Who we are
At SPB UK & Ireland we collect and use personal information for insurance policy, claims and card loss administration services. We are aware of our responsibilities to handle your personal data with care, to keep it secure and comply with applicable privacy and data protection laws.
The EU General Data Protection Regulation (“GDPR”) came into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age. The EU General Data Protection Regulation was embodied in the UK with the Data Protection Act 2018 and includes additional domestic requirements such as national security and serious crime.
All of our companies are registered with the Information Commissioner’s Office (ICO) under the following numbers;
Burnett & Associates Limited – Z5471059
Burnett’s Computer Services Limited – ZA312869
Burnett’s Insurance Services Limited – Z7925355
Citymain Administrators Limited – Z5585895
Citymain Limited – ZA061427
Your Privacy and our preparation and embedding of the GDPR requirements included: –
- Information Audit – we carried out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed. We logged this information appropriately and review it when there is any change in reasons for processing.
- Policies & Procedures – we have revised/implemented new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws.
- Legal Basis for Processing– we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
- Privacy Notice/Policy– we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
- Obtaining Consent– we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
- Direct Marketing– we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
- Data Protection Impact Assessments (DPIA)– where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
- Processor Agreements– where we use any third-party to process personal information on our behalf (e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
- Special Categories Data– where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
We will hold any additional information you submit to make a claim for example date of birth, name and address of the device user and vehicle registration number if item stolen from a car and other information you provide when making a claim. Further, and as an extension to this, we may hold police crime reports.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website, in the office, during induction etc of an individual’s right to access any personal information that we process about them and to request information about: –
- What personal data we hold about them
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store their personal data for
- If we did not collect the data directly from them, information about the source
- The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this.
- The right to request erasure of personal data (where applicable) or to restrict pressing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use.
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Your personal information will not be retained for longer than is necessary and will be managed in accordance with our data retention policy. Please be aware that we are required to keep details of any policies you apply for or have taken out, including any claims or complaints history under the rules laid out in the Financial Conduct Authority Handbook requirements and other legislation as applicable from time to time.
Security & Technical and Organisational Measures
We take the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including:
- Access Controls
- Password Protection for all files and systems (including a policy governing it)
- Encryptions for external or cloud storage
- Authentication for access to programs that process our data
- IT Access controls and change policies
GDPR Roles and Employees
We have designated the Compliance Manager as our Appointed Contact Person any gap areas and implementing the new policies, procedures and measures. As a small company we do not have to appoint a Data Protection Officer.
We understand that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our implementation plans. We have implemented an employee training program which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.
If you have any questions about our implementation for the GDPR, please contact our Appointed Contact Person above.
We use IP addresses to analyse trends, administer the site, track the user’s movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. Additionally, for systems administration, detecting usage patterns and troubleshooting purposes, our web servers automatically log standard access information including browser type, access times/open mail, URL requested, and referral URL. This information is not shared with third parties and is used only within our companies on a need-to-know basis. Any individually identifiable information related to this data will never be used in any way different to that stated above without your explicit permission.
Google Analytics cookies and identifiers
Google Analytics mainly uses first-party cookies to report on visitor (aka. user) interactions on Google Analytics customers’ websites. Users may disable cookies or delete any individual cookie. Learn more
In addition, Google Analytics supports an optional browser add-on that – once installed and enabled – disables measurement by Google Analytics for any site a user visits. Note that this add-on only disables Google Analytics measurement.
Google Analytics also collects Internet Protocol (IP) addresses to provide and protect the security of the service, and to give website owners a sense of which country, state, or city in the world their users come from (also known as “IP geolocation”). Google Analytics provides a method to mask IPs that are collected (detailed below) but note that website owners have access to their users’ IP addresses even if the website owners do not use Google Analytics.
Find out how to manage cookies on popular browsers:
To find information relating to other browsers, visit the browser developer’s website.
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
Links to this website
You may not create a link to any page of this website without our prior written consent. If you do create a link to a page of this website you do so at your own risk and the exclusions and limitations set out above will apply to your use of this website by linking to it.
Links from this website
We do not monitor or review the content of other parties’ websites which are linked to from this website. Opinions expressed or material appearing on such websites are not necessarily shared or endorsed by us and we should not be regarded as the publisher of such opinions or material. Please be aware that we are not responsible for the privacy practices, or content, of these sites. We encourage our users to be aware when they leave our site & to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site yourself, before disclosing any personal information to them. This Company will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of personal information.
Copyright and other relevant intellectual property rights exist on all text relating to the Company’s services and the full content of this website.
This Company’s logo is a registered trademark of this Company in the United Kingdom and other countries. The brand names and specific services of this Company featured on this website are trademarked.
You have the right to lodge a complaint with the Information Commissioner’s Office about our processing of your personal data. We ask that you please attempt to resolve any issues with us first, by contacting us at firstname.lastname@example.org.
SPB UK & Ireland
Telephone: 0333 999 7904 (all calls are charged at the local rate)