HMCA Insurance Limited
Registered office: 33/2 Cannon Lane, Gibraltar
The personal data of all data subjects is collected in line with the requirements of the Gibraltar General Data Protection Regulation (“GDPR”) and the Data Protection Act 2004.
The Data Protection Officer (“DPO”) is responsible for ensuring that this notice is made available to data subjects prior to HMCA Insurance Limited collecting and processing their personal data.
Who are we?
HMCA Insurance Limited is an Insurance Company authorised and regulated by the Gibraltar Financial Services Commission (GFSC), with passported authority to issue Insurance in the UK regulated by the Financial Conduct Authority. We offer health related insurance products both direct and via intermediaries in the UK.
HMCA Insurance Limited’s Data Protection Officer is Jackie Bibby who can be contacted directly on 00350 200 61430 or by email at email@example.com
HMCA Insurance Limited would like to collect from you and that of any other names you provide, information that will allow us to provide you quotations, and manage your policies, including underwriting and claims handling. Your information comprises of the details we hold about you and your transactions and includes information we obtain about you from third-party sources who promote HMCA Insurance Limited’s products.
Personal data includes information HMCA Insurance Limited obtains about you from the:
- Forms and surveys you complete
- Records of our correspondence and phone calls; and
- Details of your visits to our website.
HMCA Insurance Limited collects only the information needed so that it can provide you with the service you expect from it.
HMCA Insurance Limited does not sell or broker your data.
How we use your personal data:
- To carry out our contractual obligations arising from any contracts entered into between you and HMCA Insurance Limited;
- To provide you with information on products or services that you request from us; or
- That which HMCA Insurance Limited believes may interest you using the post, telephone and email. To enable you to participate in interactive communications concerning the services offered by HMCA Insurance Limited, if you choose to do so;
- To notify you about changes to the service you get from HMCA Insurance Limited;
- HMCA Insurance Limited may also use data obtained from you to ensure that the content from our website is presented in the most effective manner.
Our legal basis for processing personal data:
To meet HMCA Insurance Limited’s contractual obligations to policy holders and to also respond to individuals making enquiries for specific products.
Any legitimate interests pursued by us, or third parties we use, are as follows:
To pursue HMCA Insurance Limited’s legitimate interests of promoting private healthcare and other policies which HMCA Insurance Limited believes may be of interest to you.
Some health data is classified as a special category of personal data:
HMCA Insurance Limited will only collect the minimum amount of health data needed to fulfil its contractual obligations to you.
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for HMCA Insurance Limited to process both personal data and special categories of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by contacting the DPO, contact details are listed at the bottom of the policy.
HMCA Insurance Limited will process personal data during the duration of the policy and will continue to store personal data for six years after the policy has terminated in order to meet any subsequent legal liabilities.
Where individuals have enquired about a policy but not accepted it, HMCA Insurance Limited will continue to maintain contact for up to four years after which any personal data will be deleted.
Data is stored locally in Gibraltar and backed up in the United Kingdom.
All servers are encrypted.
No data is stored in the cloud.
Why does HMCA Insurance Limited need to collect and store personal data?
In order for us to provide you with a service, HMCA Insurance Limited needs to collect personal data for communicating with you concerning the policies offered and subsequently administrating any policy you purchase. In any event, we are committed to ensuring that the information we collect and its use is appropriate for this purpose, and does not constitute an invasion of your privacy.
Will HMCA Insurance Limited share my personal data with anyone else?
HMCA Insurance Limited sometimes needs to pass on your personal data to third-party service providers contracted to HMCA Insurance Limited, such as companies within the same group, auditors etc.
Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to meet HMCA Insurance Limited’s contractual obligations to you or to communicate information about other services we offer. When they no longer need your data to fulfil this service, they will dispose of the details in line with HMCA Insurance Limited’s procedures, which is normally within 30 days of completion of the task unless part or all of the data is required to be retained to meet legal or contractual obligations such as post-operative support. If HMCA Insurance Limited wishes to pass your special category data onto a third party it will only do so once it has obtained your consent, or where HMCA Insurance Limited is legally obliged to divulge information.
HMCA Insurance Limited does not hold personal data outside the UK, Gibraltar or the EEA.
How will HMCA Insurance Limited use the personal data it collects about me?
HMCA Insurance Limited will process (collect, store and use) the information you provide in a manner compatible with the Gibraltar General Data Protection Regulation (“GDPR”). HMCA Insurance Limited will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary, this is normally four years after an enquiry or six years after all policies have lapsed.
HMCA Insurance Limited is required to retain certain information in accordance with the law, such as details needed for income tax and audit purposes.
How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. In certain circumstances, such as contractual disputes or with your permission, personal data may be held for longer periods.
Under what circumstances will HMCA Insurance Limited contact me?
Our aim is not to be intrusive, and HMCA Insurance Limited undertakes not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Your rights as a data subject:
At any point that 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 HMCA Insurance Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in section 9 below.
Can I find out the personal data that the organisation holds about me?
HMCA Insurance Limited, at your request, can confirm what information we hold about you and how it is processed. If HMCA Insurance Limited does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. In all cases, this will be a representative in the UK or Gibraltar.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of HMCA Insurance Limited or a third party and information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
HMCA Insurance Limited accepts the following forms of ID when information on your personal data is requested:
- A copy of your passport, driving licence, birth certificate and a utility bill not older than three months.
- A minimum of one piece of photographic ID listed above and a supporting document is required.
If HMCA Insurance Limited is dissatisfied with the quality, further information may be sought before personal data can be released.
Data Protection Officer (DPO)
HMCA Insurance Limited
33/2 Cannon Lane
Telephone: +350 200 61430
In the event that you wish to make a complaint about how your personal data is being processed by HMCA Insurance Limited (the third parties as described in section 4), or how your complaint has been handled, you have the right to lodge a complaint directly to HMCA Insurance Limited and the supervisory authority as detailed below:
James Llandro, Director
HMCA Insurance Limited
33/2 Cannon Lane
Telephone: +350 200 61430
Gibraltar Regulatory Authority
2nd Floor, Eurotowers 4
1 Europort Road
Telephone: +350 200 74636