Markel International is committed to protecting information which identifies and relates to you or other individuals (personal information) and complying with data protection laws.
Markel Capital Holdings Limited / Markel Consultancy Services Ltd / Markel Syndicate Management Ltd / Terra Nova Pension Trustee Ltd / Markel Protection Ltd / Markel International Insurance Co Ltd / MIPS Pension Scheme / Markel Law LLP / Galleon Marine Insurance Agency Ltd / JanJer Ltd / Markel International Services Ltd / Markel International Limited / Effective Tax Solutions Ltd (Howarth Lynch) / Alterra Capital Services UK Ltd / Alterra at Lloyd’s Limited / Markel Underwriting Services Ltd / Schouten Insurance Limited (Markel International, Netherlands) / Le Centaure (Markel International, France) / EC Insurance Company Limited / Markel International
Policyholders, clients, suppliers, advisers, service providers, enquirers, candidates for recruitment, beneficiaries or claimants and their agents and relatives (“you”)
This website may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information
Data protection laws require us to provide you with a lot of information about how we collect and use your personal information – and it is easy for all this information to become confusing rather than helpful.
We use a layered approach to providing you with the information required by law. This means that we may provide the information required in a number of different formats and documents. In particular, it means that in our initial contact with you, we may provide you only with the most important information about how we will use your personal information; but we will always provide you with easy access to all the further information you need about our privacy practices
As an example, if you buy an insurance policy from us, then we may use a three layer approach:
- This London Markets Core Uses Information Notice can be accessed here: LMA Insurance Market Information Uses Notice post enactment
As an example, if you engage us to provide you with advisory services, then we may use this three layer approach:
- Additional privacy notice terms in your letter of engagement that accompanies the terms of engagement, tailored to the specific advisory services provided and data involved if required.
- By using this three-layer approach, we provide you with both specific and general information about how we use personal information to provide you with the insurance cover or advisory services that you require, whilst at the same time making sure that you get the most important information without overwhelming you with facts and information about all our privacy practices in one go.
- Information we may collect about you
- Why we collection information about you
- How we may use your personal information
- Sharing your personal information
- Transmission, storage and security of your personal information
- Retention of your personal information
- Your rights
- Contacting us
- Cookies Statement
- Your right to complain
- Personal data and Brexit
1. Information we may collect about you:
We may collect and process the following personal information about you:
- information that you provide by filling in forms or upload or send to us;
- information including your name, address, contact details
- for insurance products, this includes details relating to a proposal or a claim (which depending on the nature of the claim may include medical reports and reports of criminal convictions or crime) that you, your employer or organisation whom we insure or reinsure or a third party claimant provide to us in relation to the administration of an insurance policy that we insure or re-insure;
- for advisory services, this includes details relating to your instructions for us to provide advisory services, the administration and management of those services and of any claim or complaint including details provided by a third party;
- for recruitment purposes, this includes information you or your recruitment agency supply in relation to your candidacy (e.g. your CV, application form) pre-offer, and references and background checks (administered by a third party) post-offer;
- information relating to any criminal or fraudulent activities provided to us by you or third parties (such as law enforcement, anti-fraud agencies or other insurers);
- if you contact us, we may keep a record of that correspondence, voicemail or details of any conversation we may have with you;
- details of your visits to our website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access;
- details of transactions you carry out through our website, including the quotations obtained for insurance and advisory services and the insurance policies and advisory services; and information that is available from publically available sources including social media websites.
2. Why we collect information about you:
We may process personal information for certain legitimate or lawful purposes in some or all of the following ways:
- to enhance the security of our network and information systems;
- to identify and prevent fraud;
- to maintain our accounts and records;
- to modify, personalise or otherwise improve our services/ communications;
- to comply with foreign law, law enforcement, court and regulatory bodies’ requirements;
- to defend or make claims;
- to correspond with clients, beneficiaries and claimants in order to facilitate the insurance policies or advisory services;
- to comply with a legal obligation;
- to protect your vital interest or the interest of another individual;
- to gather market intelligence, communicate with and tailor offers to individuals;
- for training and quality purposes;
- for the performance of a contract with you or to take steps to enter into a contract;
- for the performance of a task carried out in the public interest or in the exercise of an official authority;
- for recruitment purposes
3. How we may use your personal information:
We may use your personal information in the following ways:
- to make decisions on whether to provide insurance or advisory services;
- to manage your insurance policy or advisory services including underwriting and claims handling
- to monitor calls and transactions to ensure service quality, compliance with procedures, to combat fraud and insure compliance with UK/ EU and international sanctions;
- to identify you and to carry out any identity checks as may be required by applicable law and best practice at any given time;
- to recover any payments due to us and where necessary to enforce such recovery through the engagement of debt collection agencies or taking other legal action;
- to analyse it in order to understand the service we provide and in order to improve our business;
- to manage our infrastructure, business operations and comply with internal policies and procedures;
- to notify you about changes to our service;
- for marketing services to you by post, email, SMS, phone and fax;
- to decide whether to enter into a contract of employment with you;
- to assess your skills, qualifications and suitability for a role, in relation to recruitment specifically;
- to carry out background and reference checks, in relation to recruitment specifically;
- to communicate with you about the recruitment process, in relation to recruitment specifically; and
- to keep records related to our hiring processes in relation to recruitment specifically.
We will never process your data where these interests are overridden by your interests.
Your consent to our processing of your personal information for certain purposes may be necessary to comply with applicable data protection laws; and where this is the case we will ask you for your consent in accordance with those laws.
You may withdraw your consent to such processing at any time. However, if you withdraw your consent in relation to advisory services or insurance cover that we have provided then this is likely to impact our ability to provide those advisory services or insurance cover and pay claims under the cover.
5. Sharing your personal information:
Markel International may make personal information available to:
Our group companies
Other third parties
We may also permit selected third parties and agents including suppliers, service providers, reinsurers and financial organisations access to your personal information for the purposes set out in section 2. All such exchanges will be made in accordance with applicable laws. If false or inaccurate information is provided and/or fraud is identified or suspected, details may be passed to fraud prevention and anti-money laundering agencies, law enforcement agencies or other insurers and may be recorded by us or by them.
We and other organisations may also access and use this information to prevent fraud and other crime, for example when deciding whether to make a payment to you under an insurance or reinsurance policy;
We, and other organisations that may access and use information recorded by fraud prevention agencies, may do so from other countries including outside the EEA.
Governmental authorities and third parties involved in court actions
We may disclose your personal information to third parties, the courts and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or in order to enable Markel International to comply with its regulatory requirements or dialogue with its regulators as applicable.
6. Transmission, storage and security of your personal information:
Unfortunately, no data transmission over the Internet or any website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with applicable data protection laws.
All information within our control is stored on our secure servers (or secure hard copies) and accessed and used subject to our security policies and standards.
Where Markel International discloses your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or any other portal we operate, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.
Your personal information may be accessed by staff or authorised third parties and, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) where the data protection laws may be of a lower standard than in the EEA. Regardless of location or whether the person is an employee or contractor we will impose the same data protection safeguards that we deploy inside the EEA.
7. Retention of your personal information:
We maintain a data retention policy which we apply to all data in our care. Where your personal information is no longer required we will ensure it is securely deleted.
8. Your rights:
Data protection laws give you rights in relation to the personal information we hold about you, which may include the right to require us to:
- provide you with further details on the use we make of your personal information
- provide you with a copy of the personal information we hold about you
- update any inaccuracies in the personal information we hold about you
- delete any of your personal information that we no longer have a lawful ground to use
- where processing is based on consent, stop that particular processing by withdrawing your consent
- object to any processing based on our legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
- restrict how we use your personal information whilst a complaint is being investigated
- transfer your personal information to a third party in a standardised machine-readable format
- In certain circumstances, we may need to restrict your rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).
9. Contacting us:
We have a data protection officer who supervises how we use personal information. You can contact our data protection officer about privacy related issues by:
• sending an email to firstname.lastname@example.org
• writing to the Data Protection Officer, 20 Fenchurch St, London, EC3M 3AZ.
11. Cookies Statement:
12. Your right to complain:
If you are not satisfied with our use of your personal information or our response to any request by you to exercise your data protection rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the authority that supervises our processing of your personal information. In the UK, this is the ICO, details of which can be found here https://ico.org.uk/
If you are unsure of the authority that supervises our processing of your personal information then please contact us for further guidance.
13. Personal Data and Brexit:
It is unknown whether the UK will leave the EU on 29th March 2019 with or without a deal.
The Markel International companies are currently working on a plan, which in the event of a hard Brexit, addresses the transfer of personal data between the UK and EU. However, we would like to assure all data subjects your personal data is and will continue to be held securely whether you are based in the UK or not.
In the interim, if you have any questions about your personal data in relation to Brexit then please feel free to contact our data protection officer. For details please see section 9. Contacting us, above.
Version Reference: Jan2019v1.0