CWH & Co is committed to protecting the privacy of information relating to individuals and business partners within the scope of our business as independent claims handling company. CWH & Co is predominantly appointed to handle, investigate and adjust claims on behalf of Insurers and specialises in claims for loss or damage to goods arising from relocation, removals and/or storage contracts. Our Principals underwrite insurance policies for UK and International Removal or Relocation Companies as well as Freight Forwarders and Hauliers. This privacy policy is based on the requirements stated by GDPR, effective 25 May 2018, which supersedes any prior privacy act or data protection act prescribed by the U.K. Government.
Introduction
Please read this privacy policy carefully as it contains important information relating to the personal information that we retain and/or process about you, which could identify you (“personal information”), and is either obtained from your insurance provider or you directly. We take the protection of your privacy and confidentiality seriously. We understand that all customers and users of our website are entitled to know that their personal data will not be used for any unintended purpose. We undertake to preserve the confidentiality of all information you provide and have put safeguards in place to prevent information accidentally falling into the hands of a third party.
This document sets out the conditions under which we may process any information that we collect from you, or that you provide to us. In the context of the law and this document, “process” is defined as collecting, storing, transferring, using or otherwise acting on information.
Our policy complies with the U.K.’s Data Protection law, including the EU General Data Protection Regulation (GDPR). It also aims to comply with the law of the countries or legal jurisdictions in which we do or aim to do business. The law requires us to tell you about your rights and our obligations to you regarding the processing and control of your personal data. These topics are covered below and we also advise that you read the information provided at www.knowyourprivacyrights.org.
By using our services and in providing your personal data you are consenting to the conditions of this privacy policy.
How we use your information
Some or all of the information you supply to us in connection with your insurance claim will be held in house and may be passed to other parties for claims purposes. You have a right of access to see personal information about you that is held in our records. If you have any queries, please write to the ICA’s GDPR representative.
Except as set out below, we do not share, sell, or disclose to a third party, any information collected through our website or by our staff.
The basis for collecting certain information, some of which may contain personal details, is to enable CWH & Co to effectively conduct work as defined by our business, and any information processed is done on the basis that we have a contractual obligation with you and will use the information only within defined business parameters.
When you contact us via our website, or we have a pre-existing business relationship, or when we are nominated as your claim handlers, or you otherwise agree to our terms and conditions, a contract is formed. To carry out our obligations under that contract we must process the information you give us, and do so on the basis there is a contract between us, or that you have requested we use the information to effectively conduct business relating to insurance claims. We may use your information to:
- Verify your identity for security purposes
- Verify your banking details
- Provide you with our services, which may include providing you with suggestions or advice on claims
We shall immediately stop processing your data when the contract between us ends or is terminated by either party under the terms of the contract. Under usual circumstances our contract is ended upon the completion of your claim. Should there be a legitimate reason for us to change the way we use or process your information, we are required by law to inform you. If you do not object, you consent to that change.
Submitting your information via our website
CWH & Co has one point of contact on our website, the “Contact CWH” form. No other area on the website processes your information. Once your information enters the public domain, we have no control over what any individual or third party may do with it. We accept no responsibility for their actions at any time. In relation to website use, the information accessed by CWH & Co extends to your IP address and the information you submit on the “Contact CWH” section, namely your name, email address, telephone number and your message to us.
Consent
Consent is either implied or explicitly given.
Submitting a contact form via our website implies consent while it does not qualify as a contractual relationship between us. By initiating contact in this way, you provide your consent to us to process your personal information. Implied consent is also given when you contact us by e-mail, to which you would reasonably expect us to reply.
You give explicit consent when we directly obtain your consent to process your information. Your explicit consent is also obtained during standard business practices that enable us to effectively process your insurance claim, should we require pertinent information that was not passed to us by your insurance provider.
Implicit consent is given when your information is passed to us by your insurance provider, who, as our contracted business partner, has nominated us to handle your insurance claim.
To maintain good business practice, we will not contact you without prior notification from your insurance provider.
We do not conduct “cold calling” to obtain your business or request your personal information.
How your information will be used and who we share it with
If you have given us explicit permission to do so, we may from time to time pass your (claim related) information to selected third parties, such as claims surveyors, solicitors or loss adjustors, who may provide services that will expedite the resolution of your claim. Prior to disclosing your information we will obtain your permission. The only exception will be where we are required or permitted to do so by law.
We may transfer your information to companies in other countries, however this will only be done if it relates specifically and directly to your claim, and you will be informed accordingly. Information sharing is done on the basis that recipients provide an adequate level of protection. In such cases we will ensure it is kept securely and used only for the purpose for which you provided it.
Although we do not disclose your information to any third party except as set out in this document, we receive data containing your information from third parties (your insurance provider) to process your claim at their request.
We will not freely hand over or sell your personal information to third parties such as marketing companies for financial gain.
Access to your personal information and the right to “be forgotten”
You may review or update personal information that we hold about you at any time. You can also request that any personal information is removed from our records. This can be done by contacting us by phone or sending a request via email.
When we receive a request to access, edit or delete personal identifiable information, reasonable steps will be taken to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information. Provided your request is reasonable and there is no legal basis for us to retain it, then, at our discretion we may agree to your request to delete personal information that you have posted.
After receiving a request, we will advise you when we expect to provide you with the information, and whether we require any fee for providing it to you.
Retention period for personal data
By law we are obliged to store your information until the statutory period for keeping any such records has expired. Except where an agreement is reached that your information is disposed of in a suitable manner, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested;
- to comply with other law, including for the period demanded by our tax authorities;
- to support a claim or defence in court.
How we protect your data
We endeavour to take all reasonable steps to protect your personal information. However, we cannot guarantee the security of any data that you disclose online and we will not be responsible for any breach of security unless this is due to our negligence or wilful default.
As a rule, your information is securely provided to us by your insurance provider. We have several processes and safeguards in place to ensure confidentiality of your information, restriction of its use, and safe destruction thereof, once the information is no longer legally required to be kept.
Questions / Complaints
Complaints regarding our use of your personal information, how we have dealt with your request for personal information to be amended, destroyed or passed back to you, or any other GDPR-related concerns, will be investigated directly by our Compliance department.
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If you are not happy with our privacy policy or if you have any complaint then you should tell us by email.
If your complaint reasonably requires us to contact another person or company, we may decide to, or be required to give to that other person or company some of the information contained in your complaint. We do this as infrequently as possible.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
How to contact us
| Request to be forgotten / Request for your personal information | claims@cwh.co.uk / 020 8467 6600 |
| Complaints | claims@cwh.co.uk / 020 8467 6600 |
Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records. The terms that apply to you will also be provided to you by CWH & Co’s claims handlers or administrators at the onset of our dealings with you. If you have any question regarding our privacy policy, please contact us.