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This website www.libertyspecialtymarkets.com (the “Site”) is operated for and on behalf of Liberty Specialty Markets Limited, Liberty Managing Agency Limited and Liberty Mutual Insurance Europe Limited™, together trading with Liberty Mutual® Reinsurance (a division of Liberty Mutual Insurance Company) as Liberty Specialty Markets® (“Liberty”, “we”, “our” or “us”). For more information on each of these entities, please see this Site.
2. Collection of Personal Data
Who is responsible for your personal information?
“You” shall include, as relevant, individual insured customers such as sole traders, a company’s owners, directors, partners and/or any individual who may be covered by an insurance policy with Liberty.
What details do we collect and why?
Subject to data protection laws, we will use the personal information you provide, or which is otherwise collected from you or third parties, whether online or offline, for various purposes depending on our relationship with you and/or the person you represent.
For example, this may include (as applicable):
• to register you as a user of the Site,
• to send information you request, to handle your insurance queries, applications and any policy and related claims,
• to manage and deal with your claim against our insured customer or to deal with your appointed agent, or representatives,
• for underwriting, claims handling, fraud prevention, anti-money laundering and counter terrorism financing purposes, and
• if you submit a CV to us through this website, for the purpose of recruitment.
We will do this at a local company and/or at a Liberty Mutual Insurance Group level as appropriate (further details below) and this will be carried out subject to applicable law. This personal information will be held in the data systems of Liberty or by our agents or subcontractors or by other Liberty Mutual Insurance Group companies (further details below).
We may use this personal information for our business processes and activities including analysis, review, audit, forecasts, business planning and transactions (including joint ventures and business sales), and dealing with insurance and/or legal claims; and for compliance with our legal, regulatory and other good governance obligations.
We may need to collect sensitive personal information about claimants and individual insured customers (such as information about physical or mental health or medical conditions, criminal convictions and pending proceedings, and bankruptcy/debt details) and others named on an insured customer’s insurance policy and third parties involved in a claim.
By going ahead with a Liberty insurance quote or policy, making a claim against a Liberty insured customer, or submitting personal information including sensitive personal information, as applicable, you will be explicitly agreeing to us, our agents, other insurers and the other persons who we describe in this notice processing that information for all purposes as are or may be relevant from time to time to your relationship with Liberty, including but not limited to those described in this notice. Before you provide personal information including sensitive personal information about others (e.g. from the other people named on your policy, your staff, personnel, company owners, directors or partners if you are an insured customer, or from the person on whose behalf you are claiming against a Liberty insured customer if you are an agent), you should make sure they have seen a copy of this notice and make sure they agree to you disclosing it to us.
We may amend the personal information so that you cannot be identified from the data either by itself or when combined with any other data we hold. That data will not be subject to this notice or data protection law. We may use it for insurance administration purposes including analysis of trends, carrying out actuarial work, planning insurance service delivery, risk assessment and costs and charges.
3. What details do we share, who with and why?
We may share information about you and your claims history with:
• our reinsurers, agents, loss adjusters and other service providers;
• other insurers, either directly or through people acting for us and them (such as loss adjusters or private investigators);
• other Liberty Mutual Insurance Group companies (both inside and outside the EEA, including in the USA, Canada, Australia, Singapore, Hong Kong and Malaysia), their reinsurers, agents, loss adjusters and other service providers;
• any agent or representative acting for you;
• recognised trade, governing and regulatory organisations we belong to or are governed by;
• the police, other law-enforcement agencies, government agencies or regulatory authorities, and any other person or organisation to comply with insurance law; and
• any other person where necessary to perform any insurance contract with you, in order to protect ourselves from risk or to ensure regulatory compliance or good governance.
We may exchange information with the Claims and Underwriting Exchange Register, run by Insurance Database Services Ltd (IDS Ltd) and the Motor Insurance Anti-Fraud and Theft Register, run by the Association of British Insurers (ABI). The aim is to help us check information and to prevent fraudulent claims. When we deal with your request for insurance, we may search these registers. Under the conditions of your policy, you must tell us about any incident which may or may not give rise to a claim. When you tell us about an incident, we will pass information about it to these registers.
Fraud prevention, money laundering and counter terrorism financing checks
If false or inaccurate information is provided by you or on your behalf or if we suspect or identify fraud, or if we have reason to believe you are involved in money laundering or terrorism financing, we will record this and may pass this information to fraud prevention agencies (FPAs), law enforcement agencies and other organisations involved in crime and fraud prevention, who may access and use this information to prevent and detect fraud and money laundering. We may use this information for those purposes when checking policy application details or during the policy term or at renewal. We may make searches at FPAs during the policy term or at renewal. We may make anti-money laundering and counter terrorism financing checks during the policy term or at renewal. We may also access and use, from other countries, the information recorded by FPAs. Other organisations as well as other Liberty Mutual Insurance Group companies which may do the same.
In accordance with legal and regulatory requirements and our compliance and risk management procedures we undertake due diligence and screening on the business that we underwrite, any financial transactions we make and all other non-underwriting activities in which we engage. We will use the information you provide for these purposes. This will include checking your information against sanctions lists, such as those published by United Nations, European Union, UK Treasury and USA Office of Foreign Assets Control (OFAC).
We may transfer your information to the Liberty Mutual Insurance Group company in the USA that operates our internal screening function for the purposes of carrying out some of these checks. Although the USA does not have a similar standard of data protection laws to the UK, we will require your personal information to be protected to at least UK standards.
If the checks reveal an actual or potential match with a sanctioned person we may provide details of the match together with any information that we hold about you or that is disclosed on the sanctions lists to other Liberty Mutual Insurance Group companies, regulators, government and law enforcement bodies for further investigation, legal or risk management purposes. We may also contact you in order to obtain further details which may help us to clear or confirm the potential match. We may retain the information that has been collected or used to carry out the checks, and records of the checks, for the period required in order to comply with our internal compliance and data retention policies.
Credit reference checks
We may make searches about you with credit reference agencies (CRAs) to obtain information on you, including on your credit history, when checking policy application details or during the policy term or at renewal. We will make checks such as assessing your credit history and verifying your identity in order to prevent and detect crime, fraud and money laundering. We may make searches at CRAs during the policy term or at renewal. If you do not make payments that you owe to us, we will trace your whereabouts and recover debts.
The CRAs supply us with both public (including electoral register) and shared credit and fraud prevention information. When these records are searched, CRAs will place a search footprint on your credit file that may be seen and used by other insurers, lenders and other companies unrelated to us. Some searches for credit scoring purposes do not leave a footprint visible to others.
The CRAs may add details of our search and your application to the records they hold on you. If you are making a joint application or tell us that you have a spouse or financial associate we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records to those to whom you are linked financially.
Credit searches and other information provided to the CRAs about you may be supplied by CRAs to other companies to perform similar checks and to trace your whereabouts and recover debts that you owe. For example, if you borrow and do not repay in full and on time CRAs will record the outstanding debt. Records remain on file for 6 years after they are closed, whether settled by you or defaulted.
CRAs may also use the information referred to in this section for the purpose of statistical analysis about credit, insurance and fraud.
We may also access and use, from other countries, the information recorded by CRAs. Other organisations as well as other Liberty Mutual Insurance Group companies may do the same.
You can contact the CRAs currently operating in the UK. The information they hold about you may not be the same so you may wish to contact more than one. They may charge you a small statutory fee.
• CallCredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 0601414
• Equifax PLC, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583 or log on to www.myequifax.co.uk
• Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk.
Where are your details sent?
The personal information, including the sensitive personal information described above, may be transferred to countries outside the European Economic Area (i.e. all countries in the European Union together with Norway, Iceland, and Liechtenstein) including to Liberty Mutual Insurance Group companies and our/their agents and service providers. We will seek to ensure that the level of protection which applies to your personal information processed in such countries is similar to that which applies in the UK, for example, by using the appropriate set of EU Commission approved “Model Clauses” in a data transfer agreement.
4. Objecting to processing; accessing, correcting and obtaining copies of your personal information
You may object to the processing of your personal information in accordance with this notice, but please note that this may result in our not being able to provide the appropriate type or level of services you require.
You also have the right to request a copy of the information we hold about you, upon payment of £10 which we are permitted to charge by law in order to cover some of our administration costs in responding. You may also request the amendment or deletion of any information we hold about you and we will make all reasonable efforts to update our records if it is deemed appropriate. Please help us to ensure your personal information is accurate by telling us as soon as reasonably possible in the event of change of address, contact details or other circumstances.
In order to exercise any of the above rights, please contact our General Counsel at Liberty Specialty Markets, 20 Fenchurch Street, London, EC3M 3AW.
5. Cookie Statement
6. Data Integrity and Security
The security measures in place on our website and computer systems are in place to protect the loss, misuse or alteration of the information you provide to us. We keep your personal data only for as long as reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
Because e-mails submitted via this website are not protected by the same security measures we use in other areas where we actively collect information, you should be particularly careful in deciding what information you wish to send to us via e-mail.
In the event that you become aware of any actual or potential misuse of any such information, please contact our General Counsel at Liberty Specialty Markets, 20 Fenchurch Street, London, EC3M 3AW as soon as possible.
7. Other Websites
Please note that we are not responsible for the privacy policies or content of any websites linked to this website, including websites of companies within the Liberty Mutual Insurance Group.
9. Contacting Us
If you have any questions about this policy you should contact our General Counsel at Liberty Specialty Markets, 20 Fenchurch Street, ECM 3AW.
Last revised September 2015