WEBSITE PRIVACY NOTICE

Lockton Companies LLP Website Privacy Notice

Last Updated: 15 May 2018

Introduction

Lockton Companies LLP is committed to protecting and respecting your privacy.

This privacy notice (“Notice”), together with the Terms of Use and Cookies Statement , sets out how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
For the purposes of this Notice, “Lockton”, “we”, “us” or “our” refers to Lockton Companies LLP, a limited liability partnership with company number OC353198 and its registered office at The St Botolph Building, 138 Houndsditch, London, EC3A 7AG, an independent insurance and reinsurance intermediary authorised and regulated in the United Kingdom by the Financial Conduct Authority (FCA) under Firm Reference Number 523069.

Please also use the Glossary to understand the meaning of some of the terms used in this Notice.

This Notice is provided in a layered format so you can click through to the specific areas set out below.


Contents of this Notice

This Notice sets out the following:

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE MAY COLLECT ABOUT (YOUR PERSONAL DATA)
3. WHERE WE MIGHT COLLECT YOUR PERSONAL DATA FROM
4. THE PURPOSES, CATEGORIES, LEGAL GROUNDS AND RECIPIENTS, OF OUR PROCESSING OF YOUR PERSONAL DATA
5. DATA SECURITY
6. RETENTION OF YOUR PERSONAL DATA
7. INTERNATIONAL TRANSFERS
8. YOUR LEGAL RIGHTS AND CONTACT DETAILS OF THE ICO
9. GLOSSARY OF TERMS

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1. Purpose of this Notice

This Notice aims to give you information on how Lockton Companies LLP collects and processes your personal data through your use of this website, including any data you may provide through this website, for example when you sign up to our newsletter or fill in our contact us form.

Lockton is committed to protecting the privacy needs of children and encourages parents and guardians to take an active role in their children’s online activities and interests. Lockton does not intentionally collect information from children, and Lockton does not target its Site to children.

It is important that you read this Notice, together with any other privacy notices we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information. This Notice supplements the other notices and is not intended to override them.

1.2. Controller

Lockton Companies LLP is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Laws to notify you of the information contained in this Notice.

1.3. Data Protection Manager

We have appointed a data protection manger to oversee compliance with and questions in relation to this Notice.

If you have any questions about this Notice, including any requests to exercise your legal rights, please contact our Data Protection Manager using the details set out below:

CONTACT DETAILS
Data Protection Manager
Lockton Companies LLP
The St Botolph Building
138 Houndsditch
London
EC3A 7AG
Email: dataprotection@uk.lockton.com

1.4. Changes to this Notice and your Duty to inform us of Changes

This Notice may be updated from time to time. We encourage you to review this Notice regularly when you visit our website to learn more about how we are using your personal data and safeguarding your privacy.

This version is dated 15 May 2018 and historic versions can be obtained by contacting our Data Protection Manager.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.5. Third Party Links

Our website may, from time to time, contain links to and from third-party websites, plug-ins and applications, including without limitation websites of our partner networks and affiliates. Clicking on those links may allow third parties to collect or share data about you. Please note that these third-party websites have their own privacy notices and we do not control those websites or accept any responsibility or liability for these privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit. This Notice applies solely to information collected by Lockton when you visit our website.

2. THE DATA WE MAY COLLECT ABOUT (YOUR PERSONAL DATA)

The types of personal data that we process may include:

types of personal data: Details:

Individual details

First name, last name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, employer, and job title

Technical data

internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website

Usage data

Information about how you use our website, products and services, including information from your visit from cookies, such as clickstream to, through and from our website (including date and time), items you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as clicks), and methods used to browse away from the page

Marketing and communications data

Your preference in receiving marketing from us and our third parties and your communication preferences


 

Personal data does not include data where the identity has been removed (anonymous data).

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you or are trying to enter into with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with insurance broking services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. WHERE WE MIGHT COLLECT YOUR PERSONAL DATA FROM

We might collect your personal data from various sources, including:

Sources

Direct interactions

You may give us your Individual Details by filling in forms or corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• make enquiries about or request our services
• subscribe to receive our newsletters or publications
• request marketing to be sent to you
• give us some feedback

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Statement for further details

Third Parties or publicly available sources

We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:
    • Analytics providers such as Google
    • Search information providers:
      • Individual Details from publicly available sources such as the open electoral register and Companies House
      • Individual Details from data brokers or aggregators

 

4. THE PURPOSES, CATEGORIES, LEGAL GROUNDS AND RECIPIENTS, OF OUR PROCESSING OF YOUR PERSONAL DATA

4.1. We set out below the purposes for which we might use your personal data:

Purposes:

Relationship Management

  • To provide you with information, products and services that you request from us, and taking steps at your request prior to entering into a contract

Website Management

  • To administer and protect our business and this website and for internal operations, including to keep our website safe and secure, data analysis, troubleshooting, testing, system maintenance, support, reporting and hosting of data, research, statistical and survey purposes
  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences, including to ensure that content from our website is presented in the most effective manner for you and for your computer

Marketing

  • To make suggestions and recommendations to you about products or services that may be of interest to you, to provide industry insight or to invite you to events
  • To measure and understand the effectiveness of marketing we serve to you and others and to deliver relevant marketing to you

 

Please note that in addition to the disclosures we have identified against each purpose, we may also disclose personal data for those purposes to our service providers, contractors, agents and group companies that perform activities on our behalf.

4.2. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Marketing communications from us

You will receive marketing communications from us if you have requested information from us (including for example where you have provided your explicit consent by way of opting-in to receiving our marketing communications in accordance with applicable law) or purchased services from us, or (where you are a corporate entity) where we consider the marketing material to be relevant to you and, in each case, you have not opted out of receiving that marketing.

Such marketing communications may include risk or insurance related information or details of services, or products, or events, which we think, may be of interest to you.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside the Lockton group of companies for marketing purposes.

Managing your Marketing Preference (including Opting Out)

You can manage your marketing preferences or ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting our Data Protection Manager at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions, and will not affect communications relating to any such matters on which we are advising you.

4.3. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Statement 

4.4. Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Manager.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.5. Legal Grounds for Processing

We will only use your personal data when the law allows us to. In particular, we will rely on the following legal grounds to use your personal data:

For processing personal data  

Legal ground

Details

Your explicit consent (optional)

You have given your explicit consent to the processing of those personal data for one or more specified purposes.

 

You are free to withdraw your consent, by contacting our Data Protection Manager

Performance of our contract with you

Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract

Compliance with a legal obligation

Processing is necessary for compliance with a legal obligation to which we are subject

For our legitimate business interests

Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where you are a child. These legitimate interests are set out next to each purpose below

4.6. Disclosure of your Personal Data

We may have to share your personal data with the parties set out below for the Purposes set out in the table above.

disclosures

Internal third parties

Other companies in the Lockton group (which means our subsidiaries and ultimate holding company and its subsidiaries) who provide IT and system administration services and undertake leadership reporting

External third parties

  • Service providers who provide IT and system administration services
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
  • Police
  • Courts
  • FCA, PRA, ICO and other regulators and authorities who require reporting of processing activities in certain circumstances
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Notice

4.7. The Purposes, Categories, Legal Grounds and Recipients, of our processing of your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, including the categories of personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate, and the third parties with whom we need to share your personal data.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact our Data Protection Manager if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose Categories of personal data Legal grounds Disclosures

RELATIONSHIP MANAGEMENT
To provide you with information, products and services that you request from us, and taking steps at your request prior to entering into a contract

  • Individual Details
  • Marketing and Communications Data
  • Performance of a contract with you
  • Compliance with a legal obligation
  • For our legitimate business interests (to correspond with you)

 

WEBSITE MANAGEMENT
To administer and protect our business and this website and for internal operations, including:
(i) to keep our website safe and secure, data analysis, troubleshooting, testing, system maintenance, support, reporting and hosting of data, research, statistical and survey purposes;
(ii) transferring books of business, company sales and reorganisations; and
(iii) complying with our legal and regulatory obligations

  • Individual Details
  • Technical Data
  • Marketing and Communications Data

 

  • For our legitimate business interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of business reorganisation or group restructuring exercise)
  • Compliance with a legal obligation

 

 


WEBSITE MANAGEMENT

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences, including to ensure that content from our website is presented in the most effective manner for you and for your computer

  • Technical Data
  • Usage Data
     
  • For our legitimate business interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
  • Internal third parties
  • External third party service providers who provide IT and system administration services
  • Purchaser
  • Courts
  • FCA, ICO and other regulators
  • Police
  • Professional advisers

MARKETING
To make suggestions and recommendations to you about products or services that may be of interest to you, to provide industry insight or to invite you to events

  • Individual Details
  • Technical Data
  • Usage Data
  • Marketing and Communications Data
  • For our legitimate business interests (to develop our products/services and grow our business)
  • Explicit Consent (optional) (where required by law)
  • External third party service providers who provide IT and system administration services

MARKETING
To measure and understand the effectiveness of marketing we serve to you and others and to deliver relevant marketing to you

  • Individual Details
  • Marketing and Communications Data
  • Technical Data
  • Usage Data
  • For our legitimate business interests (to understand how customers use our products and services, to develop them and grow our business, and to inform our marketing strategy)
 

5. DATA SECURITY

Unfortunately, the transmission of data over the internet or any website cannot be guaranteed to be completely secure from intrusion. However, we have put in place appropriate physical, electronic and procedural security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.


We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. RETENTION OF YOUR PERSONAL DATA

How long will you use my personal data for?

We will keep your personal data only for so long as is necessary and for the purpose for which it was originally collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your personal data: see Section 8 (Your Legal Rights and Contact Details of the ICO) below.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. INTERNATIONAL TRANSFERS

We may need to transfer your data to other companies within the Lockton group or to our affiliates or sub-contractors which are located outside of the European Economic Area (EEA). Those transfers would always be made in compliance with the GDPR.

If you would like further details of how your personal data would be protected if transferred outside the EEA, please contact our Data Protection Manager.

8. YOUR LEGAL RIGHTS AND CONTACT DETAILS OF THE ICO

If you have any questions about this Notice or in relation to our use of your personal data, you should first contact our Data Protection Manager. Under certain conditions, you may have the right to require us to:

  • provide you with further details on the use we make of your personal data/special category of data;
  • provide you with a copy of the personal data that you have provided to us;
  • update any inaccuracies in the personal data we hold;
  • delete any special category of personal data/personal data that we no longer have a lawful ground to use;
  • where processing is based on consent, to withdraw your consent so that we stop that particular processing;
  • object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
  • restrict how we use your personal data whilst a complaint is being investigated.

In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

If you wish to exercise any of the rights set out above, please contact our Data Protection Manager.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Your Right to Complain to the ICO

If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights in Section 8: Your Rights and Contact Details of the ICO, or if you think that we have breached the GDPR, then you have the right to complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Please see below for contact details of the ICO.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

England Scotland Wales Northern Ireland

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Information Commissioner’s Office
45 Melville Street
Edinburgh
EH3 7HL

Information Commissioner’s Office
2nd Floor
Churchill House
Churchill Way
Cardiff
CF10 2 HH

Northern Ireland
Information Commissioner’s Office
3rd Floor
14 Cromac Place
Belfast
BT7 2JB

Tel:
0303 123 1113 (local rate) or
01625 545 745 (national rate)

Tel: 0131 244 9001

Tel: 029 2067 8400

Tel:
0303 123 1114 (local rate) or
028 9027 8757 (national rate)

Email:
casework@ico.org.uk

 

Email:
scotland@ico.org.uk

 

Email:
wales@ico.org.uk

 

Email:
ni@ico.org.uk

 

 

9. GLOSSARY OF TERMS

Key data protection terms:

Data Protection Laws means all laws and regulations relating to the Processing of Personal Data, including the GDPR, as the same may be in force from time to time.

GDPR is the EU General Data Protection Regulation and the new UK Data Protection Act, which replaces the UK Data Protection Act 1998 from 25 May 2018.

Data Controller is an entity which collects and holds personal data. It decides what personal data it collects about you and how that personal data is used.

Information Commissioner’s Office (ICO) is the regulator (or National Competent Authority/Data Protection Authority) for data protection matters in the UK.

Personal Data is any data from you which can be identified and which relates to you. It may include data about any claims you make.

Processing of personal data includes collecting, using, storing, disclosing or erasing your personal data.