In accordance with the UK General Data Protection Regulation (GDPR), this Privacy Notice is intended to provide you with transparent information regarding our Data Protection Policy and how we process your personal data. In doing so, it will explain:
We are Trinity Place Legal Services Ltd trading as Trinity Place Legal Services and our office address is Trinity Place, 14 Sovereign Way, Tonbridge TN9 1RS. If you have any questions regarding this Privacy Notice, you can write to our Data Protection Officer at this address, or email dpo@trinityclaims.co.uk. We are a data controller of your personal data. We are registered with the Information Commissioner’s Office (ICO) and our registration number is ZB327491. You can check our registration details on their website which is www.ico.org.uk. Privacy Policy last updated 15/06/2022.
Your personal data consists of many different things where one or more of these can identify you. It may also include personal information which is regarded as more sensitive and is described as ‘Special Category Data’ under the GDPR. This can include information about your ethnic origin, politics, religion, genetics, biometrics, health or sexuality. We will only process Special Category Data where it is required for processing an insurance claim. For the purposes of this Privacy Notice, we also use the term ‘information’ to mean ‘personal data’.
Our Data Protection Policy and related procedures have been designed to comply with the GDPR. We may change this privacy notice from time to time in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website.
In accordance with Articles 6,13 and 14 of the General Data Protection Regulation (GDPR), we confirm that our lawful basis for processing your personal data is because:-
1. it is necessary in relation to a claim administered by us on an insurance policy that you hold, or to meet the legal obligations relating to an insurance claim administered by us.
2. It is in our legitimate interests to do so, such as:
3. To comply with our legal obligations
We collect your personal data in order that
A. we can manage an insurance claim on behalf of the Underwriter
B. we can process applications for jobs within the Company
C. we can maintain staff records
GDPR gives you various rights in relation to the processing of your personal data, as follows:
RIGHT TO BE INFORMED - You have the right to receive clear and transparent information regarding why we require your personal data and what we are
RIGHT OF ACCESS - Your personal data includes information which can directly or indirectly identify you, and you are legally entitled to access that information should you wish to do so. This access is called a Data Subject Access Request (DSAR).
RIGHT TO RECTIFICATION - You are entitled to have your personal data rectified if it is inaccurate or incomplete.
RIGHT TO ERASURE - In certain circumstances, you have the right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing.
RIGHT TO RESTRICT PROCESSING - You have the right to block or suppress the processing of your personal data where you contest its accuracy.
RIGHT TO DATA PORTABILITY - In certain circumstances, you are entitled to obtain and reuse your personal data for your own purposes across different services, and this right allows you to move, copy or transfer your personal data easily from one IT environment to another in a safe and secure way without hindrance to your usability.
RIGHT TO OBJECT - You also have the right to object to the processing of your personal data.
RIGHTS IN RELATION TO AUTOMATED DECISION MAKING & PROFILING - we use an automated decision making or profiling process, we will be required to give you information about the processing. You will also have the right to request human intervention or challenge a decision.
If you want to exercise any of these rights, please write to our Data Protection Officer.
We will only collect relevant and sufficient data from you as required in accordance with our lawful basis for processing. Personal information that we’ll process in connection with all of our products and services, if relevant, includes:
Your personal data will include your personal details, financial details and other information including your personal circumstances, financial needs, priorities and objectives. You should inform us of any changes to your personal information which you consider to be relevant to the services we are providing to you.
We will collect your personal data from a variety of sources including:
We collect this information because we need:
Failure to provide relevant information about yourself may impair our ability to provide our services to you, and may lead to your claim being declined
Your personal data may be shared with third parties, including:
We process your personal information so that we can provide our services to you and to meet our contractual, legal and regulatory obligations. The privacy of your personal information is very important to us, and our Data Protection Policy and procedures have been developed to ensure this is always maintained.
This will depend upon the nature of the services which we provide to you, and as required to meet contractual, legal and regulatory requirements. If you have entered made a claim with us, your information will be retained in line with the legal or regulatory requirement to keep it, which protects you and us. This will normally be for a period of 25 years, but may be longer for certain types of insurance claims.
All Trinity Claims field staff are provided with body worn cameras. The purpose of the camera is to provide security to our policyholders and employees. In addition, the footage will be utilised to understand the validity/content of insurance claims. Note that the footage may also be used as evidence, should we have suspicions of fraudulent activity.
During Trinity CLaims' communications with you, you would have been asked to confirm that you are happy for our visits to your home/premises to be recorded via the use of body worn cameras.
The cameras are fitted with front facing screens so you will be able to fully acknowledge when recording is live. Likewise, an evident red light will demonstrate that there is recording is process.
None of the field staff have access to the recorded footage whilst it is stored on the device. All footage is encrypted and can only be accessed by a small number of senior staff within the business. All cameras are PIN protected and can only be used by specifically trained members of staff.
All the cameras are also fitted with live stream emergency features and GPS functionality meaning that, should the staff feel threatened in any way, live footage can be viewed from our base locations and where necessary emergency services will be called.
All recordings will be retained in line with our Privacy Policy.
Please note that Trinity Claims also deploy surveyors, contractors and other third parties which are not directly employed by us. Should they wish to utilise body cameras within the course of their investigations and/or works, please refer directly to their privacy policies.
Protecting the privacy of your personal data is very important to us. However, if you are concerned in any way or wish to make a complaint regarding how we process it, then you should write to our Data Protection Officer. If you are still not satisfied with his response, you can raise your concerns with the Information Commissioner’s Office (ICO), who are our Supervisory Authority in relation to Data Protection. Details of how to contact our Data Protection Officer or the ICO are set out earlier within this Privacy Policy. This does not affect your rights for your complaint to be handled by the Legal Ombudsman. Details of the Legal Ombudsman Complaints handling procedures can be provided on request.