Effective date: 25 May 2018
1. Introduction
This notice describes how Lloyd’s, as a data controller, collects, uses, shares and retains the personal information you provide and informs you about your choices regarding use, access and correction of your personal information. Lloyd’s is committed to ensuring that any personal information it receives is protected and handled in accordance with applicable data protection laws.
For the purposes of this Privacy Notice, references to “we”, “us” or “our” shall refer to Lloyd’s.
2. Who we are
The Society of Lloyd’s (Lloyd’s) is incorporated by Lloyd’s Acts 1871 to 1982 whose principal place of business is at One Lime Street, EC3M 7HA.
3. What personal information we process about you
The personal information we hold is restricted to your:
• Identity and contact data: title, first name, last name, business email address, employer name, job title, country of residence, telephone number
• Profile data: username, password and user ID
• Usage data: includes information on which systems you use
• Technical data: includes login data
4. Why we collect your personal information and the lawful basis for processing
Lloyd’s System Access: Your personal details will be processed in order to provide you access to the Lloyd’s systems requested. The lawful basis which allows us to process your data is a legitimate interest.
It is in the legitimate interests of Lloyd’s and its market participants that Lloyd’s facilitates a Lloyds.com account which allows access to a number of products and tools. We process your personal information for appropriate administration and maintenance of the Lloyd’s systems.
5. Who we are sharing your data
Your data will not be shared outside of Lloyd’s.
6. How long we keep your data
We will retain your personal information for as long as is reasonably necessary to fulfil the relevant purposes set out in this Privacy Notice. The retention period will primarily be determined by relevant legal and regulatory obligation and/or duration of our business relationship with you, your employer or another associated party. We maintain and update regularly our data retention policy with a detailed retention schedule. We will securely delete or erase your personal information if there is no valid business reason for retaining your data. 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 reasons the data will be needed in the future.
7. Your rights
You have certain rights as an individual which you can exercise in relation to the personal information we hold about you. If you make a request to exercise any of your rights we reserve the right to ask you for a proof of your identity. We aim to acknowledge your request as soon as possible and will address your query within one month.
You have the following rights:
The right to access
You are entitled to a confirmation whether we are processing your data, a copy of your data, and information about purposes of processing, who do we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, where we got your data from and how you can make a complaint.
The right to rectification
If you believe the personal information we hold about you is inaccurate or incomplete you can request for it to be rectified.
The right to erasure
If you withdraw your consent, terminate a contract with us or you believe the personal information is no longer necessary for the purposes for which it was collected, you may request your data to be deleted. However, this will need to be balanced against other factors, for example there may be certain regulatory obligations which mean we cannot comply with your request.
The right to restriction of processing
You can ask us to restrict (i.e. keep but not use) your personal information, but only where:
• Its accuracy is contested, to allow us to verify its accuracy; or
• The processing is unlawful, but you do not want it erased; or
• It is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
• You have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction, where we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
The right to object
You have the right to object at any time to processing of your personal data where (i) we use data about you for marketing, or (ii) if we use the data about you on the basis of legitimate interest for purposes other than direct marketing.
8. Contact details of the Data Protection Officer
If you have any questions relating to data protection that you believe we will be able to answer, please contact our Data Protection Officer:
Data Protection Officer
Lloyd’s
1 Lime Street
EC3M 7HA, London
Email: data.protection@lloyds.com
9. Complaints
If you are not satisfied with our response or believe we are not processing your personal data in accordance with legal requirements you can make a complaint to relevant Supervisory Authority.
Our Lead Authority within the European Union is the UK Information Commissioner’s Office
(https://ico.org.uk/concerns/)
