Fair Processing Notice (FPN)
Use of personal information
To provide our services as Insurance Brokers, Deninsure Limited will collect and use information about you or a beneficiary under the policy (e.g. your employees or other identified individuals), such as name, address and contact details. This may also include special categories of personal data (e.g. about health) and information relating to criminal convictions and offences. The purposes for which we use personal data may include: evaluating your insurance application and providing a quotation; providing insurance cover; handling claims; and crime prevention and debt recovery. More information about our use of personal data is set out in the Deninsure Limited Privacy Notice (“Privacy Notice”). You can request a copy of the Privacy Notice by contacting the Data Protection Officer at firstname.lastname@example.org or Deninsure Limited, 209 Bellingham Road, Catford, London SE6 1EQ.
We recommend that you review this notice
We may pass personal data to third parties such as intermediaries, insurers, reinsurers, loss adjusters, sub- contractors, our affiliates, the police and other law enforcement agencies, fraud and crime prevention and detection agencies, databases and registers (for example the Motor Insurance Database, Claims and Underwriting Exchange and Motor Insurance Anti-Fraud and Theft Register) and to certain regulatory bodies who may require personal data themselves for the purposes described in the Privacy Notice. If you require details of the third parties your data has been passed to and how this information is used please contact the Data Protection Officer at email@example.com or at the address detailed above. Depending on the circumstances, the use of personal data described in this notice may involve a transfer of data outside the UK and the European Economic Area to countries that have less robust data protection laws. Any such transfer will be made with appropriate safeguards in place.
Use of personal data for which consent is required
In some circumstances, we (and other insurance market participants) may need to collect and use special categories of personal data (e.g. health information) or information relating to criminal convictions and offences. Where this is required, unless another ground applies, consent to this processing is necessary for us to provide relevant services. Although consent may be withdrawn at any time, this may mean we are unable to continue to provide services and/or process enquiries and/or claims and that insurance cover will stop. Where you are providing us with personal data about a person other than yourself, you agree to provide this notice to them and confirm that you have obtained their consent as outlined here.
TERMS OF BUSINESS
Authorised and Regulated by the Financial Conduct Authority
209 Bellingham Road Catford London SE6 1EQ
Telephone: 020 8699 3333 / Fax: 020 8697 6748
In arranging insurance for our customers, we act as Independent Intermediary. Our service includes advising you on your insurance needs, arranging your insurance cover with insurers to meet your requirements and helping you with any ongoing changes you have to make. We can also assist you with making a claim.
Please note that our Uninsured Loss Recovery Scheme is not an insurance product and is not covered by Financial Conduct Authority (FCA) Regulations. We will give you details of any such arrangements before you make any commitment on any product we offer you.
It is your responsibility to provide complete and accurate information to insurers when you take out your insurance policy, throughout the life of your policy, and when you renew your insurance. Failure to disclose information pertaining to your insurance, or any inaccuracies in information given, could result in your insurance policy being invalid or cover not operating fully.
It is important that you ensure all statements you make on proposal forms, claims forms and other documents are full and accurate. If a form is completed on your behalf, you should check that the answers shown to any questions are true and accurate before signing the document.
You are reminded that is an offence under the Road Traffic Act to make any false statements or withhold any relevant information to obtain a Certificate of Motor Insurance.
Please note that under the Rehabilitation of Offenders Act 1974 you are required to disclose convictions regarded as “Spent”.
You are advised to keep copies of any correspondence you send to us or direct to your insurer.
If you are in any doubt about whether information is material, you should disclose it.
Confidentiality And Data Protection
All personal and sensitive information about our customers is treated as private and confidential.
We will use and disclose the information we have about customers in the normal course of arranging and administering their insurance, and will not disclose any information to any other parties without their written consent. Unless we are notified of any changes, we shall assume the personal and sensitive data we hold about our customers is correct, and shall use it to provide quotations when policies fall due for renewal.
In the interests of security and to improve our service, telephone calls you make to us may be monitored and/or recorded.
We may pass information about you to credit reference agencies for the purpose of arranging payments of instalments, and may also pass to them details of your payment record with us.
Under the Data Protection Act 1998, individuals have a right to see personal information about them that we hold in or records. A charge may be made for this service. If you wish to exercise this right, or have any other related queries, you should write to us at the above address.
Access to Records By A Regulator Or Complaints Resolution Body
We may have to allow access to your records by a regulator or a complaints resolution body, or their appointees or representatives, who have been appointed to undertake monitoring of investigatory activities.
Motor And Home Insurance Anti-Fraud Registers
Insurers share information with each other via the Claims and Underwriting Exchange Register, and the Motor Insurance Anti-Fraud and Theft Register, to aid the prevention of fraudulent claims.
In the event of a claim, the information you supply on the claim, together with any other information relating to the claim, will be put on the Registers.
Motor Insurer Information Database (MID)
Insurers are legally required to provide details of motor insurance policies to the MID. The information describing your insurance cover will be added to the Motor Insurance Database (MID), to which the police and other government agencies have access. This helps the pursuance of claims following accidents and assists in the detection of people who drive uninsured.
Use For Marketing Purposes
We may use information held about you, to provide you with information about other products and services which we offer, and which we feel may be appropriate to you, by email, telephone, post or other means.
You may exercise your right to give notice to stop data being processed for marketing purposes by contacting us at any time. Please contact us on the above telephone number or write to us at the above address.
We have no authority to handle claims on behalf of insurers. In the event of an accident occurring, which may give rise to a claim under your policy, you should notify the insurer direct as soon as possible using the contact details in your policy document.
When we receive notification of an accident that might give rise to a claim under your policy, we will inform the insurer without delay and, in any event, within 3 working days.
We shall use our best endeavours when acting on your behalf in relation to a claim, to handle all elements of the claim with due care, skill and diligence.
We shall advise you promptly of insurers’ requirements concerning claims, including the provision, as soon as possible, of information required to establish the nature and extent of a loss.
If there is any conflict of interest, we shall only handle a claim on your behalf after we have disclosed to you all information you require, to enable you to decide whether to give your informed consent, and shall you have given that consent for us to handle the claim.
We shall forward any payments received from insurers in respect of any claim, to you, without delay.
We shall notify you of any request for information we receive from your insurers.
It is our intention to provide you with a high level of customer service at all times. If there are occasions when we do not meet these standards, please contact the member of staff you were dealing with, either verbally or in writing. They will take details of your concerns and we shall then acknowledge in writing, advising you of who is dealing with the matter. A copy of our full Complaints Handling Procedure is available on request.
Cancellations Rights (The Mediation Contract)
The Mediation Contract is the agreement between you and us for the insurance mediation services that we provide to you in respect of your insurance requirements.
Once you have entered into the Mediation Contract with us, you are entitled to a period of reflection during which you may decide whether to proceed with the purchase of the Mediation Contract. The duration of this cancellation period of 14 days and commences from either:
- the delay of conclusion of the Mediation Contract; or
- the day on which you receive the full terms of the Mediation Contract detailing the full contractual terms, conditions and information of the contract;whichever is later.
To cancel this Mediation Contract within the cancellation period, please write to us at the above address. If you do cancel this Mediation Contract within the cancellation period, you may be charged a proportion of any of our fees that we have incurred.
This Mediation Contract can be cancelled at any time by either party in writing by giving 14 days notice. If you wish to give notice of cancellations, please write to us at the above address. If we wish to cancel this Mediation Contract we shall write to you at the last known address we have for you on our records.
If you decide to cancel the Mediation Contract with us at any time other than cancellation period, we will retain in full any fees that you have paid.
Premiums And Financial Aspects
In order to be able to offer you credit facilities, we are registered under the Consumer Credit Act and our Licence Number is Z121457X
We normally accept payment by cash, guaranteed cheque or the following credit/debit cards – Switch, Maestro
The following cards are accepted subject to 2.5% surcharge – Amex
You may be able to spread your payments through insurers’ instalments schemes, a credit scheme with a third party finance provider, or a facility we have arranged ourselves. We shall give you full information about your payment options when we discuss your insurance in detail.
We may keep certain documents, such as your insurance policy documents or Certificate, while we are waiting for full payment of premiums. In these circumstances, we shall ensure that you receive full details of your insurance cover and will provide you with any documents that you are requested to have by law.
If you choose to pay your Insurance Premiums in instalments, we may offer you the option of paying via Close Brothers Premium Finance. Close Brothers Premium Finance will give us a fee for arranging your finance.
Premiums that we collect from you are held in an insurance broking bank account specifically used for the purpose of holding client premiums. By virtue of agreements we hold with insurers, we collect premiums as agent of the insurer. Therefore, once we have collected premiums from you, under the terms of our agreements with insurers, those premiums are treated as having been paid to the insurer. We will remit the premiums to insurers, after deductions of our commission, in accordance with the terms of our agreements with insurers.
Client Money Segregation (Statutory Trust)
Premiums that we collect from you will be segregated into and held in a Client Money Bank Account. The client money will be held by us as trustee on your behalf. The Client Money Bank Account is set up as a trust governed by FCA rules. This means that once the client money is segregated into the Client Money Bank Account, it falls into our legal ownership but remains in the beneficial ownership of customers whose premiums are deposited in the Account. If we become insolvent, the terms of the trust dictate that customers will have a prior claim on the client money in the Account according to their respective interests in the client money. The costs relating to the distribution of client money may have to be borne by the trust.
Client Money Segregation (Non-Statutory Trust)
The client money will be held by us as trustee on your behalf. The Client Money Bank Account is set up as a trust governed by FCA rules. We may agree to extend credit to other customers using client money from the Client Money Bank Account. We shall have a place, and maintain, systems and controls adequate to ensure that we are able to monitor and manage client money transactions and any credit risk arising from the operation of the trust arrangement. If we become insolvent, the terms of the trust dictate that customers will have a prior claim on the client money in the Account according to their respective interests in the client money. The costs relating to the distribution of client money may have to be borne by the trust.
Return premiums usually arise if an insurance risk is reduced or a policy cancelled.
On a return premium, we repay commission on the amount to your insurer and this will be deducted from the final amount due to you.
If a policy is cancelled, we shall refund any return premium due (after deduction of the commission and our charge).
All quotations are subject to change in respect of the amount of premium indicated, and/or the terms and conditions that are applied.
Policy Terms, Conditions And Warranties
You should read through all policy terms, conditions and warranties shown on your policy documentation. Please ensure you understand them and are able to follow their requirements exactly. If not, please advise us immediately, as a breach of any terms, conditions or warranties may enable your insurer to terminate your policy from the date of that breach, and/or repudiate a claim under your policy.
Renewal Premiums Paid By Instalments
In good time before the renewal of your policy, we shall contact you with the renewal premium and terms for the coming year.
If you have not contacted us before the renewal date, we shall renew the policy automatically on your behalf. If you do not wish to renew the policy, please let us know as soon as possible. We should also advise you to cancel your direct debiting instruction with your bank prior to renewal date.
If it is your intention to renew the policy, no action is required by you, and the policy will automatically renew. We shall send your new Certificate of Insurance to you.
Disclosure Of Commission
If you would like to know the amount of commission that we are paid in respect of your insurance contract, this information is available on request.
In certain instances we may receive no commission from an underwriter or wholesale intermediary and in such instances it is necessary to make a charge consistent with the amount of commission that would have been earned.
In such instances our charges will be clearly notified to you prior to commencement of the transaction.
Earning Interest On Customer Premiums
We hold premiums that you pay to us in a Client Money Bank Account. Under FCA Regulations we have to inform you that we earn no interest from the money held in our Client Money Bank Account. By accepting these Terms of Business, you are giving your consent for us to act in the manner described in this Section.
Customer Money Passed To Another Person
In accordance with FCA Regulations we have to inform you that in managing and/or arranging your insurance requirements, we may transfer money that you have paid us, in payment of an insurance premium, to another insurance intermediary.
By accepting these Terms of Business, you are giving your consent for us to act in the manner described in this Section.
Customer Money Passed To Another Person Outside The UK
In managing and/or arranging your insurance requirements, we may transfer money that you have paid us, in payment of an insurance premium, to another insurance intermediary operating outside of the United Kingdom.
Unless you notify us that you do not wish your premiums to be transferred in the manner outlined in this Section, by accepting these Terms of Business, you are giving your consent for us to act in the manner described in this Section.
We have a duty under FCA Regulations to inform you that:
- The legal and regulatory regime applying to the insurance intermediary may differ from that in the United Kingdom, and
- Consequently if the insurance intermediary fails, the premium may be treated in a different manner from that which would apply if the premium was held by an insurance intermediary in the United Kingdom
Use Of Non-Approved Bank
We hold premiums that you pay to us in a Client Money Bank Account. The bank with which we hold this bank account is not approved as defined by the FCA. We have a duty under the FCA Regulations to inform you that:
- The legal and regulatory regime may differ; and
- Consequently if the bank fails, the money may be treated differently;
- The bank may not have accepted that it may not use client money as set-off against a debt that we may have.
By accepting these Terms of Business, you are giving your consent for us to act in the manner described in this Section.
Segregation Of Investments
We hold premiums that you pay to us in a Client Money Account. We may invest these premiums in a range of permitted designated investments as prescribed by FCA Regulations. In the event that there is any shortfall in our client money resource attributable to falls in the market value of any of these permitted designated investments, we shall make provision for, and bear the cost of, any such shortfall.
By accepting these Terms of Business, you are giving consent for us to act in the manner described in this Section.
This Agreement shall be governed by the laws of England and Wales and the parties agree herewith that any disputes arising out of it shall be subject to the [non-] exclusive jurisdiction of the English Courts.
This Agreement shall be governed by the laws of Scotland and the parties agree herewith that any dispute arising out of it shall be subject to the [non-] exclusive jurisdiction of the Scottish Courts.
Other Taxes Or Costs
Other taxes or costs, or both, may exist in relation to the products and services offered by us, which are not paid through, nor imposed, by us.
We receive commission from the premiums that you pay to us. We shall only withdraw commission after we have received the premium from you, and in accordance with FCA Regulations and agreements that we hold with insurers.