands and needs in relation to insurance
  • Full details of your insurance risks where cover has been arranged by us
  • Details of other insurance risks not managed by us
  • Sanctions information
  • Details of policies purchased and Services provided to you
  • Financial Details – such as credit history or payment or bank details
  • Information obtained through our use of cookies (please see our Cookie Policy)
  • Your marketing preferences

  Special Categories of Personal Data that we collect:

  New or Existing Customers or parties covered under an Insurance Policy we have arranged

  • Details relating to health or previous health insurance claims when arranging a travel insurance policy where it is relevant to the policy being arranged
  • Information relating to criminal sanctions (including offences and alleged offences and any caution, court sentence or criminal conviction), which can be established directly from you or as a result of carrying out sanctions checks.
  • Information relating to any professional disciplinary action you have been the subject of where it is relevant to the policy being arranged
  • The following special category information offered by you in the course of your discussions with us relating to race, ethnicity, religious or philosophical beliefs, political opinions, trade union memberships or data concerning your sex life or sexual orientation.  We will only process such information to the extent necessary in the connection with a claim or where in connection with legal proceedings.  Any further processing will only be with your explicit consent.

  How we collect your information

  In most cases, we collect your data directly from you.  We collect data and process it when you

  • Complete an online ‘contact us’ form
  • Speak to us on the telephone to discuss or use our services
  • Email or write to us to enquire about or use our services
  • View our website via your browsers cookies (see our Cookie Policy)

  Or Indirectly

  We also receive your data indirectly from the following sources:

  • Social Media Sites such as LinkedIn or Facebook
  • Public sources – demographic data, Market Research, Local Directories

  Purpose	Lawful Basis	Lawful Basis for Any Special Category of Information
  To understand your insurance requirements, needs and risk appetite on an ongoing basis to obtain regular quotes and terms for you as part of an ongoing contract of service with you	The processing is necessary for the performance of our ongoing contract with you.	It is necessary for an insurance purpose
  To provide documentation and assist with any ongoing claims made under an insurance policy we have arranged	The processing is necessary for the performance of our ongoing contract with you.	It is necessary for an Insurance Purpose
  To assist with any renewals, mid-term adjustments of your insurance policy or cancellations.	The processing is necessary for the performance of our ongoing contract with you.	It is necessary for an Insurance Purpose
  To hold you on our records as a client including carrying out annual credit, fraud, sanctions and anti money laundering checks	We have a legal or regulatory obligation	The prevention of fraud is in the substantial public interest.
  To comply with our legal or regulatory obligations (such as our requirements to report to the FCA)	We have a legal or regulatory obligation	It is necessary to establish and exercise our legal rights.
  To communicate with you, respond to your queries and notify you about changes to our service	It is in our Legitimate Interests to use your personal information to keep you informed about any changes that may affect you	It is necessary for an insurance purpose
  Prevention, detection and investigating and prosecuting fraud.  This can include sharing personal data information with third parties including the police, and other insurance and financial providers	The processing is necessary for the performance of our ongoing contract with you. It is in our Legitimate Interests to ensure that we take all necessary steps to prevent fraud.	The prevention and detection of fraud is in the substantial public interest
  For Marketing of similar services to existing customers	It is in our Legitimate Interests to use your personal information for marketing purposes where the services being marketed are relevant to you	N/A
  For electronic Marketing of services to new customers	We rely on Consent for direct electronic marketing to individuals	N/A
  For Direct Marketing to Businesses	It is in our Legitimate Interests to market our services to other businesses which can include personal business email addresses	N/A
  To identify and prevent fraud	It is in our Legitimate Interests to act as a responsible business	N/A
  Managing our Business operations such as maintaining accounting records, analysing financial results, complying with internal audit requirements and receiving professional advice (e.g. tax or legal advice)	It is in our Legitimate Interests to manage and improve our business operations and activities.	N/A

• Third Party Claimants (Click To Show)

  Where you contact us in relation to a claim you may have against one of our contractual clients, we can collect, store or use the following types of personal data:

  • General contact details such as, Name, Address, email address, Telephone number
  • General Identity Information such as Driving Licence Number, National Insurance Number
  • Job title where relevant

  If Relevant to your claim, we can also collect:

  • Business Activities of the person who’s personal information we are processing
  • Details of your claim
  • Details of your own insurance arrangements
  • Details of all discussions in relation to the claim
  • Sanctions information
  • Financial Details – such as payment or bank details
  • Information obtained through our use of cookies (please see our Cookie Policy)

  Special Categories of Personal Data that we collect:

  We may collect the following information, only where it is relevant to your claim:

  • Information relating to health / medical history or previous claims
  • Information relating to criminal sanctions (including offences and alleged offences and any caution, court sentence or criminal conviction), which can be established directly from you or as a result of carrying out sanctions checks.
  • The following special category information offered by you in the course of your discussions with us relating to race, ethnicity, religious or philosophical beliefs, political opinions, trade union memberships or data concerning your sex life or sexual orientation. We will only process such information to the extent necessary in the connection with your claim or where in connection with legal proceedings. Any further processing will only be with your explicit consent.

  How we collect your information

  In most cases, we collect your data directly from you. We collect data and process it when you

  • Complete an online ‘contact us’ form
  • Speak to us on the telephone to discuss or use our services
  • Email or write to us to enquire about or use our services
  • View our website via your browsers cookies (see our Cookie Policy)

  Or Indirectly

  We also receive your data indirectly from the following sources:

  • Social Media Sites such as LinkedIn or Facebook
  • Public sources – demographic data, Market Research, Local Directories
  • Insurance Companies may provide Personal Data relating to third parties involved in a claim

  Purpose	Lawful Basis	Lawful Basis for Any Special Category of Information
  To assist in any claims made under an insurance policy we have arranged	It is in our Legitimate Interests to assist in any claims which have been made under an insurance policy we have arranged	It is necessary for an insurance purpose
  To comply with our legal or regulatory obligations (such as our requirements to report to the FCA)	We have a legal or regulatory obligation	It is necessary to establish and exercise our legal rights
  Prevention, detection and investigating and prosecuting fraud.  This can include sharing personal data information with third parties including the police, and other insurance and financial providers	It is in our Legitimate Interests to ensure that we take all necessary steps to prevent fraud.	The prevention and detection of fraud is in the substantial public interest
  Managing our Business operations such as maintaining accounting records, analysing financial results, complying with internal audit requirements and receiving professional advice (e.g. tax or legal advice)	It is in our Legitimate Interests to manage and improve our business operations and activities	N/A

• Specialist Claims Experts and Service Providers (Click To Show)

  Where we work with you as a specialist claims expert, we can collect, store or use the following types of personal data:

  • General contact details such as, Name, Address, email address, Telephone number
  • General Identity Information such as Driving Licence Number, National Insurance Number
  • Information about your business, job title and role

  How we collect your information

  In most cases, we collect your data directly from you. We collect data and process it when you

  • Complete an online ‘contact us’ form
  • Speak to us on the telephone to discuss or use our services
  • Email or write to us to enquire about or use our services
  • View our website via your browsers cookies (see our Cookie Policy)

  Or Indirectly

  We also receive your data indirectly from the following sources:

  • Social Media Sites such as LinkedIn or Facebook
  • Public sources – demographic data, Market Research, Local Directories

  Purpose	Lawful Basis	Lawful Basis for Any Special Category of Information
  To assist in any claims made under an insurance policy we have arranged	It is in our Legitimate Interests to assist clients in any claims which have been made under an insurance policy we have arranged	It is necessary for an insurance purpose
  Prevention, detection and investigating and prosecuting fraud.  This can include sharing personal data information with third parties including the police, and other insurance and financial providers	It is in our Legitimate Interests to ensure that we take all necessary steps to prevent fraud	The prevention and detection of fraud is in the substantial public interest
  Managing our Business operations such as maintaining accounting records, analysing financial results, complying with internal audit requirements and receiving professional advice (e.g. tax or legal advice)	It is in our Legitimate Interests to manage and improve our business operations and activities	N/A

• Potential Employees (Click To Show)

  Where you provide us with information (e.g. a CV) in relation to potential recruitment at J C Roxburgh Insurance Brokers Ltd, we will collect, hold and process the following personal data:

  • General contact details such as, Name, Address, email address, Telephone number
  • General Identity Information such as Driving Licence Number, National Insurance Number
  • Employment History
  • Education History
  • Salary and Benefits History

  Special Categories of Personal Data that we can collect:

  • Trade Union Memberships

  How we collect your information

  In most cases, we collect your data directly from you. We collect data and process it when you

  • Send us a CV
  • Complete an application form
  • Provide information during an Interview
  • Email or write to us in relation to potential employment
  • Telephone us to enquire about potential employment

  Or Indirectly

  We also receive your data indirectly from the following sources:

  • Social Media Sites such as LinkedIn or Facebook
  • Public sources – demographic data, Market Research, Local Directories

  Purpose	Lawful Basis	Lawful Basis for Any Special Category of Information
  To hold your information during a recruitment process	The processing is necessary to consider entering into a Contract	N/A
  To contact potential candidates during a recruitment process	It is in our Legitimate Interest to use your personal information to keep you informed about potential vacancies where you have expressed an interest in such previously	N/A

Legitimate Interests - Where the processing of personal data is based on our Legitimate Interests, it is to improve on our service, security and prevent fraud or illegal activity in favour of the wellbeing of our (Potential) employees, customers and shareholders.

Who we share your information with?

From time to time we may share your personal information with third parties for the various purposes set out above. These are:

• Insurers with whom we are obtaining quotations or placing cover
• Other brokers who also act for you
• Industry bodies
• Accountants
• Payment Services Providers
• Regulators or Auditors
• Service Providers such as Software Providers (I.T. Suppliers, Insurance Software providers, Cloud Services)
• Lawyers
• Specialist Claims Experts, Loss Adjusters
• Fraud detection Agencies
• Police and Law Enforcement agencies where reasonably necessary for the prevention or detection of crime
• Debt Collection Agencies
• Credit Reference Agencies
• Selected Third Parties in connection with the sale, transfer or disposal of our business

Direct Marketing

We may send you details of similar services to those you have enquired about or purchased from us previously. You can opt out of receiving this information from us at any time by contacting us at the above address or clicking ‘unsubscribe’ on any messages you may receive.

We will never share or sell your information to any other party for marketing purposes.

International data transfers

Sometimes we (or third parties acting on our behalf) will transfer personal information that we collect about you to countries outside of the UK or the European Economic Area (EEA). As a safeguard to protect your information, we ensure that the relevant safeguards are in place including checking that adequacy decisions have been made for those countries or where necessary we rely on Standard Contractual Clauses (Controller to Processor).

Automated decision-making or Profiling

We do not use automated means to make decisions about your insurance, however insurers can do so when providing us with a quotation. They consider the information provided (for example, details of your cover required, local crime rates, claim rates, flood registers) to determine whether your application for insurance can be accepted and the premium. All of such decisions are however reviewed by us and you can request that the decision be made by an individual decision maker.

How Long do we keep personal data for?

We will retain personal data in accordance with legal and regulatory requirements and for no longer than is necessary to fulfil the purposes set out in this privacy policy. We maintain and review a detailed retention policy and schedule which documents how long we will hold different types of data. The time period will depend on the purpose for which we collected the information and is never on an indefinite basis. Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for tax, accounting or auditing purposes).

The following details the criteria used to establish the retention period set out within our policy.

Where it is still necessary for the provision of our Services

This includes the duration of any contract for services we have with you and for a period of 12 months after the end of any contract with a view to maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule only where we are not required to retain the data for longer.

Where required by Statutory, contractual or other similar obligations

Corresponding storage obligations may arise, for example, from laws or regulation, for example depending on the type of insurance policy we arranged for you. It may also be necessary to store personal data with regard to pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.

Your Rights as a data subject

As a data subject, you have rights in relation to your personal data. These are:

The Right to Access – You have the right to request details of personal information held or processed and to copies of this data.  We do not usually charge for this service.

The Right to Rectification – You have the right to request that any information be corrected that you believe is inaccurate or to complete any information that you believe is incomplete.

The Right to Erasure – You have the right to request that we erase your personal information under certain conditions

The Right to Restrict Processing – You have the right to request that we restrict the processing of your personal data under certain circumstances

The Right to Object to Processing – You have the right to object to our processing of your data, under certain conditions.

The Right to Data Portability – You have the right to request that we transfer the data that we have collected to another organisation or directly to you, under certain conditions.

As previously detailed, you also have the Right to Withdraw Consent where you have previously provided this at any time.

To exercise any of these rights or wish to make a complaint to us in respect of those rights, please contact us using the details at the beginning of this notice.

You also have the right to complain to the Supervisory Authority. Where you wish to report a complaint or feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office at:

Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline: 0303 123 1113

Contractual Obligations and Consequences

In some circumstances, the provision of personal data is partly required by law (for example, tax regulations, legal obligations) or can also result from contractual provisions such as payment details. This means that it may sometimes be necessary to conclude or fulfil a contract, that the personal data be provided. In those circumstances where the data is not provided or where certain rights are exercised, (Erasure, Object) there is a possible consequence that the contract could not be fulfilled or concluded and may be cancelled.

Cookies & similar technologies

When you visit our Website, we use cookies and similar technologies to provide you with a better, faster and safer user experience or to show you personalised advertising. Cookies are small text files that are automatically created by your browser and stored on your device when you visit or use the Website. For full details please see our separate Cookie Policy.

Please remember: When you click on any external links on our site including the member log in, or where you find us on social media, you are redirected to those websites.  We have no control over the privacy of those domains, so please check and review the privacy information on those sites.

How we keep your Personal Data Secure

We protect your personal data through technical and organisational security measures to minimise risks associated with data loss, misuse, unauthorised access and unauthorised disclosure and alteration. 
We store your data in in files within Insurance Software, Cloud Service Providers and use firewalls, antivirus, malware protection and encryption. We have a full data protection policy which includes a records management and information security policies. These include access controls, password security requirements, remote working and clear desk restrictions.

Changes to our Privacy Notice

All businesses and their operations change from time to time. J C Roxburgh (Financial Services) Ltd consider and embed data privacy prior to making any such changes. We keep our Privacy Notice under regular review to ensure that any changes are captured, and you are kept informed.

This Privacy Notice was last updated on 7th January 2021.