This Privacy Notice is issued by Hampden Agencies Limited and Nomina PLC (collectively referred to as ‘we’, ‘us’ and ‘our’ in this Privacy Notice).
We are committed to protecting and respecting your privacy and take our responsibilities regarding the security of client data very seriously.
This Privacy Notice explains how we, as a data controller, comply with data protection requirements, and how we use any Personal Data you provide.
- Personal Data
- Why we collect and store your Personal Data
- What Personal Data we collect
- How we use your Personal Data
- Who we share your Personal Data with
- Your rights as a data subject
Under the General Data Protection Regulation (‘GDPR’) Personal Data is defined as “any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, and identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
Why we collect, process and store your Personal Data
The majority of the Personal Data that we collect and process is done for the purpose of entering into a business relationship with you and for the performance of that relationship. We may collect Personal Data both at the outset of a business relationship and also on an ongoing basis in-line with the business timetable. The processing of this data allows us to perform our contractual and/or legal obligations. We may also collect and process Personal Data if you contact us enquiring about any services we offer, whether in person, by telephone or by email, or when you visit our website.
What Personal Data we collect
- Details about the individual, such as name, address, other contact details, gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details their including relationships to you.
- Details that could be used to identify an individual, such as an identification numbers issued by government bodies or agencies including your national insurance number, Unique Taxpayer Reference, passport number, and driving licence number.
- Financial information, such as bank account details, income and source of wealth (including from employment, property, shareholdings, inheritances, gifts and other sources) and other financial information.
- Credit and anti-fraud data, such as credit history, credit score, sanctions, any status as a politically exposed person, criminal offences and information from anti-fraud databases.
- Special categories of Personal Data, such as health information or criminal conviction data. These types of data will only ever be collected and stored where necessary for us to fulfil our legal and contractual obligations.
How we use your Personal Data
We use your Personal Data to allow us to provide the products and services that we offer, namely the facilitation of Membership of Lloyd’s and advice on syndicate participation (HAL), or to provide management and administration of limited liability vehicles underwriting at Lloyd’s (Nomina).
We also use your data to meet the legal requirements to which we are subject, which includes requirements to identify and verify clients and their source of funds and wealth for the prevention of financial crime, audits, and any further requirements of public authorities and regulators (including the Financial Conduct Authority and the Corporation of Lloyd’s).
We may also process your personal data where necessary to pursue our legitimate interests, for example to review and improve our services, contact you with market information or our newsletter, and to analyse market behaviours.
We will keep your Personal Data only for as long as is necessary and for the purpose(s) for which it was collected, following which it will be deleted. The period for which we keep your Personal Data will include any period which may be necessary for the performance of contractual relationships between us or where we are required to keep your Personal Data for legal or regulatory reasons.
Who we share your Personal Data with
We do not disclose your Personal Data to any third parties except as stated in this Privacy Notice, as otherwise permitted by law, or as authorised by you.
We disclose your Personal Data (including information in relation to verification of client identity, source of funds and source of wealth) to the Corporation of Lloyd’s for the purpose of administration and oversight of your underwriting at Lloyd’s. We may also disclose your Personal Data to your Approved Investment Managers and your own accountant(s), as well as public or regulatory authorities (including the Financial Conduct Authority and the Corporation of Lloyd’s) in order for us to perform our contract with you or to comply with any legal or regulatory obligations to which we or you are subject.
We may disclose your Personal Data to Hampden Tax Consultants Ltd or other members of our group of companies where this is reasonably necessary for the provision of services to you or for other purposes set out in this Privacy Notice.
We may disclose your Personal Data to other companies who provide services to us including data management, IT, email delivery, website hosting, identify verification, company secretarial, auditing and other third party services, or in the event of any merger, sale or other transfer of all or part of our business.
Should we transmit Personal Data to recipients outside the European Economic Area (EEA) we will only do so if the EU has confirmed that the country has an appropriate level of data protection or that other appropriate data protection guarantees are in place in compliance with data protection legislation.
Your rights as a Data Subject
You can write to us to obtain further details of the Personal Data we hold about you and the purposes for which we use it.
Our contact details are as follows:
Hampden Agencies Limited
40 Gracechurch Street
+44 (0)20 7863 6643
40 Gracechurch Street
+44 (0)20 7863 6592
You may also have the right to require us to:
- Provide you with a copy of the Personal Data you have provided to us
- Update any inaccuracies in the Personal Data we hold
- Delete any Personal Data that we no longer have a lawful ground to use
- Where processing is based on consent, to withdraw your consent so that we stop that particular processing
- Object to any processing based on our legitimate interests unless our reasons for that processing outweigh any prejudice to your data protection rights
Any requests for additional information or to exercise your rights should be made in writing to the above contact details.
If you are not happy with our use of your Personal Data or our response to any request to exercise any of your rights mentioned above, you have the right to complain to the Information Commissioner’s Office (ICO).
The contact details of the ICO are:
Information Commissioner's Office
0303 123 1113
This Privacy Notice was last updated on 05 July 2019.