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Privacy policy

PLEASE READ THIS PRIVACY POLICY IF YOU’RE A CUSTOMER OR A CUSTOMER REPRESENTATIVE

If you’re an adviser, please read our adviser privacy policy.

PROTECTING YOUR PERSONAL INFORMATION

The Data Protection Act requires us to manage personal information in line with the data protection principles. In particular, we need to process your personal information fairly and lawfully. We collect, hold and use your personal data, and you’re entitled to know how we intend to use any information you give us.

As employees, we’re personally responsible for keeping your information confidential. We’re all given training and education to remind us about our obligations. Our policies and procedures are also regularly audited and reviewed.

Please read this privacy policy carefully as you’ll be legally bound by it. We reserve the right to amend it at any time and to let you know by posting an updated version on our website. You’ll be deemed to have accepted the amendments by continuing to hold our products, use our websites and submit your information to us either directly or through a Financial Adviser.

Any reference to ‘we’, ‘us’ or ‘our’ means Guardian Financial Services Limited as an appointed representative of Scottish Friendly Assurance Society Limited.


WHO WE ARE

Guardian Financial Services Limited is an appointed representative of Scottish Friendly Assurance Society Limited which is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority. Registered office: Scottish Friendly House, 16 Blythswood Square, Glasgow G2 4HJ. Registration number 110002.

Guardian Financial Services Limited is registered in England and Wales under number 11115769. Registered office: 11 Strand, London WC2N 5HR.


WHERE WE GET YOUR INFORMATION AND HOW WE USE IT

We’ll hold your personal information securely in our systems so that we, either now or in the future, can manage your relationship with us.

How we receive and use this information depends on who you are. There are separate sections below for customers and their representatives.

CUSTOMERS

As a customer, you need to give us your permission to use your information so that we can provide you with the product or service you want. This includes for example:

  1. Information you give your Financial Adviser, or that you or others give us, in relation to your application.
  2. Information provided in emails and letters, during phone calls, when registering for services, in customer surveys, and when you take part in competitions and promotions.
  3. Information you give us during the life of your policy, including if you claim or cancel.
  4. Information we receive from or through other organisations (such as other insurance companies, credit reference agencies, anti-money laundering and fraud prevention agencies) whether in the course of providing products and services to you or otherwise, and from information we gather from your use of and interaction with our internet and mobile services and the devices you use to access them.

Your Financial Adviser will ask you for your permission.

Using and sharing this information helps us to understand your needs better and administer your policies in the efficient way you expect.

CUSTOMER REPRESENTATIVES

If you’re representing a customer, you may be a claimant, beneficiary, trustee or other individual. We’ll collect information that you provide, or that a Financial Adviser, customer or other party provides about you, in relation to an application, policy or claim for one of our products or services.

CUSTOMERS AND THEIR REPRESENTATIVES

Whether you’re a customer or their representative, we may use and share the personal information we hold about you for the following administrative activities:

  1. Providing your Financial Adviser with quotes, offers and decisions for products and services they’ve identified may be appropriate for you.
  2. Providing your Financial Adviser with information about your applications or any active and expired policies they manage on your behalf.
  3. Providing your Financial Adviser with information about you that will help them continue to give you the best possible advice.
  4. Identifying and requesting medical tests and evaluating the results, or requesting other information relating to the administration, maintenance and processing of your application, policy or claim.
  5. Providing you with products and services, and letting you know about important changes or developments to the features and operation of those products and services.
  6. Responding to your enquiries and complaints.
  7. Administering offers, competitions and promotions.
  8. Facilitating secure access to our online platforms.
  9. Providing information about how our products and services change.
  10. Processing a claim, payment or other benefit relating to one of our products or services.

And also for the following activities:

  1. Updating, consolidating and improving the accuracy of our records.
  2. Testing new systems and checking upgrades to existing systems.
  3. Detecting, preventing and prosecuting crime.
  4. Evaluating the effectiveness of marketing, and for market research and training.
  5. Customer modelling and statistical and trend analysis with the aim of developing and improving products and services.
  6. Assessing insurance risks.
  7. Managing your relationship with us.

We may use your data for other purposes where you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act.

We won’t keep your personal information for longer than necessary for administering your policy, or for legal or regulatory requirements.


WHEN WE MAY SHARE YOUR INFORMATION

We’ll treat your personal information as private and confidential, but may share it with each other and disclose it outside Guardian if:

  1. Allowed by this agreement.
  2. You consent.
  3. Needed by our agents, advisers or others involved in running products and services for you or collecting what you owe.
  4. Needed by subcontractors to help us manage your records.
  5. HM Revenue & Customs or other authorities require it.
  6. The law, regulatory bodies (including for research purposes), or the public interest permits or requires it.
  7. Required by us or others to investigate or prevent crime.
  8. Needed by any other parties connected with your policy.
  9. Required as part of our duty to protect your policy. For example, we’re required to disclose your information to the UK Financial Services Compensation Scheme (FSCS).

We’ll always make sure your information remains safe and secure.


SHARING YOUR INFORMATION WITH OTHER COMPANIES

So that we can provide you with services and carry out the activities described above, your data may be processed by the following organisations:

  • Equifax
  • Experian
  • Genesys Inc
  • GenRe Reinsurance
  • Hannover Re Reinsurance
  • Infor UK Ltd
  • LISS Systems Ltd
  • Make Positive Ltd
  • Medical Screening Solutions Ltd
  • Microsoft Inc
  • Red Arc Assured Ltd
  • Salesforce Inc
  • Scottish Friendly Assurance Society Limited
  • Space01 (MBPA) Ltd
  • TIG Ltd
  • Xalient Ltd

This list may be updated from time to time.


USING YOUR INFORMATION TO HELP PREVENT TERRORISM AND CRIME

The government also requires us to screen applicants, policyholders and claimants to make sure we’re complying with the international fight against terrorism and other criminal activities. Because of this we may need to disclose information to government bodies.


SHARING YOUR INFORMATION TO HELP WITH ASSET BUYING OR SELLING

We may in the future wish to sell, transfer or merge part or all of our business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it. If so, we may disclose your personal information to a potential buyer, transferee, or merger partner or seller and their advisers so long as they agree to keep it confidential and to use it only to consider the possible transaction. If the transaction goes ahead, the buyer, transferee or merger partner may use or disclose your personal information in the same way as set out in this notice.


SEARCHING INSURANCE RECORDS

If you make a claim, we may put any information you give to us onto a register of claims and share it with other insurers to prevent fraudulent claims. A list of the participants is available on request. We may also disclose your information to our agents and other insurers to investigate or prevent fraud.


SHARING PERSONAL INFORMATION BETWEEN JOINT APPLICANTS

You shouldn’t give personal information about someone else (such as a joint applicant) without their permission. Where you provide information about someone else, or someone discloses information about you, it may be added to any personal information we already hold and will be used in the ways described in this privacy policy.

Sometimes, when you take out a joint policy, this may mean your personal data will be shared with the other applicant.


HOW WE MANAGE SENSITIVE PERSONAL INFORMATION

The Data Protection Act defines certain information as ‘sensitive’ (racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences). If you apply to us for insurance we may ask you for some ‘sensitive’ details. We’ll only use this information to provide the service you want and we’ll ask for your explicit consent for this use either directly or through your Financial Adviser, which will normally be requested by referring you to this policy. As a customer, there may be times when you give us sensitive information. We may share it with other parts of the group and our subcontractors to keep your records up to date in line with these terms.


USING COMPANIES TO PROCESS YOUR INFORMATION OUTSIDE THE EEA

All countries in the European Economic Area (EEA), which includes the UK, have similar standards of legal protection for your personal information. We may administer your policies and provide other services from centres outside the EEA (such as the USA and India) that don’t have a similar standard of data protection laws to the UK. If so, we’ll require your personal information to be protected to at least UK standards.

We may process payments through other financial institutions such as banks and the worldwide payments system operated by the SWIFT organisation if, for example, you make a CHAPS payment or a foreign payment. Those external organisations may process and store your personal information abroad and may have to disclose it to foreign authorities to help them in their fight against crime and terrorism. If these are based outside the EEA, your personal information may not be protected to standards similar to those in the UK.


USING ANTI-MONEY LAUNDERING AND FRAUD PREVENTION AGENCIES

To comply with money laundering regulations, there are times when we need to confirm (or reconfirm) your name and address. We may share this information with other group companies.

We have systems that protect our customers and ourselves against fraud and other crime. Customer information can be used to prevent crime and trace those responsible. We’ll share your personal information from your application with fraud prevention agencies. If we receive false or inaccurate information and identify fraud, we’ll pass the details to these agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

  • Recovering debt.
  • Checking details on applications and claims.
  • Checking details of job applicants and employees.

If you’d like details of the relevant fraud prevention agencies, please contact us on:

0808 123 1821

We and other organisations may access and use the information recorded by fraud prevention agencies.


HOW WE CHECK YOUR IDENTITY

We may ask you to provide physical forms of identity verification when you apply for a policy, and we may search credit reference agency files when we assess your application. The agency also gives us other details and information from the electoral register to verify your identity. The agency keeps a record of our search, whether or not your application proceeds. Our search isn’t seen or used by lenders to assess your ability to get credit.

If you send us emails from your personal account, please remember that the information may not be secure and there’s a risk that it could be intercepted. If we ask you to send us sensitive information we’ll suggest an appropriate method to use. If you choose to send an ‘insecure’ email, you should keep the amount of confidential information you include to a minimum.


RECORDING PHONE CALLS AND WEBCHAT SESSIONS

We may monitor or record our phone calls and webchat sessions with you in case we need to check we’ve carried out your instructions correctly, to answer questions or resolve issues, for regulatory purposes, to help improve the quality of our service, and to help detect or prevent fraud or other crimes. We may also monitor conversations for training purposes.


USING INFORMATION ON SOCIAL NETWORKING SITES

We may research comments and opinions made public on social networking sites such as Twitter and Facebook to help us understand our customers better.


GETTING A COPY OF YOUR INFORMATION

Under the Data Protection Act you have the right of access to your personal data. If anything is inaccurate or incorrect, please let us know and we’ll fix it. For details on how to request a copy of your information, please contact us on:

0808 123 1821
 Guardian, Forbury Works, 37-43 Blagrave Street, Reading RG1 1PZ

USING YOUR PERSONAL INFORMATION TO CONTACT YOU ABOUT PRODUCTS AND SERVICES

We’ll use your personal information to give you product details and offers that are more relevant to you. We may carry on doing this after your relationship with us ends.

We might contact you by mail, phone, email, or text message unless you’ve asked us not to. We may also display personalised messages when you use our internet and mobile services. You can change your preferences at any time by calling us or emailing us.

You can opt out of receiving this information at any time contacting us on:

0808 123 1821
Guardian, Forbury Works, 37-43 Blagrave Street, Reading RG1 1PZ

PASSING YOUR INFORMATION TO OTHER COMPANIES FOR THEIR OWN DIRECT MARKETING

Unless you’ve given us your consent, we won’t give information about you to other companies to use for their marketing purposes.


VIEWING NOTIFICATIONS

Organisations must lodge a notification with their regulator describing what they process personal information for. The details are publicly available from the regulator’s office and you can view ours at ico.org.uk/esdwebpages/search


UPDATES

We keep our privacy policy under regular review and we’ll reflect any updates in this notice. It was last updated in May 2018.