Introduction
This document relates to personal data, which is defined as any information relating to a living person (Data Subject) that is not in the public domain. General Data Protection Regulation (GDPR) aims to protect and enhance the rights of these data subjects.
These rights cover the protection of personal data and the safeguarding against any unlawful processing of personal data and any unrestricted movement of personal data within the European Union. It is worth noting that for any information already in the public domain, GDPR will not apply.
We, as a company believe that the privacy of both our client’s and the general public is paramount. We hope that this policy will establish an effective and transparent framework for ensuring compliance with the requirements of GDPR.
Personal Data
When we take on a new client, we collect the following information:
- Name
- Address
- Policy number
- Claim number
- Details of the assigned Loss Adjuster
- Details of Broker
All of this information is in putted and stored on our database (Microsoft Access).
Clarin uses the information collected from you to make telephone and email contact relating to a claim. Clarin also acts on behalf of its clients in the capacity of data processor. When working as a data processor, Clarin will be acting on the instruction of its client and will work hard to ensure that the client is fully GDPR compliant.
Clarin does not use cookies for user browsing sessions. The only cookies used on our website are from Google Analytics. These cookies give an approximate geographical location based on method of browsing and IP address (desktop, mobile etc.). This information cannot be used to identify a user and is only used by Clarin to assess the usage and areas of improvement on the website itself.
Any information that Clarin holds about you and your business encompasses all the details we hold about you.
Legal Basis for Processing Any Personal Data
To meet Clarin contractual obligations to clients.
Consent
By agreeing to this privacy notice, you are consenting to Clarin processing your personal data for the purposes outlined above. At any time, you can withdraw consent by emailing hello@clarin.ie, or by writing to us.
Disclosure
Clarin do not pass on information gained from your engagement with our company without your consent. However, Clarin may disclose your personal information to meet legal obligations, regulations or through a valid government request. Clarin may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Clarin, its clients and/or the wider community.
Retention Policy
Clarin will process personal data during the duration of any contract and will continue to store only the personal data needed for six years after the contract has expired to meet any legal obligations. After six years any personal data not needed will be deleted.
Data Storage
Data is held in Ireland and the European Union on multiple servers owned and secured by our I.T. service providers. Clarin does not store personal data outside the EEA.
Your Rights as a Data Subject
Whilst Clarin are in possession of your personal data, all data subjects have the following rights:-
- Right of access – you have the right to request a copy of the information that 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 we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Clarin refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
At your request, Clarin can confirm exactly what information it holds about you and how it is processed. You are able to request the following information:
- Identity and the contact details of the person in Clarin that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Clarin or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (Data Protection Regulator).
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To Access What Personal Data is Held, Identification Will Be Required
Clarin will accept the following identification: a copy of your national ID card, driving licence, passport, birth certificate or a utility bill that is less than three years old. A minimum of one piece of photographic ID listed above and a supporting document is required. If Clarin is not satisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to hello@clarin.ie, or by phoning 091 70 55 44, or by writing to us.
Complaints
If you wish to make a complaint about how your personal data is being processed by Clarin, you have the right to complain to Clarin.
You may complain to the Data Protection Regulator if you do not get a response within 30 days. The details for each of these contacts are:
Clarin , Unit 36, Glenrock Business Park, Ballybane, Galway City. H921 AY28. Telephone: 091 70 55 44, or email: hello@clarin.ie