PRIVACY POLICY

Introduction

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. We are committed to protecting and respecting your privacy. We take your privacy seriously and will only use your personal information as set out in this privacy notice.

The legal basis for processing your personal data will be to meet our contractual obligations in providing and / or offering you an insurance policy and administering that policy. Under the GDPR this is known as processing your data for the performance of a contract or in contemplation of a contract (i.e. the insurance policy).

Who are we?

First Title Insurance plc (First Title) is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. First Title is registered in England under company number 01112603. Registered office:
ECA Court, 24-26 South Park, Sevenoaks, Kent, TN13 1DU.

In what capacity will First Title hold information about you?

In providing insurance services, we will act as a data controller, in full compliance with the GDPR requirements.
In most cases, your personal data will be provided to us, on your behalf, by a legal advisor or insurance broker.
This data will usually be input to our websites (www.firsttitle.co.uk, www.firsttitleresidential.co.uk and https://secure.first-title.co.uk) or provided to us by telephone or email.

What happens if you cannot provide us with personal information?

Please note, if you are unable to provide us with all the necessary information, we may be unable to offer you an insurance policy or administer any existing policy.

What are your rights relating to the use of your data?

Under data protection law, you have certain rights around the processing of your data, which depend on the legal basis for collecting your data and the uses made of your data. For all uses made of your data, you have the right to be informed about how we use your data and this notice discharges that obligation. However, further rights apply in different circumstances, set out below:

• Right of access – You have a right to request a copy of the information we hold about you.

• Right of rectification – You have a right to correct data that we hold about you that is inaccurate or incomplete.

• Right to be forgotten – In certain circumstances you can ask for the data held about you to be erased from our records. Please note our retention period set out below.

• Right of portability – You have the right to have the information we hold about you transferred to another organisation.

• Right to restriction of processing – Where certain conditions apply you have a right to restrict the processing. Please note this may mean we cannot continue with your case.

• Right to object – You have the right to object to certain types of process such as direct marketing and automated processing. Please note, we will not use your data for this purpose unless you have previously consented to such use.

What information will First Title hold about you?

Personal information about you to enable us to offer or provide you with an insurance policy and to administer that policy (including fraud prevention and financial crime checks as well as claims handling), such as:
• title and full name
• current and new home addresses
• email address
• telephone or other contact number
• post code
• IP address
• bank details

First Title will under no circumstances ask for any sensitive personal data from you.

How will First Title use information held about you?

First Title will use the information provided for:
• processing a request for an insurance policy
• internal record keeping
• claims handling
• for fraud prevention; we may share the information with fraud prevention agencies
• undertaking financial crime checks

If you give us information regarding another person, you are confirming they have given you permission to provide their information to us to be able to process their personal data and also that you have told them about First Title.
In some cases, we may be required to disclose information held to Government bodies or our Regulators, but First Title is committed to only doing so under proper authority.

How long will First Title retain your information?

In most cases, the policies we offer provide insurance coverage in perpetuity. We are therefore required to retain the information indefinitely, in order to continue administering those policies.

Will your data be transferred to third countries?

On occasions we may transfer your personal information to third countries for case administration or reinsurance purposes. We will not release the information to non-affiliated parties. Where we make such a transfer, we will take the required steps to ensure your information is protected. Such steps will include placing the party we are transferring personal information to under contractual obligations to protect it to adequate standards.

How do we use Cookies?

A cookie is a small file of letters and numbers that is downloaded onto your computer when you visit a website. You can use your web browser to control cookies. These cookies are used to secure sessions and improve access to our websites.

Further information

In the event you wish to make a complaint about how your personal data is being processed by First Title you have the right to complain to the Data Protection Officer, by email: compliance@firsttitle.co.uk or in writing to Compliance team, First Title Insurance plc, ECA Court, 24-26 South Park, Sevenoaks, Kent, TN13 1DU.

You also have the right to complain to the Information Commissioner’s Office who would normally expect we have been given the opportunity to respond to your complaint within 30 days.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF