Apollo Syndicate Management Limited (“Apollo”) is a Lloyd’s Managing Agency. Our managed syndicates underwrite insurance and reinsurance business in the Lloyd’s building in London.

 

The underwriting process will frequently involve the collection and processing of assureds’ Personal Data. Apollo uses Personal Data primarily in order to evaluate risk, monitor exposures and to manage claims. Further information about how we use your personal data can be found in section 2 below.

 

The London insurance market is a complex network of insurers, brokers, reinsurers and professional services firms. Your data will often be shared by market participants through the market lifecycle in order for appropriate insurance coverage to be secured and for claims to be managed and settled. Further information about who we share your personal data with can be found in section 5 below.

 

The contact details of our Head of Compliance are shown below. Please contact the Head of Compliance should you have any queries about how we handle your personal data, or wish to exercise any of your rights, as detailed in section 9 below.

 

2. WHY WE COLLECT AND PROCESS YOUR PERSONAL DATA

The purposes that Apollo might use your personal data for are listed below:

 

Quotation/Inception:

  • Setting you up as a client, including possible fraud, sanctions, credit and anti-money laundering checks
  • Evaluating the risks to be covered and matching to appropriate policy/ premium
  • Payment of premium where the insured/policyholder is an individual

 

Policy administration:

  • Client care, including communicating with you and sending you updates
  • Payments to and from individuals

 

Claims Processing:

  • Managing insurance and reinsurance claims
  • Defending or prosecuting legal claims
  • Investigation or prosecuting fraud

 

Renewals:

  • Contacting the insured/policyholder to renew the insurance policy
  • Evaluating the risks to be covered and matching to appropriate policy/premium
  • Payment of premium where the insured/policyholder is an individual

 

Other purposes outside of the insurance lifecycle but necessary for the provision of insurance throughout the insurance lifecycle period:

  • Complying with our legal or regulatory obligations
  • Risk and exposure modelling and monitoring
  • Transferring books of business, company sales & reorganisations

 

The lawful basis that we normally rely on for the collection and processing of personal data is that it is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.

 

Occasionally we may rely on your consent as the lawful basis for processing special categories of personal data, such as medical and criminal convictions records. For this to apply, we must obtain your clear consent for us to process your personal data for a specific purpose.

 

You may withdraw your consent to such processing at any time. However, if you withdraw your consent this may impact our ability to provide insurance or pay claims.

 

The full list of the legal grounds that we might rely on for the purpose of processing Personal Data under the General Data Protection Regulation (GDPR) is shown below:

 

FOR PROCESSING PERSONAL DATA

Legal Ground

Detail

Performance of our contract with you

Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

Compliance with a legal obligation

Processing is necessary for compliance with a legal obligation to which we are subject.

Protection of vital interests of you or another person

Processing is necessary in order to protect the vital interests of you or of another natural person.

In the public interest

Processing is necessary for the performance of a task carried out in the public interest.

For processing special categories of personal data

Your explicit consent (optional)

You have given your explicit consent to the processing of those personal data for one or more specified purposes.

You are free to withdraw your consent, by contacting our Head of Compliance.

Your explicit consent (necessary)

You have given your explicit consent to the processing of those personal data for one or more specified purposes, where we are unable to procure, provide or administer insurance cover without this consent.

You are free to withdraw your consent by contacting our Head of Compliance. However withdrawal of this consent will impact our ability to provide insurance or pay claims.

For legal claims

Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

In the substantial public interest

Processing is necessary for reasons of substantial public interest, on the basis of EU or UK law.

For health services

Processing is necessary for the purposes of preventive or occupational medicine, for medical diagnosis, the provision of health or social care or treatment on the basis of EU or UK law or pursuant to contract with a health professional who is under legal or professional obligations of secrecy

3. THE TYPES OF PERSONAL DATA THAT WE COLLECT

In order for us to provide insurance quotes, insurance policies, and/or deal with any claims or complaints, we need to collect and process personal data about you. The types of personal data that are processed may include:

Types of Personal Data

Details

Individual details

Name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to you

Identification details

Identification numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving licence number

Financial information

Bank account or payment card details, income or other financial information

Risk details

Information about you which we need to collect in order to assess the risk to be insured and provide a quote. This may include data relating to your health, criminal convictions, or other special categories of personal data. For certain types of policy, this could also include telematics data.

Policy information

Information about the quotes you receive and policies you take out

Credit and anti-fraud data

Credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to you

Previous and current claims

Information about previous and current claims, (including other unrelated insurances),which may include data relating to your health, criminal convictions, or other special categories of personal data and in some cases, surveillance reports

Special categories of personal data

Certain categories of personal data which have additional protection under the GDPR. The categories are health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation

4. HOW WE OBTAIN YOUR PERSONAL DATA

We collect your personal data from various sources, which may include:

  • You;
  • Your family members, employer or representative;
  • Other insurance market participants;
  • Credit reference agencies;
  • Anti-fraud databases, sanctions lists, court judgements and other databases;
  • Government agencies such as the DVLA and HMRC;
  • Open electoral register; or
  • In the event of a claim, third parties including the other party to the claim (claimant / defendant), witnesses, experts (including medical experts), loss adjustors, solicitors, and claims handlers

 

Which of the above sources apply will depend on your particular circumstances

 

5. WHO WE SHARE YOUR PERSONAL DATA WITH

The parties with whom we may share your Personal Data, and the reasons for sharing it, are listed in the table below:

Affiliates of Apollo

Reinsurance brokers

Reinsurers

Co-insurers

Exposure modelling companies

London market data management companies

Auditors and actuaries

Credit reference agencies

Anti-fraud databases

Banks

Solicitors / attorneys

Loss adjusters

Experts

Third parties involved in a claims

Private investigators

Police / law enforcement agencies

Courts

PRA, FCA and other regulators

Internal administration

Risk sharing

Risk sharing

Risk sharing

Exposure management

Policy administration

Regulatory

To obtain credit reports of counterparties

To check bona fides of counterparties

Premium collection

Claims management

Claims management

Claims management

Claims management

Claims management

Claims management

Company sales / reorganisations

Regulatory

6. DETAILS OF TRANSFERS TO THIRD COUNTRY AND SAFEGUARDS

We may need to transfer your data to insurance market participants or their affiliates or sub-contractors which are located outside of the European Economic Area (EEA). Those transfers would always be made in compliance with the GDPR.

 

If you would like further details of how your personal data would be protected if transferred outside the EEA, please contact Apollo’s Head of Compliance.

7. HOW LONG WE KEEP YOUR PERSONAL DATA FOR

8. PROFILING AND AUTOMATED DECISION MAKING

When calculating insurance premiums Apollo may compare your personal data against industry averages. Your personal data may also be used to create the industry averages going forwards. This is known as profiling and is used to ensure premiums reflect risk.

 

Profiling may also be used by Apollo to assess information you provide to understand fraud patterns.

 

Where special categories of personal data are relevant, such as medical history for life insurance or past motoring convictions for motor insurance, your special categories of personal data may also be used for profiling.

 

Apollo does not currently make decisions based on profiling and without staff intervention (known as automatic decision making). Should automatic decision making be adopted by Apollo in the future, our Privacy Policy will be updated to reflect:

 

  • Where we use such automated decision making
  • The logic involved
  • The consequences of the automated decision making
  • Any facility for you to have the logic explained to you and to submit further information so the decision may be reconsidered.

We will keep your personal data only for so long as is necessary and for the purpose for which it was originally collected. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim under this insurance, or where we are required to keep your personal data due to legal or regulatory reasons.

9. YOUR RIGHTS

If you have any questions in relation to our use of your personal data, you should contact Apollo’s Head of Compliance. Under certain conditions, you may have the right to require us to:

 

  • Provide you with further details on the use we make of your personal data/special category of data;
  • Provide you with a copy of the personal data that you have provided to us;
  • Update any inaccuracies in the personal data we hold;
  • Delete any special category of data/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 the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
  • Restrict how we use your personal data whilst a complaint is being  investigated. In certain circumstances, we may need to restrict the above 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).

If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights, or if you think that we have breached the GDPR, then you have the right to complain to the ICO. Please see below for contact details of the ICO.

10. YOUR RIGHT TO COMPLAIN TO THE INFORMATION COMMISSIONER’S OFFICE (ICO)

England

Information Commissioner's Office

Wycliffe House, Water Lane

Wilmslow, Cheshire

SK9 5AF

Tel: +44 (0)303 123 1113 (local rate)

or +44 (0)1625 545 745 (national rate)

E-mail: casework@ico.org.uk

 

 

 

Wales

Information Commissioner's Office

2nd floor Churchill House

Churchill Way, Cardiff

CF10 2HH

Tel:+44 (0)29 2067 8400

E-mail: wales@ico.org.uk

Scotland

Information Commissioner's Office

45 Melville Street

Edinburgh

EH3 7HL

Tel: +44 (0)131 244 9001

E-mail: scotland@ico.org.uk 

 

 

 

 

Northern Ireland

Information Commissioner's  Office

3rd Floor

14 Cromac Place

Belfast

BT7 2JB

Tel: +44 (0)303 123 1114 (local rate) or +44 (0)28 9027 8757 (national rate)

E-mail: ni@ico.org.uk

APOLLO SYNDICATE MANAGEMENT LIMITED – PRIVACY NOTICE

1. WHO WE ARE

Andrew Gray

Apollo Syndicate Management Ltd

1 Bishopsgate, London, EC2N 3AQ

 +44 (0)20 3169 1970

andrew.gray@apollounderwriting.com

Head of Compliance:

Address:

 

Tel:

Email:

Who the personal data is shared with

Reason for sharing your personal data

For our legitimate business interests

Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where you are a child. These legitimate interests are set out next to each purpose.

Protection of vital interests of you or another person, where you are unable to consent

Processing is necessary to protect the vital interests of you or of another natural person where you are physically or legally incapable of giving consent.

Further information about how Personal Data is collected and shared in the London Insurance Market (including a glossary of kety insurance terms) can be found in the insurance Market Core Uses Information Notice viewable here

Further information about how Personal Data is collected and shared in the London Insurance Market (including a glossary of key insurance terms) can be found in the insurance Market Core Uses Information Notice viewable here

COMPLAINTS

PROCEDURE

MODERN SLAVERY ACT STATEMENT

BOARD DIVERSITY

POLICY

 

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