Privacy Notice
Introduction
Jade Insurance Management DAC is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.
It is the intention of this privacy statement to explain to you the information practices of Jade Insurance Management DAC in relation to the information we collect about you.
For the purposes of the GDPR the data controller is Jade Insurance Management DAC
Contact Details:
Address: 69 St Patricks Road, Dalkey, Co Dublin
Email: dataprotection@jadeinsurance.ie
Tel: +353 1 284 9246
Our GDPR Owner and data protection representatives can be contacted directly at:
Name: William Murphy
Email: william@jadeinsurance.ie
Phone: +353 1 284 9246
When we refer to ‘we’ it is Jade Insurance Management DAC
Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Who are we?
We are a firm of Insurance Brokers regulated by the Central Bank of Ireland and registered to undertake insurance mediation.
Purpose for processing your data
We process data in order to carry out our services to you in relation to insurance contracts that we assist you with, including presenting your risk details and material information to underwriters and related services such as claims handling, contract reviews, premium collection and financing, and other matters that arise from time to time in relation to our insurance broking services, in accordance with Data Protection Law.
Changes to our Communication and Claims Process from the 25th May 2018:
Policy Administration
We will communicate and take instruction from the policy holder in relation to the administration of the policy (e.g. cover sets, payments/refunds, renewals, cancellations).
If the policy holder would like to authorise another individual to deal with the administration of the policy on their behalf, please contact us for details.
Claims and related information:
We will communicate directly with each adult insured on a policy in relation to their own claim. We can only discuss claims information with the individual it relates to, subject to some limited exceptions.
Regarding payments, we will make claims payment to the specified bank account details provided. If there are multiple claimants on a claim, cheque payments and claims statements will be issued to the policy holder.
Jade Insurance Management Data Protection Statement-Insurance, Assurance, Protection, Pensions.
What is the purpose of this notice?
Our promise to you is that ‘when you need us, we’re there. In order to fulfil that promise, and to provide you with suitable products and services, we need to get to know you and what your needs are.
This means that we collect certain information about you in the course of operating our business. This notice set out the details of the information that we collect, how we process it and who we share it with. It also explains you rights under the data protection law in relation to our processing of your data.
Who Controls the use of your personal data?
Jade Insurance Management DAC whose registered address is Jade Insurance Management,69 St Patricks Road, Dalkey, Co Dublin is the company that controls your data and is responsible for personal data that is collected in relation to our Insurance, Assurance, Protection, Pensions products. If you have any queries in relation to the processing of your personal data, you can contact us: by post Data Protection Jade Insurance Management DAC or dataprotection@jadeinsurance.ie
What Personal Data is collected?
In order to provide our services to you we need to process certain personal data in relation to you, which includes:
Biographical data – We collect the following biographical data: name, assumed names, address, phone number, email, address, gender, family relations (e.g. material status, cohabitating spouse, children date of birth, PPS number and if you are a student or in college.
Payment data – If you pay by direct debit or receive payments through electronic funds transfers, we will collect the IBAN, BIC and name of your bank/ building society/credit union /similar or your credit card details where relevant.
Claims data – If you make a claim we will process details on your behalf. By liaising and making submissions with the Insurer/Assurer concerned and make submissions for your case.
Interactions with us – If you interact with us we will record details of those interactions (e.g. phone calls, and logs of phone calls, email correspondence and hard copy correspondence). If you make a compliant we will process details in relation to that complaint.
Online services – When you interact with us online (by computer, tablet or smart phone), you will often provide personal data to us, which you will be aware of when using the services or for which you give consent. We also automatically collect data about your use of our services, such as the type of device of device you are using and its IP address, and how you interact with the services. Further details are available in the cookies policy and/or the data protection statement that accompanies the relevant service.
Where does Jade Insurance Management DAC collect personal data from?
Most of your personal date that we collect will be provided by you through our Fact Find, Insurers and Assurers application forms, claims forms and your interactions with us. However, certain information may be provided by third parties on your behalf, including the following:
Group Schemes – Many of our client’s avail of our services through a group scheme that is operated by their employer, In order to interact with you, your employer may give us certain details such as your name, address, gender, date of birth, contact details, details of dependants and their relationship to the policy holder, previous insurance/ assurance/Pension details, employee and group scheme number and PPS number. This information may be provided electronically.
Dependants – If you are covered on a policy, the policy holder may have provided us with certain details, such as your name, address, gender, date of birth, contact details, relationship to the policy holder, previous insurance/ assurance/Pension details, and PPS number.
Online services – When you interact with us online we will collect the information that you provide to us. We also automatically collect data about your use of our services, such as the type of device of device you are using and its IP address, and how you interact with the services.
Other Insures/Assurers – We may receive your personal data from other insurers to verify your previous insurance details as well as for other regulatory reasons.
Why do you process my personal data?
We process your personal data in order to provide you with our services and to assist us in the operation of our business. Under data protection law we are required to ensure that there is an appropriate basis for the processing of your personal data, and we are required to let you know what that basis is.
There are various options under data protection law, but the primary basis that we use are (a) processing necessary for the performance of our contracts with you (b) processing necessary in order for us to pursue our legitimate interest, (c) processing where we have your and /or your dependants’ consent, and (d) processing that is required under applicable law.
Here are further details of our processing of your personal data below, together with the basis for that processing:
Administering your policies – We will process your personal data in order to administer your policy. This includes processing your personal data in order to make and receive payments, and to maintain our records of the insurance/Assurance/ Pension products that you have purchased. Where we process your personal in order to administer your policy this will be on the basis that it is necessary in order for the performance of our contract with you.
Providing you with services – Jade Insurance Management DAC provides different channels to engage with you in order to perform our contractual obligations, including where you have opted to avail of electronic channels such as email, agency provider web sites for direct interaction with the Insurance / Assurance/ Pension provider. These applications give you access to your policy documents in a secure place anytime, anywhere.
Processing claims – In order to process claims that you make under a policy we will need to process personal data in relation to the claim. This includes details pertaining to nature of the claim in the case or a property, car accident, medical conditions that is being treated, your medical history, details of previous policies you may have had. We will also need to process your personal data in order to deal with queries about your level of cover under your policy that are most relevant to you.
If your claim is successful, we will process your personal data in order to pay you the necessary/agreed compensation set out by the Insurers / Assurers or have the Insurers / Assurers make the payment direct to you.
Running our business – The data we collect may be used to help us develop new services. We also carry out auditing and quality control to check that our processes are robust and are being followed. In addition, we also need to process your data to meet certain regulatory and legislative obligations that apply to our business.
Marketing – if you consent to us sending you marketing messages about our products and services we will process your personal data in order to make sure that any marketing message that we send to you are relevant to you. With your permission, this may include processing your data to identify services that might be particularly relevant to you. We may also use it to ensure that we don’t send your details about a service that isn’t relevant to you. At policy renewal this could mean processing details of you claims history to help us identify what your needs are and processing details of your pension history to help us identify what your needs are, what might be the most appropriate policy for you/ appropriate financial advice regarding your pension requirements and whether you are likely to change or cancel your policy.
Fraud prevention and claim management- It is an unfortunate feature of any insurance system that fraud may occur from time to time, we have a number of systems and procedures in place to monitor for potentially claims. If we identify a suspicious claim or pattern of claims, we will process your personal data in order to investigate the claim and take the appropriate measures to protect and inform Insurers/ Assurers.
Administering our computer systems – Jade Insurance Management relies on up to date technology and computer systems to run our business and to process claims. We have specialists IT supports who are constantly testing our systems, running trials and updating software.
Consent
In order to process certain personal data in relation to you, for certain purposes such as direct marketing, we may need to get your consent. When we process your personal data on the basis of your consent, you are free to withdraw that consent at any time. You can withdraw your consent by contacting us using the contact details at the bottom of this notice. Please note that if you withdraw your consent we may not be able to continue providing you with the services to which your consent related.
Information you are obliged to provide
We require certain information from you in order to be able to enter into a contract with you to provide you with our services.
Who do we share your personal data with?
We share your personal data with the following parties:
Service providers – We rely on trusted third parties to help us run the Jade Insurance Management DAC business and to provide us with specialised services. These can include companies that provide IT services (e.g. scanning and uploading letters from customers and hosting data when providing software services). These can also include legal advisors, accountants and consultants. Where our service providers have access to your personal data, we ensure that they are subject to appropriate contracts and safe guards.
Group schemes – Many of our client’s avail of our services through a group scheme that is operated by their employer. In order to administer your policy Jade Insurance Management DAC may exchange certain details, such as your name, address, gender, date of birth, contact details, details of dependants and their relationship to the policy holder, previous insurance/ assurance/Pension details, employee and group scheme number and PPS number. This information may be provided electronically.
Regulators – In certain circumstances Jade Insurance Management DAC is obliged to provide information to a regulator, (The Central Bank)
Other Insurers – We may share your personal data with other insurers in order to verify your level of cover as well as for other regulatory reasons.
Transfer outside of the European Economic Area (EEA)
There may be certain circumstances where we will transfer your personal data outside of the EEA to a country which is not recognised by the European Commission as providing an equivalent level of protection for personal data as is provided for in the EEA. If we transfer your personal data outside the EEA pleas rest assured that we will ensure that appropriate measures are in place to protect your personal data and to comply with our obligation under applicable data protection law. This may mean that we enter into contacts in the form approved by the European Commission, or we ensure that the company to which we transfer your personal data has agreed to abide by an approved transfer mechanism, such as the EU-US privacy shield framework.
Retention of personal data
Jade Insurance Management DAC will retain your personal data in accordance with our record retention policy. This policy operates on the principle that we keep personal data for no longer than is necessary for the purpose for which we collected it. It is also kept in accordance with any legal requirement that are imposed on us. This means that the retention period for your personal data will vary depending on the type of personal data
Statutory and regulatory obligations – As we work in a highly regulated industry, we have certain statutory and regulatory obligations to retain personal data for set periods of time.
Managing legal claims – When we access how long to keep personal data we take into account whether that data may be required in order to defend any legal claims which may be made. If such data is required, we may keep it until the statute of limitations runs out in relation to the type pf claim that can be made (which varies from 2 to 12 years)
Business requirements – As we only collect personal data for define purposes, we access how long we need to keep your personal data for in order to meet our reasonable business purposes.
Your Rights
You have various rights under the data protection law, subject to certain exemptions, in connection with our processing of your data:
Right to access the data- You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
Right to rectification- You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
Right to erasure- You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
Right to restriction of processing or to object to processing- You have the right to request that we no longer process your personal data for particular purposes.
Right to data portability- You have the right to request us to provide you, or a third party, with a copy of your personal data in a structure, commonly used machine-readable format.
In order to exercise any of the above rights, please contact us using the contact details set out below.
Questions and Complaints
If you have any queries or complaints in connection with our processing of your personal data, you can get in touch with us using the following contact details:
Post: Data, Jade Insurance Management DAC , 69 St Patrick Road, Dalkey, Co Dublin Republic of Ireland.
E-Mail dataprotection@jadeinsurance.ie
You also have the right to lodge a complaint with the Date Protection Commission if you are unhappy with our processing of your personal data. Details of how to lodge a complaint can be found on the dataprotection.ie website, or you can call the Data Protection Commission on 1890 252 231
