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Usay Business Limited - Privacy Notice

How we use your information

We respect your personal privacy and will not use your personal information in any way that we would not accept ourselves. We have set out the following information about how we manage the personal information we do collect. If you have any comments or concerns regarding our privacy policy or our use of your information please contact us.

1. Who we are

We are Usay Business Limited ("Usay"). We provide a price and content comparison a range of general insurances via our website UsayCompare.co.uk and through our telephone advisery service. As part of this service we may refer our customers to insurers for an appropriate insurance product.

We are a company registered in England and Wales under company number 6463920 and our registered company address is Usay House, 5 Hercules Court, Lakeside business Park, Broadway Lane, South Cerney Cirencester GL7 5XZ. We are authorised and regulated by the Financial Conduct Authority reference No 478676.

2. Our contact details

If you want to contact us you can do so by:

  • Writing to us at Usay House, 5 Hercules Court, Lakeside business Park, Broadway Lane, South Cerney Cirencester GL7 5XZ
  • Telephoning us at 01285 864670
  • Faxing us at 01285 343039
  • Emailing us at info@usaycompare.co.uk

3. Our Data Protection Officer

At Usay we take how we use your information seriously and so we have appointed a Data Protection Officer who has special responsibility for how we deal with the personal information of other people. If you have any queries about what we do with your information, or you have any other questions or request concerning your information (including if you want to exercise any of your rights under section 10 below) you can contact our Data Protection Officer using the details below:

Alternatively you may write to, fax or telephone him using the details in at sections 2 above.

4. The information that we may hold

We hold the following different types of personal information:

Customer Information:

The type of information that we hold

  • Name and contact details - so we know who our customers are and how to contact them
  • Type of insurance requested -so that we can help locate an appropriate insurance policy
  • Medical information - so that we can help the customer apply for the correct insurance policy, and so that we can tell insurers about the customer's past medical history
  • Bank details - so that these can be sent to an insurer for an insurer to take payment, and so we can remunerate our customers directly when it is appropriate to do so
  • Employment details - so that we can tell an insurer the customer's occupation
  • Date of birth - so that we can tell an insurer how old the customer is

Why we hold it

We hold this information so that we can help our customers obtain an insurance policy.

We may then keep this information for our records and for legal and regulatory purposes.

Why we are allowed to use the information

  • Consent - By providing us with this information our customers consent to us using their information
  • Contract - We need to use the customer's information so that we can perform our service to the customer
  • Public interest - the use of the information is in the public interest, specifically the provision of insurance
  • Legal obligations - we have legal and regulatory obligations to show that we are carrying out our business in a compliant manner
  • Legitimate interest - We have a legitimate interest in carrying out our business of insurance introductions, including that we keep a record of our activities both for our client's benefit and also for our own legal and regulatory reasons.

Where we use medical information we only rely on consent and public interest to use this information.

Who we will share the information with

We will share information with insurers, as requested by the customer.

We may also share your information as set out in section 5 below.

How long will we hold the information for

If the customer decides to take out an insurance policy we will keep the information for 7 years from the end of the last insurance policy that is taken out or renewed.

If the customer does not take an insurance policy but has shown an interest in an insurance policy we will keep the information for 6 months from the end of our contact with the customer, unless the customer has consented for us to keep it for longer, in which case we will keep it until the consent expires.

How we obtain the information

We either obtain the information directly from the customer, or from third party sellers of leads. If you would like to know the identity of the person who sold us the lead please contact us.

Third party medical details:

The type of information that we hold

If a customer applies for certain types of insurance they may be asked about the medical history of their close relatives, and we will record and keep the answer to that question. We will not capture any other information about the relative, for example we do not record the names of relatives.

Why we hold it

We hold this information so that we can help our customers obtain an insurance policy.

We may then keep this information for our records and for legal and regulatory purposes.

Why we are allowed to use the information

  • Public interest - the use of the information is in the public interest, specifically the provision of insurance. However, we will not use the information if we believe that the relative would not consent to it (for example if they tell us that they do not consent)

Who we will share the information with

We will share your information with insurers, as requested by the customer.

We may also share your information as set out in section 5 below

How long will we hold the information for

If the customer decides to take out an insurance policy we will keep the information for 7 years from the end of the last insurance policy that is taken out.

If the customer does not take an insurance policy but has shown an interest in an insurance policy we will keep the information for 6 months from the end of our contact with the customer, unless the customer has consented for us to keep it for longer, in which case we will keep it until the consent expires.

How we obtain the information

We either obtain the information directly from the customer, or the information may be bundled in a lead that we purchase. If you would like to know the identity of the person who sold us the lead please contact us.

Employee and potential employee information:

The type of information that we hold

  • Personal Details - such as name and contact details, so that we know who our employees are and how to contact them
  • Financial details - such as salary and bank details, so that we can pay our employees
  • Employment history - so that we can obtain references and assess suitability
  • Doctors reports - so that we may assess reasons for absenteeism and to ensure we provide a suitable workplace
  • Employment records - details of the role the employee does for us, and related information such as disciplinary matters, grievance records, performance reports, pension documents etc
  • Criminal convictions - we may carry out a check for criminal convictions on our employees

Why we hold it

We hold this information so that we can run our business.

Why we are allowed to use the information

  • Consent - employees consent to us holding certain information about them in their employment contract and/or in application forms
  • Contract - We need the information for the purposes of preparing for or carrying out the employment contract
  • Legitimate interest - we have a legitimate interest in running our business
  • Legal obligations - we need this information to comply with our legal obligations (in particular we may need medical information for employment law purposes so that we can make reasonable adjustments to how you work)

Where we use medical information we only rely on consent and employment law purposes to use this information. Where we use information about criminal convictions we rely on consent.

Who we will share the information with

We will share your information with the Sage Group Plc, our payroll company, to ensure that the employee gets paid.

We will share your information with third parties to fulfil our legal obligations such as HM Revenue and Customs, financial auditors and the Office for National Statistics.

We may also share your information as set out in section 5 below

How long will we hold the information for

We will keep information for employees for a period of 8 years after termination of the employment contract.

We will keep information about prospective employee for a period of 6 months from last contact

We are required to keep any board minutes for 10 years, which may refer to the names of employees.

How we obtain the information

We normally obtain the information directly from the employee or applicant. However, in some circumstances we may ask previous employers or other third parties for references. We will also carry out checks at Creditsafe, a credit reference agency, for information about your past financial activity and your credit rating and may contact Gloucestershire County Council, who carries out a search for criminal convictions.

Insurers, Intermediaries, other third party suppliers and business contacts:

The type of information that we hold

We do business with many organisations, such as insurers, other insurance brokers, or other suppliers (such as legal advisers, accountants, office equipment suppliers). We will keep contact details for individuals at those organisations, and we may also keep financial information, such as bank details. We may also have other business contacts for who we keep contact details (such as shareholders, associated companies or business acquaintances)

Why we hold it

We hold this information so that we can run our business.

Why we are allowed to use the information

  • Consent - if we have been provided with contact details by a person then that person has consented to us having those contact details
  • Contract - the information may be necessary so that we can perform a contract with the organisation
  • Legitimate interest - we have a legitimate interest in being able to conduct our business

Who we will share the information with

See section 5 below.

How long will we hold the information for

We will retain contact details for as long as we carry on business, unless those contact details become out of date (in which case they will be deleted)

We will keep bank details for a period of 2 years after the end of the applicable contract

How we obtain the information

We obtain the information directly from the insurer, intermediary or third party, or from publicly available information such as websites or phone directories.

Appointed Representatives:

The type of information that we hold

If we appoint an appointed representative then we will keep that representative's contact details, financial information and other information about how that representative conducts its business. This may include details about the appointed representative's customers, including medical information

Why we hold it

We hold this information so that we can ensure that the appointed representative is acting or will act appropriately, and to comply with our legal and regulatory obligations

Why we are allowed to use the information

  • Contract - it is necessary for the performance of the appointed representative contract, or to prepare for such a contract
  • Legal obligation - we have legal obligations to ensure that our appointed representatives act in a compliant manner;
  • Legitimate interest - we have a legitimate interest in appointing appointed representatives, and also in being able to defend any claims made against us as a result of the actions of an appointed representative
  • Public interest - where we hold medical information about clients or relatives of clients of appointed representatives there is a public interest in being able to provide insurance by way of an appointed representative. However, where the information is about a client's relatives we will not use the information if we believe that the relative would not consent to it (for example if they tell us that they do not consent)

Who we will share the information with

See section 5 below.

How long will we hold the information for

We will hold this information for 7 years from the later of:

  • The end of the appointed representative contract
  • Where the information is that of a client of the appointed representative or a relative, from the last contract of insurance or renewal in respect of that customer

How we obtain the information

We obtain the information from the appointed representative. We will also carry out checks at Creditsafe a credit reference agency, for information about your past financial activity and your credit rating and may contact Gloucestershire County Council, who carries out a search for criminal convictions.

5. Other people that we may provide information to

In addition to what is set out in section 4 above we may also share information with the following people.

IT companies

We use the following third party suppliers to help us run our business. These suppliers may therefore have access to the information set out above:

  • We use a company called BOM Group Limited that provides us with IT services such as file storage and email
  • We use a company called UKFast.Net Limited that hosts an IT platform that we use for our business
  • We use Google Cloud part of Google Incorporated to host other aspects of our IT platform
  • We use Rackspace Incorporated for support and maintenance of Google cloud resources
  • We use a company called GBE Converge that provide us with IT services such as firewalls and internet security

Legal and regulatory bodies

We are authorised and regulated by the Financial Conduct Authority. They may require access to the information that we hold. We may also have to share your information with other regulators, for example the information commissioner, or to other bodies that have a legal right to obtain it, such as the police.

Legal advice and disputes

We may need to share your information with our legal advisers. If there is a dispute between us or you make a complaint (or a third party makes a complaint or raises a dispute that involves you) we may also need to share your information with any person adjudicating on that dispute or complaint, such as a court or an ombudsman.

Business purchaser

If we decide to sell our business we may provide your information to any potential purchaser of our business.

Group members

We may share your members for other members of the Usay Group of companies. We will do this where you consent to us passing on your details in order for that other company to provide a quote or other service to you, but we may also do this where we have a legitimate interest such as sharing data for research or statistical purposes, for helping improve systems or to otherwise help us improve the running of a business of a group company.

6. Other uses of your information

In addition to what is set out in section 4 above We may use your information:

  • for research, analysis or statistical purposes.
  • for system administration or development purposes and to form personalised profiles and demographics that we may use to improve the content of our communications to you

We have a legitimate interest in doing this so that we can run our business more efficiently.

7. Marketing

We may use your information to deliver personalised offers and promotions based upon your demographics and product purchase profile. We will only do so where:

  • We have your express consent; or
  • You are a customer and the offers and promotions are about our own products and services which we believe will be of interest to you. We can do this because we have a legitimate interest in marketing our business.

It is possible to opt out of such communications or to withdraw such consent by contacting us by any of our contact details in section 2 above. There is also an unsubscribe function on our website which can be used to unsubscribe from email communications.

We will not sell any of your information to third parties for the purpose of marketing.

8. Public interest processing

Where we rely on the public interest to use any of your information then you can object to us doing so. See the "right to object" in section 10 below.

9. Legitimate Interests

Where we have referred to having a legitimate interest to use any of your information then we have balanced our legitimate interest against your rights and interests to have your information protected. If you would like details about how we have done this please contact us. You may also object to us processing the information in this way - see the "right to object" in section 10 below.

10. Withdrawal of consent

Where we rely on your consent to use your information you may withdraw that consent at any time by contacting us using the details in section 2 above. We shall then stop using your information, unless there is another applicable reason for which we can use it set out in section 4 above. The withdrawal of consent shall not affect the lawfulness of any use of the information that occurred prior to the withdrawal of consent.

11. Your rights

If we hold information about you then you have the following rights in respect of our use of that information:

  • A right of access to your information and to details about how we use your information
  • A right to rectification of inaccurate information
  • A right to have information erased (a right to be forgotten)
  • A right to restrict the use we can make of your information
  • A right to information portability
  • A right to object to the processing of your information

To exercise any of these rights contact either us or our data protection officer using the contact details in sections 2 or 3 above. You can find more detail about these rights below.

We will comply with any of these rights as soon as possible and in any event no later than one month from the request (although if the request is complex or there are numerous requests we may extend this by up to two further months).

We will not charge for any request, unless it is manifestly unfounded or excessive (for example because it is repetitive). If a request is manifestly unfounded or excessive then we will either charge our reasonable administrative costs to comply with it, or we tell you that we are not going to comply because it is manifestly unfounded or excessive.

Access to information

You may request access to the information that we hold about you, together with information about the purposes for which we use that information, the type of information we hold, who we disclose it to, and the length of time which we hold it for. This is commonly referred to as a subject access request.

If you make a subject access request we will send you a form to complete so that we know who you are and so that we can locate your information. We will then comply with your request by providing you with the details set out above and with a copy of the information that we hold about you. If you only want to have access to certain information that we hold about you (for example call recordings) then you may request this.

Right to rectification

If we hold any inaccurate information about you please let us know as soon as possible and we will correct it. You may also request that we supplement any incomplete information that we hold about you.

If we rectify or supplement any information that we hold about you then we will let any third parties to who we have provided this information know, unless this is impossible or disproportionate. If you ask us to we will tell you to who we have disclosed this information.

Right to erasure

In certain circumstances you can ask that we erase the information that we hold about you:

  • We no longer need to keep it for the purposes for which it was collected or used
  • Our only basis to process it is your consent and you withdraw that consent
  • You object to our use of the information and we do not have any overriding legitimate grounds to continue using the information
  • We are using the information unlawfully
  • We have to erase it in order to comply with our legal obligations

If you wish to be removed from our system then please let us know and we will delete you, unless we have a legitimate reason why we need to keep your information (for example we are in a dispute with you).

If we erase any information that we hold about you then we will let any third parties to who we have provided this information know, unless this is impossible or disproportionate. If you ask us to we will tell you to who we have disclosed this information.

Right to data portability

Where our processing of your information is based on consent and the processing is carried out by automated means then you have the right to have that information provided to you in a commonly used format, provided that this is technically feasible.

Right to restrict processing

In certain circumstances you can ask that we restrict how we use your information:

  • You have made a request for rectification or to supplement inaccurate information. You can ask that we restrict your processing while we deal with your request
  • The use of the information is unlawful, but you ask that we restrict our use of the information rather than delete it
  • We no longer need to use it but you want us to keep it so that you can use it for a legal claim

In these circumstances we will stop using your information (although we may still store it) unless you consent to our use, we need it for legal claims, we need to use it to protect another person or where there is an important public interest in us doing so.

If we restrict our use of any information that we hold about you then we will let any third parties to who we have provided this information know, unless this is impossible or disproportionate. If you ask us to we will tell you to who we have disclosed this information.

Right to object

You have the right to object to our using your information where we base our use on either it being in the public interest or it being for legitimate interests (see section 4 above). If you do so and we have no other basis to process it we can only continue to process it if we can demonstrate that we have compelling grounds to do so which override your interests, or we need it for legal claims.

12. Complaints

Our use of information is regulated by the Information Commissioner. If you would like to complain about us you can contact the Information Commissioner on 0303 123 1113. More information about your rights to complain can be found at ico.org.uk

13. Data Protection Impact Assessment

Download a copy of our Data Protection Impact Assessment (PDF file)

Date of document: 30th May 2018

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