|
|
Consumer Outcome
|
How we try to Achieve this Outcome
|
|
1.
|
Consumers can be confident that they are dealing with firms where fair treatment of customers is central to the corporate culture.
|
Treating Customers Fairly (henceforth abbreviated to “TCF”) is a cornerstone of our firm and the way in which we do business. This applies from the first communication with our clients through to the way we help them in every aspect of the sales process and beyond.
|
|
2.
|
Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
|
As we are independent brokers, and are not driven to consider products by any particular insurer, we are able to research the market and offer our clients independent advice, thereby ensuring only the most competitive product/s for our clients’ individual set of circumstances are considered.
|
|
3.
|
Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale
|
We regard clear, easy-to-follow information to be crucial in the way in which we deal with our clients, and we do our very best at all times to ensure that our letters and verbal discussions are free of technical or any other jargon that may be confusing. Our clients will be regularly asked if all the information given is clear to them, and are invited to call us as often as they wish should they have any queries on anything we discuss with them or send to them at any point throughout our business relationship.
|
|
4.
|
Where consumers receive advice, the advice is suitable and takes into account their circumstances.
|
We issue an Initial Fact-Finding Questionnaire at our first point of contact if at a meeting - or if by phone discussion, at the first meeting following such phone discussion - during which time our clients are asked for full details of all relevant circumstances that may affect the type of products we will recommend to them. It is vitally important that full disclosure of material information is made at this juncture so that we can obtain an accurate picture of our clients’ circumstances. Effective disclosure is also important in order for us to make sure our clients understand why we are suggesting a particular product or products; that they are buying the correct product for their needs; and that they fully understand exactly what they are buying.
|
|
5.
|
Consumers are provided with products that perform as firms have let them to expect, and the associated service is both of an acceptable standard and as they have been led to expect.
|
We are transparent in our communications with our clients, be they verbal or written, as to precisely what product or service is being provided. We also aim to ensure that our clients understand if any exclusions are going to be applied to their policy. In addition, if there are any special conditions that are unique to any particular insurer, these are fully explained as well. This is important, since the disclosure of such information may affect any claims our clients may wish to make under their respective policies.
|
|
6.
|
Consumers do not face unreasonable post sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.
|
If any policy has any form of penalty, we will ensure our clients know about this before taking out such policy. We are here to assist our clients with the submission of claims, although we do point out that due to doctor-patient confidentiality, we do not help with claims unless specifically requested to do so by our clients. Either at the first meeting, or very early on in the sales process, we issue a document entitled “What happens if you wish to complain?”. This sets out our Complaints procedure. If something does go wrong and we are made aware of client dissatisfaction , we will deal with such complaints in a fair and considerate manner.
|
|
7.
|
Consumer Data in line with the General Data Protection Regulation (GDPR) will be collected and processed on valid grounds ie. Lawful Basis.
|
We identify an appropriate lawful basis (or bases) for our processing.
If we are processing special category data or criminal offence data, we identify a condition for processing this type of data.
For processing of personal data to be lawful, we ensure that we identify specific grounds for the processing. This is called a ‘lawful basis’ for processing, and there are six options which depend on the purpose and the relationship with our consumers:
- A contract with the individual: for example, to supply goods or services they have requested, or to fulfil an obligation under an employee contract.
- Compliance with a legal obligation: when processing data for a particular purpose is a legal requirement.
- Vital interests: for example, when processing data will protect someone’s physical integrity or life (either the data subject’s or someone else’s).
- A public task: for example, to complete official functions or tasks in the public interest. This will typically cover public authorities such as government departments, schools, and other educational institutions; hospitals; and the police.
- Legitimate interests: when a private sector organisation has a genuine and legitimate reason (including commercial benefit) to process personal data without consent, provided it is not outweighed by negative effects to the individual’s rights and freedoms.
- Consent: when the data subject agrees to the processing when presented with a clear explanation of the personal sensitive data that will be collected and what it will be used for.
There are also specific additional conditions for processing some especially sensitive types of data which we duly respect.
|
|
8.
|
Consumer data in line with the General Data Protection Regulation (GDPR) will be used in a manner that is Fair – we will not process data in a way that is unduly detrimental, unexpected, or misleading to the individuals concerned.
|
We consider how the processing may affect our consumers concerned and can justify any adverse impact.
We only handle consumer data in ways they would reasonably be expected, or we can explain why any unexpected processing is justified.
We do not deceive or mislead consumers when we collect their personal data.
We believe Processing of personal data must always be fair as well as lawful.
In general, fairness means that we only handle personal data in ways that our consumers would reasonably expect and not use it in ways that have unjustified adverse effects on them.
In order to assess whether or not we are processing personal data fairly, we consider more generally how it affects the interests of the people concerned – as a group and individually.
We also ensure that we treat consumers fairly when they seek to exercise their rights over their data. This ties in with our obligation to facilitate the exercise of individuals’ rights.
|
|
9.
|
Consumers will be informed in line with the General Data Protection Regulation (GDPR) – how their data will be processed – the principle of Transparency will be adhered to.
|
We are open and honest and comply with the transparency obligations of our consumers right to be informed.
Transparency is fundamentally linked to fairness. Transparent processing is about being clear, open, and honest with consumers from the start about who we are, and how and why we process your personal data.
We believe transparency is always important, but especially in situations where consumers have a choice about whether they wish to enter into a relationship with us. If consumers know at the outset what we will use their information for, they will be able to make an informed decision about whether to enter into a relationship, or perhaps to try to renegotiate the terms of that relationship.
Transparency is important even when we have no direct relationship with the individual and collect their personal data from another source. In some cases, it can be even more important - as individuals may have no idea that we are collecting and using their personal data, and this affects their ability to assert their rights over their data. This is sometimes known as ‘invisible processing’.
We ensure that we inform consumers and individuals about our processing in a way that is easily accessible and easy to understand, with clear and plain language.
|