Markham Privacy Policy

​Markham Special Risks is a trading name of Markham Private Clients. Markham Private Clients Limited (“Markham”, “we”, “us” or “our”) is committed to protecting the privacy and security of personal information. This Privacy Notice explains how we collect, use, store and share personal information when we provide insurance broking and related services, including arranging insurance, obtaining quotations, conducting renewals and market reviews, administering policies and assisting with claims. This notice also explains your rights in relation to your personal information.

1. Who we are

Markham Private Clients Limited is the controller responsible for the personal information described in this Privacy Notice where we determine the purposes and means of processing that information.

Our contact details are:

Markham Private Clients Limited
St John’s Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom
info@markhamspecialrisks.com
+44 (0)1223 200 678

If you have any questions about this Privacy Notice or how we use your personal information, please contact us using the details above.

2. Personal information we collect

The personal information we collect will depend upon the insurance services we provide and the nature of the insurance being arranged. The information we may collect includes:

• name;
• residential, business and correspondence address;
• email address;
• telephone and other contact details;
• date of birth;
• nationality;
• occupation, job function and employment details;
• employer, company and institutional affiliation;
• financial information where relevant to the insurance being arranged;
• details of assets, property, business activities, travel or other insured risks;
• insurance history;
• claims and incident history;
• information provided in insurance proposals, questionnaires and underwriting submissions;
• policy, quotation and premium information;
• correspondence and communications relating to insurance arrangements;
• recruitment information, where you apply for employment with us, such as your CV, qualifications, employment history and references;
• technical and online information, including IP address, device information, cookie information and information about how you use our website.

We may also receive information about family members, employees, directors, insured persons or other individuals where this is relevant to the insurance services we are asked to provide.

3. Where we obtain your personal information

We may obtain personal information directly from you. We may also receive information from:

• insurance brokers and other intermediaries;
• introducers;
• employers or companies;
• family offices;
• professional advisers;
• other representatives acting for you or the insured;
• insurers and other insurance market participants;
• claims handlers and service providers;
• publicly available sources;
• regulatory, fraud prevention and other official bodies.

In particular, where an insurance broker or other representative provides information to us on behalf of an insured person or prospective insured, we may use that information to provide the insurance broking services requested.

4. How we use your personal information

We may use your personal information for the following purposes.

Providing insurance broking services

This includes:

• understanding your insurance requirements;
• assessing your demands and needs;
• preparing insurance reports and recommendations;
• obtaining quotations and insurance terms;
• comparing insurance terms;
• negotiating with insurers and other insurance market participants;
• arranging and placing insurance;
• renewing insurance;
• conducting market reviews and re-marketing exercises;
• administering policies;
• collecting and processing information required for underwriting;
• assisting with claims and other insurance-related matters.

 

Insurance placement and market reviews

Where you ask us to arrange, review, renew or administer insurance for you, or for a client you represent, we may use information provided to us to approach, obtain quotations from and negotiate with one or more insurers and other insurance market participants. This may include approaching alternative insurers during a renewal, market review or re-marketing exercise where we consider this appropriate in providing our insurance broking services. Where we approach an insurer or other insurance market participant, we will seek to use and share only information reasonably necessary for the relevant insurance purpose. We may receive underwriting and other insurance information from an insurance broker or other representative acting for an insured or prospective insured. Subject to applicable law and the arrangements under which the information was provided, we may use that information to obtain quotations or terms from appropriate insurers and other insurance market participants.

5. Our legal bases for using your personal information

Depending upon the circumstances and the processing activity, we may rely on one or more of the following legal bases.

 

Performance of a contract

We may process personal information where this is necessary to perform a contract with you or take steps at your request before entering into a contract.

For example, this may include obtaining insurance quotations, arranging insurance and administering an insurance policy.

 

Legitimate interests

We may process personal information where this is necessary for our legitimate interests or the legitimate interests of a third party, provided that those interests are not overridden by your rights and interests.

Our legitimate interests may include:

• providing and improving our insurance broking services;
• managing our business and relationships with clients and brokers;
• conducting market reviews;
• maintaining records;
• managing risk;
• protecting our business and systems;
• preventing fraud and financial crime;
• responding to complaints and legal claims.

 

Legal and regulatory obligations

We may process personal information where necessary to comply with legal, regulatory or professional obligations.

This may include obligations relating to insurance regulation, financial crime prevention, record keeping and responding to regulators or other authorities.

 

Consent

In certain circumstances, we may ask for your consent to process personal information. Where we rely on consent, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.

6. Special category and sensitive information

Depending on the nature of the insurance or claim, we may need to process information that receives additional protection under data protection law.

This may include, where relevant:

• health information;
• information concerning racial or ethnic origin;
• information concerning religious or philosophical beliefs;
• information concerning criminal allegations, offences or convictions;
• information concerning security incidents, threats or other events relevant to insurance.

Where we process such information, we will do so only where we have an appropriate legal basis and any additional condition required by applicable data protection law.

7. Who we may share your personal information with

We may share personal information where necessary for the purposes described in this Privacy Notice. Recipients may include:

• insurers;
• reinsurers;
• underwriting agencies and managing general agents;
• other insurance intermediaries and brokers;
• claims handlers;
• assistance, security and crisis-response providers;
• professional advisers;
• IT, cloud, software and communications providers;
• payment and banking providers;
• fraud prevention and financial crime prevention organisations;
• auditors;
• regulators and governmental authorities;
• other service providers acting on our behalf;
• other parties where required by law or reasonably necessary to establish, exercise or defend legal claims.

We do not sell personal information to third parties. Where we use service providers to process personal information on our behalf, we require them to protect the information appropriately and to process it in accordance with applicable legal requirements.

8. International transfers

As an international insurance broker, we may transfer personal information outside the United Kingdom. This may include transfers to insurers, brokers, service providers or other insurance market participants located outside the United Kingdom. Where we transfer personal information internationally, we will take appropriate steps to ensure that the transfer is carried out in accordance with applicable data protection law and that appropriate safeguards are used where required.

Depending upon the destination country, this may include the use of:

• adequacy regulations;
• approved standard contractual clauses or international data transfer agreements;
• other legally recognised transfer safeguards.

You may contact us if you would like further information about the safeguards used for a particular international transfer.

9. How long we keep your personal information

We will retain personal information for no longer than reasonably necessary for the purposes for which it was collected, including to provide insurance services and comply with legal, regulatory and professional obligations. As a general rule, we may retain insurance and related records for up to eleven years after the end of our relationship with you or the relevant insurance arrangement. We may retain information for longer where necessary because of:

• legal or regulatory requirements;
• potential or actual legal claims;
• complaints;
• investigations;
• fraud prevention;
• audit requirements;
• technical limitations affecting immediate deletion.

Where information is retained for statistical or research purposes, we will take appropriate measures to protect it and use it only for those purposes.

10. Marketing communications

We may send you information about our services, activities, publications, events and other relevant matters where permitted by applicable law. Where required, we will obtain your consent before sending marketing communications.

You can ask us to stop sending marketing communications at any time by:

• using the unsubscribe facility included in an electronic communication; or
• contacting us using the details set out in this Privacy Notice.

Service communications relating to insurance policies, claims, quotations or other services we provide are not marketing communications and may continue where necessary.

11. Your rights

Subject to applicable law, you may have the right to:

• request access to the personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to delete personal information in certain circumstances;
• object to certain processing;
• ask us to restrict our use of your personal information in certain circumstances;
• request the transfer of certain personal information to you or another organisation where applicable;
• withdraw consent where we rely on consent.

These rights are not absolute and may not apply in all circumstances. If you wish to exercise any of your rights, please contact us using the details provided above.

12. If you choose not to provide personal information

In some circumstances, we need certain personal information in order to provide insurance broking services or comply with legal or regulatory obligations. If you do not provide information that we require, this may:

• delay our ability to obtain quotations or arrange insurance;
• prevent an insurer from considering a risk;
• affect our ability to administer an insurance policy or claim;
• prevent us from providing a particular service.

We will tell you where providing information is necessary and explain the consequences of not providing it where appropriate.

13. Accuracy of your information

You should tell us if personal information we hold about you changes or is inaccurate. If you believe information we hold is incorrect or incomplete, please contact us and we will take reasonable steps to investigate and correct it where appropriate.

14. Automated decision-making

We do not generally make decisions about individuals based solely on automated processing. However, insurers and other insurance market participants may use automated systems or profiling when assessing risks, setting premiums or deciding whether to offer insurance. Where applicable, further information about such processing may be provided by the relevant insurer or other organisation.

15. Cookies and website information

Our website may use cookies and similar technologies. Cookies are small text files placed on your device when you visit a website. They may be used to enable website functionality, understand how the website is used and improve our online services.

Depending upon the cookies used, we may collect information such as:

• IP address;
• device and browser information;
• approximate location;
• pages visited;
• services used;
• how you interact with our website.

Where required by law, we will obtain your consent before placing non-essential cookies on your device. You can manage cookies through our cookie preference tool, where available, and through your browser settings. Further information about the cookies used on our website should be provided in our separate Cookie Notice.

16. Complaints

If you have concerns about how we use your personal information, please contact us first and we will seek to resolve your concern. You also have the right to complain to the UK data protection supervisory authority:

Information Commissioner’s Office

Further information about making a complaint is available from the Information Commissioner’s Office.

17. Changes to this Privacy Notice

We may update this Privacy Notice from time to time. The most recent version will be made available through our website or otherwise provided where appropriate. We recommend that you review this Privacy Notice periodically to ensure that you remain aware of how we use your personal information.