Privacy policy

1. WHO WE ARE

This Data Privacy Notice (“Privacy Notice”) sets out the basis on which Alpha Insurance Analysts Limited (“Alpha”, “we” or “us”) collect information from you.

We collect and process your personal information in accordance with this privacy notice and in compliance with applicable data protection laws and regulations. This notice outlines your rights and our responsibilities, and explains how, why, and when we handle your personal data.

Alpha’s registered office is at 107 Fenchurch Street, London, EC3M 5JF. Alpha is a company registered in England and Wales with the company number 2915929 and is registered with the Information Commissioner’s office as a data controller with the registration number Z1071668. Alpha’s Compliance Director, Jenny Doyle, is responsible for data protection at Alpha.

We are committed to protecting your privacy. We comply with UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable data protection laws and strive to maintain consistently high levels of best practice in our processing of personal and/or sensitive data.

2. WHY AND WHEN DO WE PROCESS YOUR PERSONAL DATA

We process your personal information to meet our legal, statutory and contractual obligations and to provide you with our services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as outlined in this notice. We only collect personal data that is necessary to provide our services, meet our legal and regulatory obligations and protect our legitimate business interests. The information we collect will depend on the services we provide to you and your relationship with Alpha.

We may collect and process personal information about you:

• When you contact us to enquire about our services;
• For you and Alpha to enter into a contractual relationship with us and to enable us to provide the service required;
• If you contact us by telephone or email or via our website for any other reason.

We collect data from you in the following ways:

• On an Alpha Fact Find or Lloyd’s Personal Information form (PIF) for purposes such as updating Lloyd’s records or for a new application for membership, conversion or change of control or in response to a request from Lloyd’s.
• Annually, on your Risk Profile form or a Fact Find form.
•  Through routine correspondence with you.

3. WHAT INFORMATION DO WE COLLECT AND HOLD ABOUT YOU?

We collect and retain the following personal data and information for you either as an unlimited member, or for you and for any participants if you underwrite through a limited liability vehicle.

• Individual details – name, address (proof of address) and other contact details including your telephone numbers, your gender, marital status, date and place of birth, nationality, employer, job title and employment history and family details including their relationship to you.
• Identification details – identification numbers issued to you by government bodies or agencies including your national insurance, Unique Taxpayer Reference, passport, driving licence and Financial Conduct Authority/Prudential Regulation Authority ID numbers.
• Credit and anti-fraud data – your credit history, credit score, sanctions, politically exposed person status, information on criminal offences and from anti-money laundering, sanctions screening and anti-fraud databases relating to you.
• Financial information – details of your funds at Lloyd’s (FAL), your underwriting portfolio, your auction activities, bank details and financial information relating to you and your family including assets and liabilities, income and source of wealth information. We will also keep information or certification from you which we request to establish whether you have sufficient knowledge and experience to invest at Lloyd’s.
• It is possible that we will also hold special categories of personal data such as health/medical information and criminal convictions, collected as part of an on-boarding or due diligence exercise or during our relationship with you (e.g. health data for a stop loss quotation).

We also hold the following data on our files:

• Specific information which may be required by Fidentia Services LLP (Fidentia) or Nomina plc (Nomina) (service providers involved in the administration of limited liability vehicles) if you underwrite through a limited liability vehicle managed by Fidentia or Nomina which may include details of your personal financial or tax position.
• Information relating to your access to our secure client portal (such as your username and any authentication details).
• Communications between you and Alpha, including emails, letters, telephone recordings and meeting notes where relevant to providing our services or meeting our legal or regulatory obligations.

4. HOW DO WE USE THE DATA YOU PROVIDE TO US?

The legal basis for which we process your personal data may be:

• To enable us to perform our obligations to you under the Members’ Agency Agreement or our contract for the provision of our services for you or the limited liability vehicle in which you do (existing LLVs) or will (new LLVs) participate either during or prior to entering into that contract with you;
• To comply with a legal obligation to which we are subject, such as for identification and verification purposes and to meet requirements of a regulatory authority including the Society or Corporation of Lloyd’s.
• For legitimate interests offered by us or a third party including providing information about services or opportunities which are relevant to your Lloyd’s underwriting activities, where we are entitled to do so under data protection and electronic marketing legislation or where you have consented to be contacted for such purposes. This includes marketing information for a third party such as for the sale of a LLV or a reinsurance product.
• Where you have given consent to us to do so including the processing of special categories of personal data.

We do not disclose your personal data to any third parties except as stated in this privacy notice as detailed below and as permitted or required by law, or as authorised by you. We share your data with the Corporation of Lloyd’s, the managing agents of the syndicates on which you participate and Fidentia or Nomina (if either of these companies manages a LLV in which you participate), when required to do so in respect of the business and your underwriting affairs at Lloyd’s. We will also provide data to reinsurance providers where appropriate and to your investment manager or accountant with your permission. Some of our service providers may process personal data outside the UK. Where this occurs, we will ensure appropriate
safeguards are in place in accordance with UK GDPR, such as the use of adequacy regulations or approved contractual safeguards.

We may disclose your personal data to other companies who provide services to us including data management providers, IT providers, email delivery services, website hosts, company secretarial providers, auditing and other third party services, or in the event of any merger, sale or other transfer of all or part of our business, when personal data held by us may form part of the transferred assets.

We are under a duty to disclose or share your personal data to perform our contract with you or to comply with our legal and regulatory obligations. We do not sell, trade, or rent your personal information to others.

5. HOW DO WE PROTECT YOUR DATA?

As required by the data protection laws, we follow strict security procedures in the storage and disclosure of information you have given to us.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on our secure servers. Access to these servers is restricted to our directors and employees.

We also store data relating to your underwriting affairs at Lloyd’s that can be accessed by you using a password through the secure private client area of our website. We do not have access to your password. Where you have been assigned an automated password (or where you have chosen one) which enables you to access our website, you are responsible for keeping this password confidential and for changing it every few months to ensure it is kept secure. We ask you not to share a password with anyone.

In the case of communications by email you should note that email is not always a secure method of communication. Unless encrypted, emails may be intercepted or accessed by unauthorised persons. Please do not send highly sensitive personal information by email unless appropriate security measures have been agreed.

If you provide us with personal data including ID documents, financial information or bank details, we will keep such documents and information secure. We will ensure that the bank details are only passed on to third parties with your consent. We use electronic screening tools to assist with anti-money laundering, sanctions and fraud prevention checks. No decisions that have a legal or similarly significant effect on you are made solely by automated processing.

If we provide information to a third party, we will exercise the strictest control over the third party contractually, requiring it to:

• Maintain the security and confidentiality of the information and restrict access to those of its own employees.
• Use the data for the agreed purpose only and prevent it being used for any other purpose by any other party.
• Refrain from communicating with you other than concerning the issue in question.
• Return the data to us at the conclusion of any contract term and destroy or delete any copies made of all or any part of the information unless copies are needed to comply with regulations.
• In addition, we will restrict the information disclosed to the absolute minimum necessary, for example, to provide a product or service.

Our own security procedures mean that we may occasionally have to request proof of identity (ID) and in the event of telephone calls from you, we also reserve the right to ask security questions in order to satisfy ourselves that you are who you say you are.

6. RETENTION OF YOUR PERSONAL DATA

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting and reporting requirements. Our retention periods are set out in our internal Records Retention Policy and are available on request.

7. RECORDING TELEPHONE CALLS

We record telephone calls with you in order to check that we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve our quality of service, and to help detect or prevent fraud or other crimes.

8. YOUR RIGHTS

You can write to us to obtain further details about the personal data that we hold about you, the purpose for which we hold it, how long we will store it and, if we did not collect it, where it came from:

Our contact details are:

Alpha Insurance Analysts Limited
107 Fenchurch Street
London EC3M 5JF
Email: [email protected]

You have the right to:

• Ask us to correct and/or complete the information, if you believe that we hold any incomplete or inaccurate data about you. We will strive to do so as quickly as possible unless there is a valid reason for not doing so at which point we will notify you.
• Ask us to delete any personal data that we no longer have a lawful purpose to use.
• If we are processing with your consent (as opposed to under a legal obligation or for legitimate interests), you have a right to withdraw that consent.
• Object to us using data for legitimate interests (such as marketing the sale of a LLV to you).

You also have the right to:

• to request access to the personal data we hold about you;
• to request restriction of processing in certain circumstances;
• to request the transfer of your personal data where applicable (data portability);
• to object to certain processing based on legitimate interests.

9. LODGING A COMPLAINT

Alpha only processes your personal data in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however, you wish to raise a complaint regarding the processing of your personal data, or are unsatisfied with how we have handled your data, you have the right to lodge a complaint with Information Commissioner’s Officer (ICO) through the following link: Make a complaint | ICO.

Further information is available from the Information Commissioner’s Office.

If you have any questions about this Privacy Notice, please contact our Compliance Director, Jenny Doyle, on 0207 767 3421 or [email protected]