Privacy Notice

Purpose

This privacy notice describes how we collect, use, share, and protect your personal information when you use any of our products and services in accordance with data protection law, including the General Data Protection Regulation (GDPR). This includes making an application, agreeing a contract, submitting a claims request, servicing your contract, visiting our website, or any other interaction you have with Cirencester Friendly.

We only collect the personal information needed to provide the service you expect. We’ll contact you if we plan to use your personal information for purposes not mentioned in this privacy notice.

Cirencester Friendly is a data controller. This means that we are responsible for deciding how we hold and use personal information about you. We’re required under data protection legislation to notify you of the information contained in this privacy notice.

This notice can be updated at any time, so please always refer to the website for the current version. It’s important that you read this notice, together with any other privacy notice that is provided on specific occasions when we’re collecting or processing personal information about you, so that you’re aware of how and why we’re using such information.

Data Protection Principles

We will comply with data protection law which says that the personal information we hold must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

The Information we Hold

We collect information about you and any other people to be covered by the contract, to create your contract, service your contract and to provide a range of services. Your information is collected in a number of ways through completion of an application form or claims form, directly from you or your financial adviser by post, email or telephone call. The information we collect will include but not be limited to:

Your identity, date of birth and contact details.
Your medical information.
Your hobbies and details about your lifestyle.
Your employment information.
Your financial information.
Banking, debit card details.

Where necessary we may also collect, store, and use the following ‘special category’ of more sensitive personal information such as:

Gender.
Marital status, details of your family members, next of kin and/or beneficiaries.
Details of any changes in your circumstances.
Criminal convictions.
Claims history.
Website user information.
CCTV images of you when you visit our premises.

We may also acquire information from third party sources such as medical professionals, accountants, HMRC, credit agencies, public sources, social media, and other online resources.

Personal Information on Behalf of Another

If you’re required to provide personal information of another person connected with your contract, you should ensure that those individuals are made aware and ensure they are happy to provide the information in accordance with this notice.

If you’re a parent, guardian or sponsor of a child contract holder or a child contract applicant then this notice, unless otherwise stated, applies to your information and information about the child.

How We Use Information

We’ll only use your personal information when the law allows us to. Most commonly, we’ll use your personal information in the following circumstances:

Where it’s necessary for performing the contract we have entered into with you.
Where we need to comply with a legal obligation.
Where it’s in the public interest to do so; or for official purposes; or in the exercise of a function of the Financial Conduct Authority (FCA) or the Prudential Regulation Authority.

There can be rare occasions where it becomes necessary to use your personal information to protect your interests (or someone else’s interests).

When We Use Information

We need all the categories of information in the list above (see: The Information We Hold) to enable us to perform our role and to enable us to comply with legal obligations. Some of the purposes will overlap and there can be several grounds which justify our use of your personal information. We’ll process your personal information for the purposes listed below:

To provide you with products and services.
Determining the terms of the product, such as exclusions.
General administration of the contract we have entered into with you, including accepting and administering claims.
Business management and planning, including accounting and auditing.
Gathering evidence and any other steps relating to complaints.
Planning for the termination of our relationship.
Education, training, and development requirements.
Complying with health and safety obligations.
To prevent fraud.
Share information with our regulators.
To monitor your use of our website of systems.
To ensure network and information security, including preventing unauthorised access to our systems.
Dealing with Freedom of Information Act requests.
For Cirencester Friendly operational and reporting documentation, such as the preparation of annual reports.
Where relevant, for publishing appropriate internal or external communications or publicity material (including photographic images) via the website, social media and other publicity and communications channels in appropriate circumstances.
Where relevant, to protect your interests or we deem there is a risk to life of you or another.

If You Fail to Provide Personal Information

You’re expected to let us know if your information changes as it’s important the information we hold on you is accurate. If you fail to provide certain information when requested, or to inform us if anything changes we may not be able to fully perform the contract we have entered with you, or we could be prevented from complying with our legal obligations.

Automated Means

We use automated decision-making processes within our underwriting procedures. It’s important to us that while automated decision-making plays a role in our underwriting process, it’s complimented by meaningful human oversight and review to ensure fairness and accuracy.

Use of Cookies

To make your visit to our website more attractive and to enable certain functions, we employ the use of cookies, which are small text files stored on your computer, on our pages.

Some cookies are deleted upon exiting the browser, others (persistent cookies) are stored on your computer and enable us to recognise you when you return to our website. For more information please check our cookie policy here.

We only disclose your information in the ways set out in this notice or subject to any agreements in place between us. We may share your personal data with third parties in the following circumstances:

To process personal data on our behalf.
To support service providers or medical professionals.
To process personal data on their own behalf such as your Financial Adviser.
To provide Membership benefits to you.
To undertake money laundering checks, credit risk reduction and other fraud and crime prevention purposes.
To provide communication or mailing services.
To any regulator, external auditor or applicable body or court where we’re required to do so by law or regulation or as part of any investigation.
To any central or local government department and other statutory or public bodies, such as the HMRC, Department for Work and Pensions.
Where we need to do so in order to exercise or protect our legal rights, other users, or our systems and services.

We will not sell or rent your data to third parties or share your data with third parties for marketing purposes. Where we rely on consent as the lawful basis for sharing your data, we’ll notify you and obtain your consent before doing so.

Data Security

We’ve put in place measures to protect the security of your information.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We’ve put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They’ll only process your personal information on our instructions.

We’ve put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we’re legally required to do so.

Data Retention

We’ll only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we’ll anonymise your personal information so that it can no longer be associated with you, in which case we’ll use such information without further notice to you. Once you’re no longer a Member of the Society, we’ll retain and securely destroy your personal information in accordance with our policy.

Right of Access, Correction, Erasure and Restriction

It’s important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a data subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we’re lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there’s no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we’re relying on a legitimate interest (or those of a third party) and there’s something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we’re processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please email our Data Protection Officer at dpo@cirencester-friendly.co.uk.

You won’t have to pay a fee to access your personal information (or to exercise any of the other rights). However, we’re allowed under the law to charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we can refuse to comply with the request in such circumstances.

What We Need From You

We sometimes need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information isn’t disclosed to any person who has no right to receive it.

In the limited circumstances where you have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact memberservices@cirencester-friendly.co.uk. Once we’ve received notification that you’ve withdrawn your consent, we’ll no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data Protection Officer

We’ve appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact dpo@cirencester-friendly.co.uk.

You have the right to make a complaint at any time to the DPO at the above email address or directly to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Web: Make a complaint

Telephone: +44 (0)303 123 1113

In Writing: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom.

Changes to This Privacy Notice

We reserve the right to update this privacy notice at any time, and we’ll update through our website. We’ll also notify you in other ways from time to time about the processing of your personal information.