Markel International - Privacy policy

Our Commitment 

Markel International is committed to protecting information which identifies and relates to you or other individuals (personal information) and complying with data protection laws.

Please read this privacy policy with care. 

This privacy policy sets out Markel International's personal information collection and sharing practices in relation to the personal information that we collect and use for the administration of insurance policies, reinsurance contracts and the provision of advisory services. This privacy policy also covers any personal information collected through your use of any of Markel International's websites.

If you would like to discuss the content of this privacy policy or privacy related issues, please contact the Data Protection Officer at: dataprotectionofficer@markel.com. Further details on how to contact the Data Protection Officer can be found in section 10.

The persons to which this privacy policy applies: Policyholders, clients, suppliers, advisers, service providers, enquirers, candidates for recruitment, beneficiaries or claimants and their agents and relatives (“you”).

You may also be interested in our Cookies Statement page.

 

Links to other websites

This website may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information.

 

Who we are

The Markel International companies to which this privacy policy applies: Markel Capital Holdings Limited | Markel Consultancy Services Ltd | Markel Syndicate Management Ltd | Terra Nova Pension Trustee Ltd | Markel Protection Group Ltd | Markel International Insurance Co Ltd | MIPS Pension Scheme | Markel Law LLP | Galleon Marine Insurance Agency Ltd | JanJer Ltd | Markel Insurance SE |  Markel International Services Ltd | Markel International Limited | Effective Tax Solutions Ltd (Howarth Lynch) | Alterra Capital Services UK Ltd | Alterra at Lloyd's Limited | Markel Underwriting Services Ltd | Schouten Insurance Limited (Markel International, Netherlands) | Le Centaure (Markel International, France) | EC Insurance Company Limited ("Markel International" or "we" or "us").

This list may change from time to time as the Markel International group expands or changes.

In this Privacy Policy, ‘we’ means the relevant Markel International Company where it acts as a data controller of your personal data. Depending on the context there may be instances where we act as processors of your personal data.

Insurance is the pooling and sharing of risk in order to provide protection against a possible eventuality. In order to do this, information, including your personal data, needs to be shared between different insurance market participants. The London Insurance Market Core Uses Information Notice  explains in more detail how the insurance market works and uses personal information to provide insurance cover. Our core uses and disclosures are consistent with the London Market Core Uses Information Notice.

This Privacy Policy is designed to help you understand how we, as insurance market participants, collect and 

Our layered approach

Data protection laws require us to provide you with a lot of information about how we collect and use your personal information – and it is easy for all this information to become confusing rather than helpful.

We use a layered approach to providing you with the information required by law. This means that we may provide the information required in a number of different formats and documents. In particular, it means that in our initial contact with you, we may provide you only with the most important information about how we will use your personal information; but we will always provide you with easy access to all the further information you need about our privacy practices.

As an example, if you buy an insurance policy from us, then we may use a three layer approach:

  • a short privacy notice in your policy-related documentation that refers to this privacy policy
  • access to this privacy policy online
  • access, via this privacy policy, to an Insurance Market Standard Information Notice that explains in more detail how the insurance market works and uses personal information to provide insurance cover in the section ‘How the Insurance Market Works’.

Or, if you engage us to provide you with advisory services, then we may use this three layer approach:

  • a short form privacy notice in your terms of engagement that refers to this privacy policy
  • access to this privacy policy online or by post
  • additional privacy notice terms in your letter of engagement that accompanies the terms of engagement, tailored to the specific advisory services provided and data involved if required.

 

How this privacy policy works

This privacy policy is intended to explain our privacy practices and covers the following areas:

1.         Information we may collect about you

2.         Why we collection information about you

3.         How we may use your personal information

4.         Consent

5.         Sharing your personal information

6.         Marketing

7.         Transmission, storage and security of your personal information

8.         Retention of your personal information

9.         Your rights

10.        Contact us

11.        Changes to our privacy policy

12.        Personal Data and Brexit

 

1. Information we may collect about you 

We may receive personal information about you by any of the following methods:

  • by filling in, uploading or sending in forms to us;
  • contacting us via our website, social media, webchat, phone, email, post or otherwise,
  • through your family members, employer or representative
  • attending our events;
  • contacting us to manage your product or service;
  • contacting us through one of our partner websites;
  • by third parties such as other insurance market participants, credit reference agencies, solicitors, witnesses, experts, employers, organisations whom we insure or reinsure or a third party claimant
  • having information that is available from publically available sources including social media websites; or
  • contacting us for any other reason.

We may collect and process the following personal information about you:

  • information including your name, address, contact details;
  • for insurance products, this includes details relating to a proposal or a claim (which depending on the nature of the claim may include credit history/score, medical reports and reports of criminal convictions or crime) or provided to us in relation to the administration of an insurance policy that we insure or re-insure;
  • for advisory services, this includes details relating to your instructions for us to provide advisory services, the administration and management of those services and of any claim or complaint
  • for recruitment purposes, this includes information you or your recruitment agency supply in relation to your candidacy (e.g. your CV, application form) pre-offer, and references and background checks (administered by a third party) post-offer;
  • if you contact us, we may keep a record of that correspondence, voicemail or details of any conversation we may have with you;
  • details of your visits to our website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access; (on most occasions, our websites anonymise IP addresses)
  • photo and video footage; and
  • details of transactions you carry out through our website, including the quotations obtained for insurance and advisory services and the insurance policies and advisory services; and information that is available from publically available sources including social media websites.

We may collect and processes the following special categories of personal information about you:

  • health and medical data, such as information on disability or dietary requirements;
  • criminal records or fraudulent activities data, in the event that Markel International has conducted or received the results of criminal records background checks in relation to you, this may be provided to us by you or third parties (such as law enforcement, anti-fraud agencies or other insurers);
  • race or ethnicity data such as information contained in your passport or other citizenship and right to work documentation, and information which you have voluntarily provided to us; and
  • sexual orientation data where this has been provided voluntarily to us.

 

2. Why we collect information about you

We may process personal information for certain legitimate or lawful purposes in some or all of the following ways:

  • to correspond with clients, beneficiaries and claimants in order to facilitate the insurance policies or advisory services;
  • to maintain our accounts and records;
  • to defend or make claims;
  • for recruitment purposes
  • for the performance of a contract with you or to take steps to enter into a contract;
  • to comply with a legal obligation;
  • to comply with foreign law, law enforcement, court and regulatory bodies’ requirements;
  • to identify and prevent fraud;
  • to modify, personalise or otherwise improve our services/ communications;
  • to protect your vital interest or the interest of another individual;
  • to gather market intelligence, communicate with and tailor offers to individuals;
  • to support the communication and management of Markel International’s run events;
  • for training and quality purposes;
  • to enhance the security of our network and information systems; and
  • for the performance of a task carried out in the public interest or in the exercise of an official authority.

 

3. How we may use your personal information

We may use your personal information in the following ways:

  • to make decisions on whether to provide insurance or advisory services;
  • to manage your insurance policy or advisory services including underwriting and claims handling
  • to monitor calls and transactions to ensure service quality, compliance with procedures, to combat fraud and ensure compliance with UK/EU and international sanctions;
  • to identify you and to carry out any identity checks as may be required by applicable law and best practice at any given time;
  • to recover any payments due to us and where necessary to enforce such recovery through the engagement of debt collection agencies or taking other legal action;
  • to analyse it in order to understand the service we provide and in order to improve our business;
  • to manage our infrastructure, business operations and comply with internal policies and procedures;
  • to notify you about changes to our service;
  • for marketing services to you by post, email, SMS, telephone and fax;
  • to decide whether to enter into a contract of employment with you;
  • to assess your skills, qualifications and suitability for a role, in relation to recruitment specifically;
  • to carry out background and reference checks, in relation to recruitment specifically;
  • to communicate with you about the recruitment process, in relation to recruitment specifically;
  • to keep records related to our hiring processes in relation to recruitment specifically; and
  • for promotional purposes we may publish photography and recordings on our website and related social media sites

We will never process your data where these interests are overridden by your interests.

 

4. Consent

On rare occasions, your consent to our processing of your personal information or special categories of personal information for certain purposes may be necessary to comply with applicable data protection laws; and where this is the case we will ask you for your consent in accordance with those laws.
Where you have given us your consent, you may withdraw that consent at any time. However, where you withdraw your consent in relation to a processing activity, there may be an impact upon our ability to provide you advisory services, insurance cover or pay claims under the cover.

 

5. Sharing your personal information

Markel International may make personal information available to:

Our group companies

We have group companies throughout the world, both inside and outside Europe (for example, in the USA). We may share your personal data with our group companies, but only for the purposes set out in this privacy policy and we remain responsible for the management and security of personal information. Access to personal information within Markel International, and our group companies, is restricted to those individuals who have a need to access the information for our business.

Other third parties

We may also permit selected third parties and agents including suppliers, service providers, reinsurers and financial organisations access to your personal information for the purposes set out in section 2.

All such exchanges will be made in accordance with applicable laws. If false or inaccurate information is provided and/or fraud is identified or suspected, details may be passed to fraud prevention and anti-money laundering agencies, law enforcement agencies or other insurers and may be recorded by us or by them.

We and other organisations may also access and use this information to prevent fraud and other crime, for example when deciding whether to make a payment to you under an insurance or reinsurance policy. We, and other organisations that may access and use information recorded by fraud prevention agencies, may do so from other countries including outside the EEA.

Governmental authorities and third parties involved in court actions

We may disclose your personal information to third parties, the courts and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or in order to enable Markel International to comply with its regulatory requirements or dialogue with its regulators as applicable.

6. Marketing

Markel International and associated companies will only use your personal data to manage your products or services and to communicate with you about information that may be of interest. However, sometimes we would like to contact you with details of other products or services it provides.

If you have been referred to us through one of our partner’s websites, we will only use your personal information to contact you about our products or services, or those of our partners which may be of interest to you, if our partner has provided us with your consent, indicating that you are happy for us to contact you.

You can object to these messages from us at any time, using one of the methods set out below:

Email: There will always be an unsubscribe link on any marketing email you receive from us. Some of our brands, where relevant, provide a level of granularity to the types of emails you can unsubscribe from.

Post: We will inform you in any postal communication how you can stop receiving direct mail in future.

Telephone: If you receive a marketing call from us, please let the call operator know if you do not want to receive calls again.

Furthermore you can contact us via email at dataprotectionofficer@markel.com, with the subject header "Stop Marketing". Please include your personal details (Name, Company name, address, email and telephone number) so we can make sure that we do not contact you again. Your details will be placed onto a suppression list to ensure that we continue to comply with your objection. Please note that this process will only stop marketing to the individual named in the email and not your company or organisation as a whole. 

If you wish to speak to us directly about marketing communications you are receiving, please use one of the contact details found in section 10.

 

7. Transmission, storage and security of your personal information

Unfortunately, no data transmission over the Internet or any website can be guaranteed to be secure from intrusion.

However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with applicable data protection laws. All information within our control is stored on our secure servers (or secure hard copies) and accessed and used subject to our security policies and standards.

  • Where Markel International discloses your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data.
  • Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or any other portal we operate, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

Your personal information may be accessed by staff or authorised third parties and, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) where the data protection laws may be of a lower standard than in the EEA. Regardless of location or whether the person is an employee or contractor we will impose the same data protection safeguards that we deploy inside the EEA.

 

8. Retention of your personal information

We will retain your personal information for as long as is reasonably necessary for the purposes listed in section 2 of this privacy policy. This may mean that we hold your personal information for some time where, for instance, there is a possibility that it may be needed in connection with a claim under an insurance policy or the advisory services, or where we are obliged to keep it to comply with tax, accounting, regulatory or legal requirements.

 In exceptional circumstances, we may retain your personal information for longer periods of time if we reasonably believe there is a prospect of litigation, in the event of any complaints or there is another valid business reason the data will be needed for a longer period. We maintain a data retention policy which we apply to all data in our care. Where your personal information is no longer required we will ensure it is securely deleted. 

9. Your rights

Data protection laws give you rights in relation to the personal information we hold about you, which may include the right to require us to:

  • provide you with further details on the use we make of your personal information
  • provide you with a copy of the personal information we hold about you
  • update any inaccuracies in the personal information we hold about you
  • delete any of your personal information that we no longer have a lawful ground to use
  • where processing is based on consent, stop that particular processing by withdrawing your consent
  • object to any processing based on our legitimate interests unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights and where it is processed for direct marketing (including profiling relevant to direct marketing) restrict how we use your personal information whilst a complaint is being investigated
  • use human intervention, in certain circumstances where you have been subjected to a decision which is based solely on automated processing
  • transfer your personal information to a third party in a standardised machine-readable format

In certain circumstances, we may need to restrict your rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

9.1. Right to Complain

If you are not satisfied with our use of your personal information or our response to any request by you to exercise your data protection rights, or if you think that we have breached any relevant data protection laws, then you have the right to complain to the data protection supervisory authority. We would, however, appreciate the chance to deal with any of your concerns before you approach the supervisory authorities so please contact us in the first instance.

In the UK, the authority that supervises our processing of your personal information is the ICO (www.ico.org.uk).

If you are unsure of the authority that supervises our processing of your personal information then please contact us for further guidance.

 

10. Contact us

We have a data protection officer who supervises how we use personal information. You can contact our data protection officer about privacy related issues by:

  • sending an email to dataprotectionofficer@markel.com
  • writing to the:
     
    Data Protection Officer,
    Markel International,
    20 Fenchurch Street,
    London, EC3M 3AZ. 

 

11. Changes to our privacy policy

We may change the content of our website or services without notice, and consequently our privacy policy may change at any time in the future. We therefore encourage you to review it from time to time to stay informed of how we are using personal information. 

 

12. Personal Data and Brexit

It is unknown what the course of Brexit will be on whether the UK will leave the EU with or without a deal. The Markel International companies have completed the transfer of the European insurance business, its London insurance company, Markel International Insurance Company Limited (MIICL), to its Munich based insurance company, Markel Insurance SE (MISE), which in the event of a hard Brexit, addresses the transfer of personal data between the UK and EU. However, we would like to assure all data subjects your personal data is and will continue to be held securely whether you are based in the UK or not. For further information please visit http://www.markelinternational.com/intl/Brexit/.

In the interim, if you have any questions about your personal data in relation to Brexit then please feel free to contact our data protection officer. For details please see section 10 above.

 

 

Version Reference: Aug2019v2.0