Kirwan Pike Insurance and Financial Services t/a Kirwan Pike Insurance and Financial Services is committed to ensuring that your data is protected. To keep you informed, we have created this statement which will explain how we use the information we collect about you and how you can exercise your data protection rights.
Kirwan Pike Insurance and Financial Services t/a Kirwan Pike Insurance and Financial Services (referred to throughout this statement as “we” “us” “our”) are the data controllers in relation to the personal information we hold about you.
Why do we collect and use your personal information?
We will use your personal information for the provision of insurance services such as providing a quotation, underwriting a policy and handling claims under an insurance contract. We will also use your data for other related matters such as complaint handling, prevention or detection of fraud and reinsurance. In addition, if you have given us separate marketing consent, we will use your personal data for direct marketing purposes.
When looking for a quote for an insurance product from us, you will need to provide us with information relating to what you wish to be covered (e.g. car make and model, your home, details about you). When buying certain products, we will on occasion need to collect special categories of data (e.g. medical history) and convictions history. If you cannot provide this information, we will be unable to provide our products to you.
In order to provide our products, we will need to process your payment information (e.g. bank account details, credit and debit card details) to collect payments from you and to issue any refunds to you.
We may contact you if you request a quote from us and/or to service your policy via our website, emails, phone calls and/or post. Phone calls may be recorded for training and verification purposes.
If you need to claim against your insurance policy, we normally need to collect information that evidences what happened in the incident. If other people are involved in the incident, we may also need to collect additional information related to them (including children) which can include special categories of data (e.g. injury and medical data).
When submitting an application to us for a product, you may provide us with information relating to other persons named under the policy, (e.g. a named driver). You agree that you will bring this Data Protection Statement to the attention of each person named on the policy at the earliest possible opportunity. Please also ensure that anyone else who is insured under your policy have agreed to provide their personal information to us.
Data protection laws require us to meet certain conditions before we are allowed to use your personal information in the manner described in this statement. In order to provide you with this detail, we have prepared the following table which describes the purpose to which we are using your data and the legal basis for doing so.
|To provide you with a quote for an insurance product and to provide you with insurance cover if you decide to purchase a product.||Processing is necessary for the performance of a contract and in order to take steps at your request prior to entering into a contract|
|To assess the information, you have provided and make a decision as to whether we can provide you with cover and at what price||Processing is necessary for the performance of a contract and in order to take steps at your request prior to entering into a contract;|
|To verify your identity and to verify the accuracy of the information we receive||Processing is necessary for the performance of a contract and in order to take steps at your request prior to entering into a contract. Also for the purposes of our legitimate interests to investigate and prevent potential fraudulent activity. To comply with legal obligations (e.g. money laundering requirements)|
|To administer your insurance contract and make any changes during its term, answer queries, provide updates and process a cancellation||Processing is necessary for the performance of a contract|
|To make and receive any payments whether in relation to your policy or a claim||Processing is necessary for the performance of a contract|
|To manage and investigate any claims made by you or another person under your policy||Processing is necessary for the performance of a contract|
|To detect and prevent fraud, money laundering and other offences. To assist An Garda Siochana or any other authorised body with investigation||Processing is necessary for the purposes of our legitimate interests to investigate and prevent potential fraudulent and other illegal activity. Processing is necessary to comply with legal obligations|
|To manage and investigate any complaints||Processing is necessary for the performance of a contract and in order to take steps at your request prior to entering into a contract; Processing is necessary to comply with legal obligations|
|To comply with laws and regulations||Processing is necessary to comply with legal obligations|
|For staff training, performance reviews and discipline||Processing is necessary for compliance with our legal obligations. Processing is necessary for the purposes of our legitimate interests. This interest is to improve our processes, products and services|
|To make back-ups of your data in case of emergencies and for disaster recovery purposes||Processing is necessary for the performance of a contract and to comply with legal obligations|
How else do we collect information about you?
Where possible, we will collect your personal information directly from you. However, on occasion we may receive information about you from other people or companies. For example
* It was given to us by someone who is applying for an insurance product on your behalf (e.g. a spouse, policyholder)
* It was lawfully collected from other sources (e.g. the Integrated Information Data System (“IIDS”)) to validate information you have submitted to us such as driver number and penalty points
* Vehicle history check suppliers/databases.
* Through a database to determine address-based risk factors (known as geocoding)
* Searches of publicly available information (e.g. online).
* Other fraud prevention databases available in the insurance industry.
Who are we sharing your data with?
We may share your details with a number of external parties in order to administer your policy, handle claims, prevent and detect fraud, provide marketing services, and conduct marketing analysis. For example:
* Anyone authorised by you to act on your behalf
* Our Third Party Service Providers such as technology suppliers, storage providers, payment providers and document providers.
* The Insurance Link Anti-Fraud register (for more info see www.inslink.ie) and insurance companies.
* Loss Adjusters, claims investigators, repairers, medical practitioners, solicitors and other firms as part of the claims handling process.
* Private Investigators when we need to further investigate certain claims.
* Other fraud prevention databases available in the insurance industry
We may also share your personal information as a result of our legal and regulatory obligations. This can include An Garda Siochana, other official agencies and on foot of a Court Order or Subpoena. In order to provide you with our products and services, some of your personal information may be shared with our service providers, which may include parties outside of the European Economic Area (EEA). We would only do this in compliance with the appropriate legal and technical safeguards such as the standard data protection clauses adopted by the European Commission, Binding Corporate Rules or as a result of an adequacy decision of the European Commission
If you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance. The third party has a right to recover from the insurer the amount of any loss suffered by them. Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person who is able to provide it concerning:
* the existence of the insurance contract
* who the insurer is
* the terms of the contract, and
* whether the insurer has informed the insured person that the insurer intends to refuse liability under the contract.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
* Right of access – you have the right to request a copy of the information that we hold about you.
* Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
* Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
* Right to restriction – of processing where certain conditions apply to have a right to restrict the processing.
* Right of portability – you have the right to have the data we hold about you transferred to another organisation.
* Right to object – you have the right to object to certain types of processing such as direct marketing.
* Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
* Right to judicial review – in the event that Pike Insurance Services DAC refuses your request under rights of access, we will provide you with a reason as to why.
Requests to restrict the use of your information or to object to the processing of your data may lead to us being unable to continue to service your policy and therefore lead to cancellation of your policy. If you would like to request any of the above, please email us at firstname.lastname@example.org or write to us at 8 Marine Road, Dun Laoghaire, County Dublin. When you are making the request please provide us with your name, address, date of birth and identification.
All requests are free of charge. We endeavour to respond within one month from receipt of the request. If we do not meet this time frame, we will explain the reason for this in our response. Please note that simply submitting a request does not mean we will be able to fulfil it, we are often bound by legal and legislative law which can prevent us fulfilling some requests in their entirety, but when this is the case we will explain this to you in our response.
Retention of your personal data
Information submitted for a quotation will be retained by us for a period of up to 24 months from the date of the quotation. All information in respect of a policy (to include claims on the policy) will be held for 8 years after the ending of the client/insurer relationship to ensure we meet our regulatory obligations. We will retain call recordings and emails for 8 years from the date of the communication.
If you wish to raise a complaint on how we have handled your personal information, please send an email to email@example.com or write to us at 8 Marine Road, Dun Laoghaire, County Dublin. Our Data Protection Officer will investigate your complaint and will give you additional information about how it will be handled. We aim to respond in a reasonable time frame, normally 30 days. If you are not satisfied with our response you can lodge a complaint to the Data Protection Commission, Canal House, Station Road, Portarlington, Co Laois, R32 AP23.
Failure to provide further information
If we are collecting your data for a contract and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on (01) 7096000 or email firstname.lastname@example.org
Changes to our Privacy Statement
We reserve the right to modify this Privacy Statement at anytime. If we make any material change, we will update our website to include such changes. We will seek your consent if we want to use your personal information for purposes other than those you have agreed to previously.
This privacy statement was last reviewed on 2nd January 2022