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Privacy Policy and Cookies Notice

IDS is committed to ensuring that your privacy is protected and respected in accordance with all relevant data protection laws including the Data Protection Act 2018 (DPA2018) and the The EU General Data Protection Regulation (GDPR).

This privacy policy sets out how Insurance Data Solutions (IDS) a division of New City Software Ltd. collects personal data through our interactions with you and through our products and services and how we process and use that data.

Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. We do not sell or trade email lists with other companies and businesses, for marketing purposes.

We are registered with the UK information and Commissioners Office (ICO) as a data processor for the processing of our customer’s data, but we also act as a data controller in relation to information that we gather from job applications and our own staff.

In this privacy policy we have provided detailed information on when and why we collect your personal information, how we use it, the limited conditions under which we may disclose it to others and how we keep it secure.

If we need to change our privacy policy, we will always update this page.  You should check this page from time to time to ensure that you are happy with any changes.

If you have any queries regarding this Privacy Notice, you should first contact our Data Protection Officer via email: enquries@insurancedatasolutions.co.uk. If you do not receive a reply within two working days, please telephone us on UK +44 (0)1245 608253 and request to speak to our Data Protection Officer.

Latest Update 25/07/2020

 

Visitors to This Website

Customers and potential customers may contact us through our website using the forms, buttons and contact details given. When you do this, you will be asked to provide your business contact details such as your email address and telephone number. You will also be asked to consent to our using your information. This information will then be passed either to our marketing or sales teams to contact you to assist you with your enquiry.

Whilst assisting you with your enquiry, we may ask for your consent to use your details for further purposes such as marketing. When we do this, you will be clearly advised and your specific consent will be required before we can use your information for any follow-up purpose.

Job Applicants

On our website you may apply for a position in our organisation –  https://www.insurancedatasolutions.co.uk/about/career-opportunities/

If you decide to do this, then you will be required to submit your personal details including previous employment experience and qualifications. This information is used for the specific purpose of assessing your suitability for a position in our business and you will be required to consent to the use of your personal data for this purpose. If you do not consent to our processing your data for this purpose, then our ability to consider your application may be limited.

Clients of our Customers

As part of the service that we provide (as data processors) to our customers (data controllers) we are required to collect, process or store the personal information of clients of our customers (e.g. policyholders). All this information is processed strictly in accordance with the instructions of our customers and is stored securely on servers located within the EEA.

Sharing Your Information

We will only share your information with parties that you have agreed we can share it with. There are, however, certain scenarios where we may have to share your data with other parties where this is required to comply with applicable laws and government or regulatory bodies’ lawful requests for information. Examples of these scenarios are:

  • For legal reasons, we may be required to share your data with law enforcement agencies, governments, etc. This may be as part of an investigation, or it may be as part of service such as fraud prevention.
  • Where your data may be required to protect against harm to the rights of property or person as permitted by law.
  • Where your data may be required to prevent or protect serious physical harm to an individual.
  • If IDS is involved in an acquisition, a merger, sale of assets, or liquidation.

Security

We are committed to ensuring that your information is secure. to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect:

  • Ensuring that any data that moves across an untrusted network (such as the Internet), will be encrypted using strong methods. though, the transmission of information via the internet cannot be guaranteed. We will do our best to protect your personal data but cannot guarantee the security of your data whilst in transit to our site(s). Any transmission to us is at your own risk. Once we have received your information, we use strict procedures and security features to protect it against unauthorised access as best we can.
  • Ensuring that all our staff or the systems that process your data have sufficient knowledge and training to handle it in a confidential and secure manner.
  • Ensuring that we have appropriate policies and procedures in place which instructs our staff on how to handle your data securely.
  • Ensuring that we minimise access to your information to only the minimal staff and systems that need it to perform the service we are offering you.
  • Any information that we receive from you will be stored depending on the service, but in all cases, it will be within the EEA, and within highly secured data centres with multiple layers of technical and organisational controls.
  • We test our systems for vulnerabilities which allows us to better protect your information.
  • We have very strict contractual and non-disclosure agreements with any third parties we use.

Data Retention

Our internal IDS Data Retention Policy sets a framework around retention to ensure we only hold your data for as long as is necessary for specified purpose.  Our policy states that we retain all communication received electronically including emails for a 7-year period after which time they are automatically deleted.

If you wish to exercise your ‘right to be forgotten or erasure’, we will need to retain some basic information to avoid potentially sending you correspondence at a later date.

International Transfers

All data we collect from you here and subsequently process will be done so in the EEA. If it becomes necessary to process data outside the EEA, we ensure that the relevant third party processing the data gives the required contractual undertakings as specified by the EU, and that we make it clear to you that this will take place.

How we use Coookies and IP Tracking Software

We use IP Address tracking technology "Lead Forensics" (please see Cookies further information below) to identify businesses visiting our site and the products they are interested in. This helps us analyse data about web page traffic to develop and improve our website and generate leads from the company contact details identified (see further information below).

Links to Other Websites 

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control of other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling Your Personal Information

You have the right to ask us for a copy of the personal information we hold on you via a “subject access request”  You also have the right to have any inaccuracies corrected or removed, or to instruct us to cease processing your data if no longer relevant, or if there are no other legal or contractual obligations for us to do so. There is no fee for this.

Please email enquiries@insurancedatasolutions.co.uk 

To respond in a faster time, it would help if you were to identify exactly what data or which particular area you are looking for. For example, all personal data we hold on you about your marketing preferences, or all data you have given us in relation to job opportunities at IDS. 

Your information will be returned within one (1) month. No information will be released, and the clock will not start until your identity has been confirmed. This needs to be photographic evidence and evidence of occupancy. This can either be sent with your request or could follow.

 

Cookies Policy

WHAT ARE COOKIES?

IDS uses cookies to collect information. Cookies are small data files which are placed on your computer or other devices when you browse this website. They are used to ‘remember’ when your computer or device accesses our websites. Some Cookies are essential for the effective operation of our website. They are also used to tailor the products and services offered and marketed to you, both on our websites and elsewhere.

INFORMATION COLLECTED

Our cookies collect information about browsing behaviour when you access this website via the same computer or device. This includes information about pages viewed and your journey in our website. We do not use cookies to collect or record information on your name, address or other contact details if you are not a business. 

WHAT ARE COOKIES USED FOR?

The main purposes for which cookies are used are to enable IDS to collect information about your browsing patterns, including to monitor the success of marketing campaigns plus performance and proper functioning of our website.

HOW DO I DISABLE COOKIES?

You can opt out of being tracked by Google Analytics across all websites, by going to http://tools.google.com/dlpage/gaoptout. Alternatively, some web browsers may have plug-ins that enable analytical cookies to be blocked. 

If you want to disable cookies you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below: -

For Microsoft Internet Explorer:

  1. Choose the menu “tools” then “Internet Options”
  2. Click on the “privacy” tab
  3. Select the setting the appropriate setting

For Google Chrome:

  1. Choose Settings> Advanced
  2. Under "Privacy and security," click “Content settings”.
  3. Click “Cookies”

For Safari:

  1. Choose Preferences > Privacy
  2. Click on “Remove all Website Data”

For Mozilla firefox:

  1. Choose the menu “tools” then “Options”
  2. Click on the icon “privacy”
  3. Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:

  1. Choose the menu Files”> “Preferences”
  2. Privacy

WHAT HAPPENS IF I DISABLE COOKIES?

This depends on which cookies you disable, but in general the website may not operate properly if cookies are switched off. 

IDS use a Third Party called Lead Forensics to track businesses that visit our site.  Please find below their Data Compliance Policy.

Lead Forensics Software Data Compliance Policy

The Lead Forensics Product The Lead Forensics product is a market leading B2B sales and marketing enablement tool. It is SaaS (Software as a Service) and provides businesses with insight relating to their website visitors. Lead Forensics works on the basis of reverse business IP tracking. A small tracking code is placed on a business’ website(s) which then enables them to identify the business IP addresses of their website visitors. Lead Forensics matches the identified business IP address to a wholly owned global database of businesses and business information.

The Lead Forensics software is almost entirely focused on leveraging business related information to effectively match a business IP address with wider business data to provide valuable business related visitor information to our customers. Lead Forensics does not identify any personal IP addresses, mobile devices or any other data than that associated with the business.

Business related data is not applicable under GDPR - which has the intention of protecting personal data. Therefore, the majority of the Lead Forensics solution and its features are not relevant to GDPR.



Contact Data

An additional feature of Lead Forensics aside from the main solution, is to provide customers with the contact information of key decision makers at the organisations that have pro-actively visited the company website. As this information contains details including first name, last name, email address and LinkedIN profile, this aspect of Lead Forensics constitutes the processing of personal data and therefore, is required to be compliant with GDPR.

Lead Forensics will only ever collect business IP addresses, which are then matched to a business profile, from there Lead Forensics offers customers the opportunity to purchase the contact details of relevant decision makers within the matched business. The data available will only relate to decision makers at the organisations that have pro-actively visited a customer’s website, in this regard it is anticipated that this data will be leveraged by the Lead Forensics customer base under the lawful basis for processing of ‘Legitimate Interests’.

It is anticipated that Lead Forensics customers will select the most appropriate point of contact from the data provided by Lead Forensics to convey a highly relevant, targeted message either by email, telephone or by post to the business address and to the point of contact. Any correspondence will be based upon their likely interest in the organisation’s product or service following their visit to the organisation’s website.

Under GDPR, Lead Forensics will only ever process necessary personal data, which is limited to first name, last name, LinkedIN profile URL and email address. Lead Forensics will process further business related data such as business IP, business name, job function and business telephone numbers. No sensitive personal data will be collected or processed in any way.

Lead Forensics customers have the option of using Lead Forensics without leveraging contact data, in which case the Lead Forensics solution is unrelated to GDPR on the basis that it will only process business data. If a customer opts to use the contact data feature of Lead Forensics, it is deemed that this will be leveraged under the lawful basis of ‘Legitimate Interests’, however the customer will be responsible for ensuring the data used is processed within their business in a method that is compliant with GDPR – each customer will be responsible for conducting their own due diligence checks and producing their own policies as applicable to their business.


Six Lawful Basis for Processing Personal Data

Under the EU General Data Protection Regulation (GDPR) there are six lawful basis for processing personal data. These are detailed as follows:

Consent

The individual has given clear consent for you to process their personal data for a specific purpose  Contract The processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract

Legal Obligation

The processing is necessary for you to comply with the law (not including contractual obligations)

Vital Interests

The processing is necessary to protect someone’s life

Public Task

The processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law

Legitimate Interests

The processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

Source: ico.org.uk, February 2018.

The information relating to the six lawful basis for processing personal data is taken from the ICO website and the GDPR regulation documentation. Further information regarding the lawful basis for processing personal data can be found at ico.org.uk

Legitimate Interest Assessment (LIA)

Lead Forensics has carried out a Legitimate Interest Assessment (LIA) as advised by the ICO. Based upon that assessment it is deemed that the rights and freedoms of the data subjects would not be overridden in our processing of the personal data and that in no way would a data subject be caused harm by the Lead Forensics processing. Based upon our segmentation by organisation and by specific job function, coupled with our processing of personal data within the context of a business environment, it is deemed that any processing of data will be limited to business matters, and therefore any risk of personal compromise is extremely unlikely. It is also deemed that direct marketing and sales is necessary in the context of following up with website visitors in order to better serve visitors and to generate business sales.

Per the ICO guidance, Lead Forensics can confirm:

  • We have checked that legitimate interests is the most appropriate basis 
  • We understand our responsibility to protect the individual’s interests
  • We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision
  • We have identified the relevant legitimate interests
  • We have checked that the processing is necessary and there is no less intrusive way to achieve the same result
  • We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests
  • We only use individuals’ data in ways they would reasonably expect
  • We are not using people’s data in ways they would find intrusive or which could cause them harm
  • We do not process the data of children 
  • We have considered safeguards to reduce the impact where possible
  • We will always ensure there is an opt-out / ability to object
  • Our LIA did not identify a significant privacy impact, and therefore we do not require a DPIA
  • We keep our LIA under review every six months, and will repeat it if circumstances change
  • We include information about our legitimate interests in our privacy notice

    How we Procure Data At Lead Forensics we procure data in a variety of ways, collected in line with the lawful basis of ‘Legitimate Interests’. The following are ways in which we collect and process data:

    Business Data

Although business data is not relevant under GDPR, Lead Forensics is committed to providing a transparent solution so that customers can effectively assess their own compliance. Lead Forensics collects business data via the following methods:

  • Primary research – Lead Forensics has a UK based in-house team who gather data relating to business from publicly available information, using search engines and other online tools to research global businesses.
  • Secondary research – Lead Forensics has a UK based in-house team who use existing publicly available sources of data such as Companies House and the WebCheck service to enhance the business data. 
  • Purchase – Lead Forensics purchases business information from a number of selected third party data vendors who are vetted to ensure the quality and validity of the business data provided.

    Personal Data

Lead Forensics collection and processing of personal data is limited to:

  • First name
  • Last name
  • Email address 
  • LinkedIN profile URL

Lead Forensics procures this personal data in the following ways:

  • Primary research - Lead Forensics has a UK based in-house team who gather data relating to key decision makers at organisations from publicly available sources including the website of each business.
  • Secondary research – Lead Forensics has a UK based in-house team who use existing publicly available sources to gather the information relating to key decision makers including the Directors’ Register at Companies House, Dun & Bradstreet, Duedil and LinkedIN.
  • Purchase – Lead Forensics purchases data from selected third party data vendors with key segmentation criteria to ensure that only decision makers from registered businesses are procured. All third party data vendors have been checked for GDPR compliance and to ensure the validity and accuracy of data.

Lead Forensics also uses automated scripts and algorithms to collect, process and validate both business data as well as the personal data detailed above. These automated processes are subject to the same compliance checks as all manual processes.

How we Ensure Data Validity and Currency

Lead Forensics has a UK based in-house data verification team who are responsible for ensuring the validity and currency of the data contained within the Lead Forensics solution. The team continually cleanse the data held within the Lead Forensics software, completing a full cleanse cycle of both business and personal data at least once every 12 months. Any records found to be out of date are placed into a deletion queue which is securely purged four times in a 12 month period. 

The data verification team use both manual methods as well as automated scripts and algorithms via an extensive multi-staged process to ensure the utmost validity and currency of data. Lead Forensics takes data cleansing extremely seriously as this ensures a highly compliant solution as well as a high calibre solution for all of the Lead Forensics customers.

Data Storage and Retention

The data held within the Lead Forensics solution is processed and stored in the UK within a secure environment.

Lead Forensics has a continual cycle of cleansing and refreshing data, all data within the Lead Forensics solution is verified at least once in a 12 month cycle. Any invalid records are placed into a deletion queue, which is then securely purged four times in a 12 month period.

Request to Object

Any individual who has been identified as a website visitor by Lead Forensics has the right to object to receiving correspondence from a Lead Forensics customer by contacting them directly and requesting to object, you can find their specific processes for this by visiting their company website and reviewing their privacy policies.

Should you wish to withdraw from Lead Forensics processing your personal data for use by the Lead Forensics software, please make your request in writing:

By emailing: data-compliance@leadforensics.com

Or by writing to: Data Compliance, Lead Forensics, Building 3000, Lakeside, North Harbour, Portsmouth, PO6 3EN.

All requests will be processed within 30 days. Your details will be added to a suppression file to ensure that your details cannot be processed by the Lead Forensics software in future. Please note that this applies only to the processing of your personally identifiable data, not that of the business data which does not fall under the remit of GDPR.

Request for Deletion

It is important to understand the difference between a right to object and a request for deletion. If you request deletion, we will remove any data we hold about you from the Lead Forensics software. This will also mean that we will remove you from our suppression files. If you are removed from our suppression files, there is a risk that your data may be processed again in the future if your details are re-added to our software by our data procurement team. If you do not wish for Lead Forensics to process your personal data in the future, we would recommend you request to object rather than a request for deletion, as this will ensure that your details are always suppressed from processing.
The option however is yours, and in either case we will process your request within 30 days.
Please make your request in writing by emailing: data-compliance@leadforensics.com
Or by writing to: Data Compliance, Lead Forensics, Building 3000, Lakeside, North Harbour, Portsmouth, PO6 3EN.

Request for Data Held

You may request that we send you all of the data we hold that relates to you. Please make your request in writing;

By emailing: data-compliance@leadforensics.com

Or by writing to: Data Compliance, Lead Forensics, Building 3000, Lakeside, North Harbour, Portsmouth, PO6 3EN.

We will process and respond to your request within 30 days, this service will be free of charge.
This policy was last reviewed and updated on the 7th February 2018. Policies are periodically reviewed to ensure compliance with the current compliance environment.
For questions relating to this policy, please contact data-compliance@leadforensics.com

Google Analytics

We use Google Analytics, to collect standard internet log information and details of visitor behaviour patterns.  We do this to track the total number of visitors to different parts of our website.  This information is only processed in a way which does not identify anyone.  We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

Insurance Data Solutions

Moulsham Mill, Parkway,
Chelmsford, Essex, CM2 7PX
United Kingdom

Telephone: +44 (0)1245 608253