Secure Health Solutions Privacy Policy
At Secure Health Solutions, we take your privacy very seriously. We promise that all personal information we receive will be treated as strictly confidential and secure, will only be processed for lawful purposes in line with current data protection legislation and the detail provided in this privacy notice.
- Who are we?
Secure Health Solutions is a trading style of T A Advisory Limited, which is an appointed representative of Healthnet Services Ltd, authorised and regulated by the Financial Conduct Authority (‘FCA’), registration number 312313.
T A Advisory Limited is registered as a data controller on the Data Protection Register held by the Information Commissioner’s Office (‘ICO’), registration number ZB265364.
- Where do we collect personal information from?
2.1 Information you give us
We collect personal information directly from you when you:
· ask for a quote.
· contact us by telephone, fax, email or post to make a general enquiry about insurance.
· and when we administer your policy.
2.2 Information we collect about you
We collect personal information from several external sources including:
· directly from the main policyholder or member under whose policy you are covered.
· Group Secretaries for Group Schemes.
· other third parties such as:
o a family member or other representative if you are incapacitated or unable to provide information relevant to your policy.
o companies who provide consumer classification for marketing purposes.
o Insurers who have been unable to assist you.
o Lead generation companies and introducers.
2.3 Non-personal information we collect
Technical, usage and profile information which tells us how people are using our website may be automatically collected and aggregated by website analytics providers. This is done anonymously, and we cannot identify you personally. We call this ‘non-personal information’. We gather non-personal information from devices you use to connect to our website, such as computers and mobile phones, using cookies and other internet tracking software.
Non-personal information may be used to learn about online behaviour in order to improve our website and marketing messages and to provide a better brand experience. We may share non-personal information with third parties for research or statistical purposes but only when there is a legal data sharing agreement that clearly stipulates an agreed, limited purpose and which precludes any use for commercial gain.
- What information do we collect?
The information we collect depends on the product or service you are interested in. For example, if you ask us for a quote, we will ask you for identity and contact information. If you take out a policy through us, we will ask for financial information to pass on to the insurer for them to collect premiums.
In certain circumstances, we may ask for more sensitive personal information about you, such as information about your physical or mental health, so we can provide a more personal quote or assist in administering your policy. This is called ‘special category’ information.
Please see below for a more detailed summary of personal information we may collect.
| Type of Personal Information | Description |
|---|---|
| Identity | Name, address, date of birth |
| Contact | Phone number(s), email address |
| Financial | Bank account, credit card or debit card details, earnings |
| Lifestyle (special category) | Occupation, smoking and drinking habits, sports activities |
| Health (special category) | Information about physical and mental health |
| Technical | IP address, browser, operating system, network, device(s) |
| Usage | Pages visited, exit page, time spent, number of visits, searches carried out |
| Profile | Age group, gender, language, location |
| Marketing | Cookies, marketing preferences |
- How do we use personal information?
The main reason we collect personal information is so we can provide you with the health insurance cover you or your employer has purchased and to make sure we help the provider administer it correctly and efficiently. However, there are several other reasons why we use personal information, and this is explained in more detail below.
4.1 The legal basis for processing personal information
Your privacy is protected by data protection law which says we are only allowed to use personal information if we have a legal basis for doing so. We have explained below the main reasons why we process personal information and the legal basis we rely on.
· To provide an insurance quote and to assist the insurance provider in administering an insurance policy and associated services. This includes sending information to a customer about their policy. In these circumstances, if the personal information we need is not given to us, we will be unable to provide a quote or offer a policy.
· We have a regulatory duty to process personal information. For example, the Financial Conduct Authority and the Information Commissioner’s Office require us to keep customer records.
· So we can establish, exercise, or defend our legal rights. For example, if we have a legal claim brought against us or we want to pursue our own legal claim or rights.
· For reasons of substantial public interest, such as investigating and preventing fraud.
· Where a customer has agreed we can use personal information (‘consent’). This can be by providing information about other products and services that might be of interest. If we ask for consent, we will explain why it is needed.
· Where we have a legitimate business need to use personal information as long as it does not interfere with a customer’s information rights and freedoms and does not cause any harm.
We also have a legal exemption that allows us to process special category information as an essential part of providing and administering an insurance policy.
- Who do we share information with?
We will not sell, distribute, or lease any data to third parties or any other organisations to use for their own commercial purposes unless we have your permission or are required to do so by law.
In order to provide our products and services, personal information may be shared with third parties who, for example, assist in our business administration or the prevention and detection of fraud. These third parties might include:
a) Insurance providers. We need to pass your information on to obtain quotations and set up policies on your behalf, and also to deal with any subsequent queries you may have with them and your renewals.
b) A relative or guardian acting on your behalf where you are incapacitated or unable to act for yourself, or other people or organisations associated with you such as your insurance provider or lawyer.
c) A named alternative contact (such as a relative or advisor) that you have appointed to speak to us on your behalf and who is authorised, by you, to discuss all aspects of your policy with us and can make changes on your behalf.
d) The underwriter and the reinsurer who provides your insurance cover.
e) Suppliers and providers of goods or services we make available to you.
f) Regulatory bodies such as the Financial Conduct Authority or the Information Commissioner’s Office.
g) The Financial Ombudsman Service if a complaint is made through it.
h) Other insurance companies, NHS fraud teams, the General Medical Council, the police and any law enforcement agencies and organisations that maintain anti-fraud databases where necessary for the prevention or detection of crime.
The extent of personal information we disclose will be limited to that which is necessary for the third party to carry out its purpose and we will not pass personal information, including special category information, to any third party if it is not needed.
- How do we process your information?
Steps are taken to ensure the data we hold is accurate, kept up to date and not kept for longer than is necessary. Measures are taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to the data.
From time to time, it may be necessary to process data outside of the European Economic Area (EEA). We will take all reasonable steps to ensure any organisation used to process data in these situations provides appropriate guarantees in respect of its technical and organisational security measures and that the transfer and processing of data complies with all relevant data protection and privacy laws.
- Cookies
Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different and useful jobs, such as remembering your preferences and generally improving your online experience.
We never store your personal details in cookies. If you want to block cookies, you can turn them off in your browser settings, but the quality of your online experience will be reduced.
- How long do we keep personal information for?
We only keep personal information for as long as it is reasonably necessary, but it will depend on what information we hold, why we hold it and what our wider regulatory obligations are.
We typically keep information provided in quotes (where no policy is purchased) for no more than six months and information provided in respect of a policy for no more than six years after a policy