OIC PRIVACY POLICY

PRIVACY STATEMENT


Unless otherwise defined below, capitalised terms defined in the Amending Scheme shall have the same meaning when used in this privacy policy ("Privacy Policy").

This Privacy Policy describes how Hampden PLC (the "Run-Off Company") and Dan Schwarzmann and Paul Evans of PricewaterhouseCoopers LLP, 1 Embankment Place London WC2N 6RH (the "Scheme Administrators", and together with the Run-Off Company "we", "us" or "our") collect and use your personal data during your visits to www.oicrun-offltd.co.uk (also known as www.thelondonandoverseasinsurancecoltd.co.uk, www.thelondonandoverseasinsurancecoltd.com and www.oicrun-offltd.com) (together the "Website"). This Website is administered by the Run-off Company on behalf of the Companies, both acting through the Scheme Administrators.

If you have any questions in relation to this Privacy Policy, in the first instance you can write to the Run-Off Company's Data Protection Officer at:

Hampden Plc
40 Gracechurch Street
London
EC3V 0BT

or via email at [email protected]

If you are concerned about how we process your personal information, or are not satisfied with our handling of a request you have made in relation to your rights, you can make a complaint to the Information Commissioner's Office via their website at www.ico.org.uk

PERSONAL DATA AND DATA COLLECTION


The Scheme Administrators and the Run-Off Company are the Data Controllers of any personal data submitted via this Website. They will store, process and/or otherwise use such personal data only for matters relating to the Scheme. The matters relating to the Scheme include:

  • administering and managing your claim;
  • responding to communications from you in relation to a claim;
  • keeping records of claims accurate and up to date; and
  • complying with our legal obligations.

This data may include (but is not limited to) identifiable information, such as your company address and contact details, as well as financial information provided by you, the Scheme Administrators or the Companies in relation to your claim. Some information may be necessary for us to manage your claim, and if you do not provide this we may not be able to manage it appropriately.

Where required, we use your personal data to meet our legal obligations (e.g. to regulators) or to meet contractual obligations to you (e.g. in relation to managing your claim). Where not strictly necessary for compliance with legal or contractual obligations, we process your personal data to meet our legitimate business interests in managing our business (e.g. in relation to managing claims made by your company and keeping our records accurate and up to date).

You have the right to object where we use your personal data to meet our legitimate interests as described more fully below.

The Scheme Administrators and Run-Off Company will not share personal data with third parties, unless (i) required by law or regulation; (ii) required by a reinsurer, as part of a request for claims information; (iii) required by a Scheme actuary; or (iv) you have given your express prior consent.

We may transfer your personal data to countries that are outside of the European Economic Area (EEA), including the US. If we do so, we will ensure that it is protected and that the transfer is lawful. We will do this by ensuring that the personal information is given adequate safeguards by using 'standard contractual clauses' which have been adopted or approved by the European Commission, the EU-US Privacy Shield Framework or other solutions that are in-line with the requirements of European data protection laws.

DATA PROTECTION RIGHTS


You have a number of rights in relation to how your personal information is processed by us. We have set out these rights below. These rights are not absolute and will apply, subject to certain conditions, as set out in applicable data protection legislation. Your rights may include:

  • to access your data (by way of a subject access request);

  • to have your data rectified if it is inaccurate or incomplete;

  • in certain circumstances, to have your data erased, for example if you withdraw your consent to us using it, or we no longer need it for the purpose for which we collected it;

  • in certain circumstances, to restrict the processing of your data;

  • a right of data portability, namely to obtain from us in a structured, commonly used and machine-readable format a copy of your data for you to reuse for your own purposes across different services;

  • to object to direct marketing. If we use information about you for this purpose you can "opt-out" without the need to justify it;

  • if we use the information about you on the basis of our legitimate interest, other than for the purpose of direct marketing, you can object to our using it for those purposes;

  • not to be subject to automated decision making (including profiling), where it produces a legal effect or a similarly significant effect on you;

  • to claim compensation for damages caused by a breach of the data protection legislation;

  • if we are processing your personal information with your consent, you have the right to withdraw your consent at any time.

If you wish to apply any of your rights, you can contact us:

By phone: +44 (0) 207 863 6560

By email: [email protected]

By post: Hampden Plc, 40 Gracechurch Street, London, EC3V 0BT

SECURITY AND CONFIDENTIALITY


We take all reasonable steps to protect the personal data and information held on this Website from loss, misuse, unauthorised access, modification or destruction. In particular, the area of the Website containing sensitive policyholder information (the "Secure Area") is located on a secure server designed to prevent unauthorised activity. In addition, creditor-specific information cannot be accessed without a unique Scheme Creditor login ID and password.

Access to the secure server or use of encryption may be denied if a company's network is protected with a firewall. If you cannot connect to the Secure Area, check with your IT administrator to see if a firewall is in place. If you are still unable to access the Secure Area, please contact us.

DATA STORAGE


We retain your personal data for as long as you have a relationship with us (e.g. for as long as you or your company have a claim, or for as long as you are in contact with us). We also keep personal data for a longer period. When determining this longer period, we take into account the amount of time we need that personal data to:

  • Maintain our business records for audit purposes;
  • Comply with record retention requirements under the law;
  • Defend or bring any existing or potential legal claims;
  • Deal with any complaints regarding our services or any claims;
  • Enable the Scheme Administrators to implement the Amending Scheme.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

THIRD PARTY LINKS


This Website may contain links to other websites. Please be aware that we are not responsible for the content or privacy practices of such other sites. Please ensure that you identify when you have left this Website and read the privacy statements of any third party website.

MODIFICATIONS


The Scheme Administrators reserve the right to amend this Privacy Policy at any time, for example to keep it up to date or to comply with legal requirements and any such amended policy will only apply from the date of amendment. By continuing to access and use the Website you will be deemed to agree with the amended policy.

COOKIES


We may use cookies in the operation of this Website, in accordance with our Cookie Policy set out below.

Cookie Information:


This Website uses cookies to enhance usability. Cookies are small often encrypted text files stored on your computer by the web browser. On the Website, cookies are used to improve your experience. None of the cookies will contain personal information or tracking data.

You may Delete and Block all cookies from the Website, but if you do, you may affect the funcionality of the Website

This Website uses cookies in the following way:

Cookie Name Purpose

Application Session Cookie This cookie maintains some of the data you enter when using the Website. The data will be removed from your
system when you leave the Website.
Client Settings Cookie This cookie contains information about preferred settings you select when using the Website. This cookie will
store data on your system to recall your preferences when you return to the Website.