Privacy policy

Baptist Insurance is a specialist insurer of church, residential property owners, commercial and household risks and offers its products to Baptist churches and connected organisations, charities, other voluntary groups and individuals and their families.

Providing insurance services means that we need to collect and process data so that we can provide you with a quote, insurance and where relevant, handle any claims or complaints that might arise. This makes us a “data controller".

If you are unsure about who the data controller of your personal information is, you can contact us at any time by e-mailing compliance@baptist-ins.com or by writing to the Data Protection Officer, Baptist Insurance, Benefact House, 2000 Pioneer Avenue, Gloucester Business Park, Brockworth, Gloucester, GL3 4AW.

Insurance involves the use and disclosure of your personal data by various insurance market participants such as intermediaries, insurers and reinsurers. The London Insurance Market Core Uses Information Notice sets out those core necessary personal data uses and disclosures. Our core uses and disclosures are consistent with the London Market Core Uses Information Notice. We recommend you review this notice.

Depending on our relationship with you (for example if you are a policyholder, individual named on a policy, investor, claimant, witness, a third party pursued for a recovery, broker or third party) we will collect different types of personal information about you and use it for different purposes.

From time to time we may ask you to provide or we may receive your “sensitive personal information” otherwise known in data protection laws as "special categories of personal information" (which is information relating to your health, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership). For example, if you apply for home insurance, we may need information about any unspent criminal convictions you have or, if you are a named individual under a Baptist Church insurance policy such as a minister, the religious denomination of the church will automatically reveal your religious beliefs. In these circumstances we would use your sensitive personal information to provide a quote and the insurance policy and to process any claims you make. We may also need details of any unspent criminal convictions you have for fraud prevention purposes. If you are a third party against whom we are seeking a recovery as part of our right to subrogation, we may have details of your criminal convictions where it relates to a claim under a Baptist Insurance policy.

Where you provide personal information to us about other individuals (for example members of your church, or your household) we will also be data controller of and responsible for their personal information. You should refer them to this notice.

We have structured this notice so that you only have to visit the section below that is relevant to you and reflects your relationship with us.

3.1 Prospective policyholder or beneficiary under an insurance policy

If you apply for an insurance policy with us (for example a home insurance policy), or someone applies for a policy which will cover you or list you as a named beneficiary (for example a minister covered under the legal expenses section of a church insurance policy) this section will be applicable to you and will provide key information about how we use your personal information.

3.1.1 What personal information will we collect?

• Your name and title, address, telephone numbers and email addresses, date of birth and gender.

• Where you are not the person applying for insurance, your relationship or connection to the prospective policyholder.

• Identity information if necessary, including marriage certificate, change of name documentation and executorship details.

• Employment status and related information such as job title, employment history and education.

• Information which is related to your insurance application including:

  • details about previous insurance policies you have held and any previous claims you have made;

  • details about your family such as dependents or spouses; and

  • policy specific information. For example, if you are applying for home insurance, we will need information about your property and possessions.

• Financial information including:

  • your bank account and payment details;

  • details about your income; and

  • information obtained from checking sanctions lists and credit checks such as bankruptcy orders, individual voluntary arrangements, office disqualifications or county court judgments.

• Information which is available publicly such as via internet search engines.

3.1.2 What sensitive personal information will we collect?

• Information about your physical and mental health if relevant to your insurance application (for example where you apply for a policy and advise us of particular needs relating to a disability).

• Information about any criminal offences you have been convicted for and any related information including about any offences or alleged offences you have committed or any court sentences which you are subject to.

• We may also collect information because it is relevant to your application, which reveals or is likely to reveal your race or ethnicity, religious or philosophical beliefs; political opinions; trade union membership; or data concerning your sex life or sexual orientation. For example, where you disclose that you are a minister at a Baptist Church, this will automatically reveal your religious beliefs.

3.1.3 How will we collect your personal information?

Directly from you:

• when you apply for a policy;

• when we provide you with a quotation; and

• during any communications we have, such as by telephone or email or when you make a general enquiry.

We will also collect your personal information from:

• The prospective policyholder where you are a beneficiary.

• Third parties who we rely on to administer insurance such as brokers, insurers and our own business partners.

• Third parties who provide sanctions checking services.

• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Public sources such as court judgments, insolvency registers and internet search engines.

3.1.4 What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a "legal ground" to do so. When using your "personal information", we will rely on the "legal grounds” set out below:

• We need to use your personal information to enter into or perform the insurance contract that you have applied for. We will rely on this legal ground for all activities that are connected to your application and without using your personal information we would be unable to do, such as assessing your application against our own risk appetite and providing you with a quote.

• We have a legal or regulatory obligation to use your personal information. We have a legal obligation to carry out anti-money laundering checks. Our regulators require us to maintain records of all dealings with you and to comply with our regulatory reporting requirements we may need to send your personal information to our regulators.

• We have a business need to use your personal information. Such needs will include keeping business and accounting records, maintaining management information, statistical analysis, developing and testing our systems, analysing our business and improving the services we offer, carrying out strategic reviews of our business models and will cover all activities which are needed to carry out everyday business activities. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

When we use your “sensitive personal information" (such as information about your health, religion or criminal offences), we need to have an additional “legal ground". When using your "sensitive personal information", we will rely on the "legal grounds” set out below:

• We have an insurance purpose to use your sensitive personal information and there is a substantial public interest such as assessing your insurance application, arranging or administering a policy and preventing and detecting fraud.

• You have clearly made your sensitive personal information public. For example, where you are a minister of a Baptist church and you have made your religious beliefs common knowledge.

• We need to use your sensitive personal information to establish, exercise or defend legal rights. This will be applicable where we are involved in legal proceedings, either against us or where we want to instigate them ourselves.

• You have given your consent.

3.1.5 What are the legal grounds on which we will use your personal information?

3.1.6 Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• The policyholder where you are a beneficiary.

• Third parties who we rely on to administer your application such as brokers, insurers and our own business partners.

• Third parties who provide sanctions checking services.

• Insurance industry bodies.

• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers (including the Insurance Fraud Register “IFR” managed by the Insurance Fraud Bureau) and third parties we use to carry out credit checks.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Service providers we have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, marketing mailing providers and business suppliers.

• Any third parties in the event of a sale, merger, re-organisation, transfer or dissolution of our business.

• The Financial Conduct Authority and the Prudential Regulation Authority who are our regulators.

• Law enforcement agencies such as the police, HMRC and taxation authorities.

• Our own insurers and companies who we have appointed to assist with arranging our insurance.

3.2 Policyholder or beneficiary under an insurance policy

If you have an insurance policy with us (for example a home insurance policy), if the policy covers you or if you are a named individual under an insurance policy with us (for example a minister under a church legal expenses insurance policy) this section will be applicable to you and will provide key information about how we use your personal information.

3.2.1 What personal information will we collect?

• Your name and title, address, telephone numbers and email addresses, date of birth and gender.

• Where you are not the policyholder, your relationship or connection to the policyholder.

• Identity information if necessary, including marriage certificate, change of name documentation and executorship details.

• Employment status and related information such as job title, employment history and education.

• Information which is related to your insurance policy including:

  • details about previous insurance policies you have held and any previous claims you have made;

  • details about your family such as dependents or spouses; and

  • policy specific information. For example, if you have home insurance, we will need information about your property and possessions.

• Financial information including:

  • your bank account and payment details;

  • details about your income; and

  • information obtained from checking sanctions lists and credit checks such as bankruptcy orders, individual voluntary arrangements, office disqualifications or county court judgments.

• Information which is relevant to any claims you make under your policy. This could include photographic evidence you provide us with, for example if you make a claim under your home contents insurance policy, we will need information about damaged items.

• Information which is available publicly such as internet search engines and social media where we need to investigate fraudulent claims.

3.2.2 What sensitive personal information will we collect?

• Information about your physical and mental health if relevant to your insurance policy or any claims you make (for example where you apply for a policy and advise us of particular needs relating to a disability).

• Information about any criminal offences you have been convicted of and any related information including about any offences or alleged offences you have committed or any court sentences which you are subject to.

• We may also collect information because it is relevant to your policy or claim, which reveals or is likely to reveal your race or ethnicity, religious or philosophical beliefs; political opinions; trade union membership; or data concerning your sex life or sexual orientation. For example, where we process information about you because you are a minister at a Baptist Church, this will automatically reveal your religious beliefs.

3.2.3 How will we collect your personal information?

When you are the policyholder, directly from you:

• when we provide you with a quote;

• when you apply for or renew a policy;

• when you make a claim on your policy; and

• during any communications we have, such as by telephone or email or when you make a complaint or general enquiry.

We will also collect your personal information from:

• The policyholder where you are a beneficiary.

• A third party who has power of attorney over you.

• Third parties who we rely on to administer insurance and handle claims such as brokers, insurers, third party claimants, defendants, witnesses and our own business partners.

• Third parties we (or you) appoint to assist with an insurance policy or claim such as claims handlers, medical experts, investigators and loss adjusters.

• Third parties who provide sanctions checking services.

• Insurance industry bodies.

• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Public sources such as court judgments, insolvency registers, internet search engines and social media where we need to investigate fraudulent claims.

• The Financial Conduct Authority and the Prudential Regulation Authority who are our regulators.

3.2.4 What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a "legal ground" to do so. When using your "personal information", we will rely on the "legal grounds” set out below:

• We need to use your personal information to enter into or perform the insurance contract that you have taken out with us. We will rely on this legal ground for all activities that are connected to your insurance contract and without using your personal information we would be unable to do, such as providing you with a quote, providing insurance cover, handling claims and responding to complaints.

• We have a legal or regulatory obligation to use your personal information. We have a legal obligation to carry out anti-money laundering checks. Our regulators require us to maintain records of all dealings with you and to comply with our regulatory reporting requirements we may need to send your personal information to our regulators.

• We have a business need to use your personal information. Such needs will include keeping business and accounting records, maintaining management information, statistical analysis, developing and testing our systems, analysing our business and improving the services we offer, carrying out strategic reviews of our business models and will cover all activities which are needed to carry out everyday business activities. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

When we use your “sensitive personal information" (such as information about your health, religion or criminal offences), we need to have an additional “legal ground". When using your "sensitive personal information", we will rely on the "legal grounds” set out below:

• We have an insurance purpose to use your sensitive personal information and there is a substantial public interest such as assessing your insurance application in particular against our own risk appetite, arranging or administering a policy, handling claims and preventing and detecting fraud.

• You have clearly made your sensitive personal information public. For example, where you are a minister of a Baptist church and you have made your religious beliefs common knowledge.

• We need to use your sensitive personal information to establish, exercise or defend legal rights. This will be applicable where we are involved in legal proceedings, either against us or where we want to instigate them ourselves or when we are investigating a legal claim that a third party brings against you.

• You have given your consent.

3.2.5 What are the legal grounds on which we will use your personal information?

3.2.6 Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• The policyholder where you are a beneficiary.

• A third party who has power of attorney over you.

• Third parties who we rely on to provide insurance and handle claims such as brokers, insurers, third party claimants, defendants, witnesses and our own business partners.

• Third parties we (or you) appoint to assist with an insurance policy or claim such as claims handlers, medical experts, surveyors, investigators and loss adjusters.

• Third parties who provide sanctions checking services.

• Insurance industry bodies.

• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers (including the Claims Underwriting Exchange "CUE" and the Insurance Fraud Register “IFR” managed by the Insurance Fraud Bureau) and third parties we use to carry out credit checks.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Service providers we have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, marketing mailing providers and business suppliers.

• Any third parties in the event of a sale, merger, re-organisation, transfer or dissolution of our business.

• The Financial Conduct Authority and the Prudential Regulation Authority who are our regulators.

• Law enforcement agencies such as the police, HMRC and taxation authorities.

• Our own insurers and companies who we have appointed to assist with arranging our insurance.

3.3 Third party claimant

If you make a claim against a third party who has an insurance policy with us, this section will be applicable to you and will provide key information about how we use your personal information.

3.3.1 What personal information will we collect?

• Your name and title, address, telephone numbers and email addresses, date of birth and gender.

• Identity information such as national insurance number.

• Any information which is related to your claim which could include:
  

  • your job title and employment status, employment history, salary and education if relevant;

  • details about the incident; and

  • photographic evidence.

• Information which is available publicly such as via internet search engines and social media where we need to investigate potentially fraudulent claims.

3.3.2 What sensitive personal information will we collect?

• Information about your physical and mental health if relevant to the claim you are making and in particular any information contained in a medical report.

• Information about any criminal offences you have been convicted of and any related information including about any offences or alleged offences you have committed or any court sentences which you are subject to.

• We may also collect information because it is relevant to your claim, which reveals or is likely to reveal your; race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, or data concerning your sex life or sexual orientation. For example, where we seek to validate or investigate a claim, we may receive files containing any of the above information. We may also need to collect this information to assess the value of your claim.

3.3.3 How will we collect your personal information?

Directly from you when you contact us to make a claim.

We will also collect your personal information from:

• The policyholder.

• Third parties who we rely on to provide insurance and handle claims such as brokers, insurers, third party claimants, defendants, witnesses and our own business partners.

• Third parties we appoint to assist with a claim such as claims handlers, medical experts we have commissioned to produce a medical report and medical screening service providers, investigators and loss adjusters.

• Third parties involved in the claim process such as lawyers or the Crown Prosecution Service.

• Third parties who provide sanctions checking services.

• Insurance industry bodies.

• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Public sources such as court judgments, insolvency registers, internet search engines, social media.

• The Financial Conduct Authority and the Prudential Regulation Authority who are our regulators.

3.3.4 What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a "legal ground" to do so. When using your "personal information", we will rely on the "legal grounds” set out below:

• We have a legal or regulatory obligation to use your personal information. We have a legal obligation to carry out anti-money laundering checks. Our regulators require us to maintain records of all dealings with you and to comply with our regulatory reporting requirements we may need to send your personal information to our regulators. We are also required to provide information to the Compensation Recovery Unit (CRU) for the purposes of fulfilling our statutory obligation to notify the CRU prior to claim settlement.

• We have a business need to use your personal information. Such needs will include investigating claims, exercising our right of subrogation, keeping business and accounting records, maintaining management information, statistical analysis, developing and testing our systems, analysing our business and improving the services we offer, carrying out strategic reviews of our business models and will cover all activities which are needed to carry out everyday business activities. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

When we use your “sensitive personal information" (such as information about your health, religion or criminal offences), we need to have an additional “legal ground". When using your "sensitive personal information", we will rely on the "legal grounds” set out below:

• We have an insurance purpose to use your sensitive personal information and there is substantial public interest such as handling claims and preventing and detecting fraud.

• We need to use your sensitive personal information to establish, exercise or defend legal rights. This will be applicable where we are involved in legal proceedings, either against us or where we want to instigate them ourselves or when we are investigating the claim that you have brought against an individual who holds a policy with us or when we are exercising our right of subrogation.

• You have given your consent.

3.3.5 What are the legal grounds on which we will use your personal information?

3.3.6 Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• The policyholder.

• Other insurers that are involved in your claim.

• Third parties who we rely on to provide insurance and handle claims such as brokers, insurers, third party claimants, defendants, witnesses and our own business partners.

• Third parties we appoint to assist with a claim such as claims handlers, medical experts and medical screening service providers, surveyors, investigators and loss adjusters.

• The third party against whom we are seeking recovery as part of the subrogation process and his or her legal representative.

• The Compensation Recovery Unit.

• Third parties who provide sanctions checking services.

• Insurance industry bodies.

• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers (including the Claims Underwriting Exchange "CUE" and the Insurance Fraud Register “IFR” managed by the Insurance Fraud Bureau) and third parties we use to carry out credit checks.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Our solicitors.

• Service providers we have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, marketing mailing providers and business suppliers.

• Any third parties in the event of a sale, merger, re-organisation, transfer or dissolution of our business.

• The Financial Conduct Authority and the Prudential Regulation Authority who are our regulators.

• Law enforcement agencies such as the police, HMRC and taxation authorities.

• Our own insurers.

3.4 Third party pursued for a recovery

If you are a third party from whom we are seeking recovery when we exercise our right of subrogation, this section will be applicable to you and will provide key information about how we use your personal information. We may exercise this right where we have paid a claim under an insurance policy but we believe that your act or failure to act caused the loss or injury.

3.4.1 What personal information will we collect?

• Your name and title, address, telephone numbers and email address, date of birth and gender;

• Any information which is related to the relevant claim which could include:

  • your job title and employment status, employment history and salary and education if relevant;

  • details about the incident and your actions; and

  • photographic evidence.

• Information which is available publically such as via internet search engines and social media.

3.4.2 What sensitive personal information will we collect?

• Information about your physical and mental health if relevant to the claim.

• Information about any criminal offences you have been convicted of and any related information including about any offences or alleged offences you have committed or any court sentences which you are subject to.

• We may also collect information because it is relevant to the claim made under a Baptist policy, which reveals or is likely to reveal; your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, or data concerning your sex life or sexual orientation.

3.4.3 How will we collect your personal information?

We will collect your personal information from:

• The policyholder.

• Third parties who we rely on to provide insurance and handle claims such as brokers, insurers, third party claimants, witnesses and our own business partners.

• Third parties we appoint to assist with a claim such as claims handlers, investigators and loss adjusters.

• Third parties involved in the claim process such as lawyers or the Crown Prosecution Service.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Public sources such as court judgments, internet search engines and social media.

3.4.4 What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a "legal ground" to do so. When using your "personal information", we will rely on the "legal grounds” set out below:

• We have a legal or regulatory obligation to use your personal information. We have a legal obligation to carry out anti-money laundering checks. Our regulators require us to maintain records of all dealings with you and to comply with our regulatory reporting requirements we may need to send your personal information to our regulators. We are also required to provide information to the Compensation Recovery Unit (CRU) for the purposes of fulfilling our statutory obligation to notify the CRU prior to claim settlement.

• We have a business need to use your personal information. Such needs will include investigating claims, exercising our right of subrogation, keeping business and accounting records, maintaining management information, statistical analysis, developing and testing our systems, analysing our business and improving the services we offer, carrying out strategic reviews of our business models and will cover all activities which are needed to carry out everyday business activities. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

When we use your “sensitive personal information" (such as information about your health, religion or criminal offences), we need to have an additional “legal ground". When using your "sensitive personal information", we will rely on the "legal grounds” set out below:

• We have an insurance purpose to use your sensitive personal information and there is a substantial public interest such as handling claims.

• We need to use your sensitive personal information to establish, exercise or defend legal rights. This will be applicable where we are involved in legal proceedings, either against us or where we want to instigate them ourselves, such as when we are exercising our right of subrogation.

3.4.5 What are the legal grounds on which we will use your personal information?

3.4.6 Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• The policyholder.

• Other insurers that are involved in your claim.

• Third parties who we rely on to provide insurance and handle claims such as brokers, insurers, witnesses and our own business partners.

• Third parties we appoint to assist with a claim such as claims handlers, investigators and loss adjusters.

• Other third parties who we engage with when exercising our right of subrogation which include the third claimant and their legal adviser or legal representative.

• Your legal adviser or legal representative.

• The Compensation Recovery Unit.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Our solicitors.

• Service providers we have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers and business suppliers.

• Any third parties in the event of a sale, merger, re-organisation, transfer or dissolution of our business.

• The Financial Conduct Authority and the Prudential Regulation Authority who are our regulators.

• Law enforcement agencies such as the police, HMRC and taxation authorities.

• The courts.

• Our own insurers and companies who we have appointed to assist with arranging our insurance.

3.5 Witness to an incident

If you have witnessed an incident which has now become the subject of a claim, this section will be applicable to you and will provide key information about how we use your personal information.

3.5.1 What personal information will we collect?

• Your name and title, address, telephone numbers and email addresses, date of birth and gender.

• Your employment status and related information such as job title, employment history and education.

• Identity documents such as passport, driving licence and national insurance number.

• Information which is available publicly such as via internet search engines and social media where we need to investigate potentially fraudulent claims.

• Any information which is related to the incident you witnessed.

3.5.2 What sensitive personal information will we collect?

• Information about your physical and mental health, if you suffered an injury as a result of the incident you witnessed or where you disclose information to us for example referring to a disability you have.

• Information about any criminal offences you have been convicted of and any related information including about any offences or alleged offences you have committed or any court sentences which you are subject to.

3.5.3 How will we collect your personal information?

Directly from you when we contact you to discuss the incident you witnessed.

We will also collect your personal information from:

• Those people involved in the incident such as the policyholder, the claimant and other witnesses.

• Other third parties involved in the incident from an insurance administration perspective such as brokers, insurers, claims handlers, loss adjusters and business partners.

• Third parties we have appointed to assist us in relation to the incident you witnessed, such as medical experts and investigators.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Public sources such as court judgments, insolvency registers, internet search engines, social media.

3.5.4 What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a "legal ground" to do so. When using your "personal information", we will rely on the "legal grounds” set out below:

• We have a legal or regulatory obligation to use your personal information. We have legal obligations to carry out anti-money laundering checks, and our regulators require us to maintain records of all dealings with you. To comply with our regulatory reporting requirements, we may need to send your personal information to our regulators.

• We have a business need to use your personal information. Such needs will include investigating claims, exercising our right of subrogation, keeping business and accounting records, maintaining management information, statistical analysis, developing and testing our systems, analysing our business and improving the services we offer, carrying out strategic reviews of our business models and will cover all activities which are needed to carry out everyday business activities. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need. When we use your “sensitive personal information" (such as information about your health, religion or criminal offences), we need to have an additional “legal ground". When using your "sensitive personal information", we will rely on the "legal grounds” set out below:

  • We have an insurance purpose to use your sensitive personal information and there is a substantial public interest such as handling claims and preventing and detecting fraud.

  • We need to use your sensitive personal information to establish, exercise or defend legal rights. This will be applicable where we are involved in legal proceedings, either against us or where we want to instigate them ourselves or when we are investigating the claim that has been brought against an individual who holds a policy with us.

  • You have given your consent.

3.5.5 What are the legal grounds on which we will use your personal information?

3.5.6 Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• The policyholder.

• Third parties involved in the incident and their legal and medical representatives.

• Other insurers that are involved in the claim.

• Other third parties involved in the incident from an insurance administration perspective such as brokers, insurers, claims handlers, loss adjusters and business partners.

• Third parties we have appointed to assist us in relation to the incident you witnessed with such as medical experts and investigators.

• Third parties who provide sanctions checking services.

• The third party against whom we are seeking recovery as part of the subrogation process and his or her legal representative.

• The third-party claimant whose loss or injury you witnessed.

• Insurance industry bodies.

• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers (including the Claims Underwriting Exchange "CUE" and the Insurance Fraud Register “IFR” managed by the Insurance Fraud Bureau) and third parties we use to carry out credit checks.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Our solicitors.

• Service providers we have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, business suppliers.

• Any third parties in the event of a sale, merger, re-organisation, transfer or dissolution of our business.

• The Financial Conduct Authority and the Prudential Regulation Authority who are our regulators.

• Law enforcement agencies such as the police, HMRC and taxation authorities.

• Our own insurers and companies who we have appointed to assist with arranging our insurance.

3.6 Brokers, appointed representatives and other business partners

If you are a broker, appointed representative or another type of business partner such as a supplier or subcontractor that we do business with, this section will be applicable to you and will provide key information about how we use your personal information.

3.6.1 What personal information will we collect?

• Your name and title, address, telephone numbers and email addresses, date of birth and gender.

• Employment status and related information such as job title, employment history and education.

• Bank and payment details.

• Financial information obtained from checking sanctions lists and credit checks such as bankruptcy orders, individual voluntary arrangements, office disqualifications or county court judgments.

• Information which is available publicly such as via internet search engines and LinkedIn.

3.6.2 What sensitive personal information will we collect?

• Information about any criminal offences you have been convicted of and any related information including about any offences or alleged offences you have committed or any court sentences which you are subject to.

3.6.3 How will we collect your information?

Directly from you and your employer.

We will also collect your personal information from:

• Third parties who provide sanctions checking services.

• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Public sources such as court judgments, insolvency registers, internet search engines, social media.

3.6.4 What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a "legal ground" to do so. When using your "personal information", we will rely on the "legal grounds” set out below:

• We need to use your personal information to enter into a services contract with you.

• We have a legal or regulatory obligation to use your personal information. For example, we have obligations to carry out due diligence checks on parties we engage with.

• We have a business need to use your personal information. Such needs will include keeping business and accounting records, maintaining management information, statistical analysis, developing and testing our systems, analysing our business and improving the services we offer, carrying out strategic reviews of our business models and will cover all activities which are needed to carry out everyday business activities. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

When we use your “sensitive personal information" (such as information about your health, religion or criminal offences), we need to have an additional “legal ground". When using your "sensitive personal information", we will rely on the "legal grounds” set out below:

• There is a substantial public interest such as preventing and detecting fraud.

• We need to use your sensitive personal information to establish, exercise or defend legal rights. This will be applicable where we are involved in legal proceedings, either against us or where we want to instigate them ourselves or when we are investigating a legal claim that a third party brings against you.

• You have given your explicit consent.

3.6.5 What are the legal grounds on which we will use your personal information?

3.6.6 Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• Third parties including the policyholder and claimant.

• Third parties who we engage with when administering a policy or claim such as claims handlers, medical experts, surveyors, investigators and loss adjusters.

• Insurers and brokers.

• Third parties who provide sanctions checking services.

• Insurance industry bodies.

• Financial crime and fraud detection agencies and other third parties who operate and maintain fraud detection registers and third parties we use to carry out credit checks.

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Service providers we have contracted with including our subcontractors and agents, auditors, our solicitors, actuaries, IT providers and database providers, marketing mailing providers and business suppliers.

• Any third parties in the event of a sale, merger, re-organisation, transfer or dissolution of our business.

• The Financial Conduct Authority and the Prudential Regulation Authority who are our regulators.

• Law enforcement agencies such as the police, HMRC and taxation authorities.

• Our own insurers and companies who we have appointed to assist with arranging our insurance.

3.7 Users of the Baptist Insurance website

If you use or access the Baptist Insurance website, this section will be applicable to you and will provide key information about how we use your personal information.

3.7.1 What personal information will we collect?

• Name, contact details, postcode and IP address.

• Information obtained through our use of cookies. Find more information about this in our cookies policy

3.7.2 How will we collect your personal information?

We collect your information directly from our website and where you have submitted any information on our website.

3.7.3 What will we use your personal information for?

We use your information in a number of different ways, depending on your particular circumstances. For every use, we must be able to demonstrate that there is a "legal ground" to do so. When using your "personal information", we will rely on the "legal grounds” set out below:

• We have a business need to use your personal information, such as developing and testing our systems, analysing our business and improving the services we offer, diagnosing any problems with our website and assessing usage of our website. When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your information unless we can demonstrate a legitimate business need.

3.7.5 Who will we share your personal information with?

We do not share or distribute your personal information other than to the following third parties and only under the limited circumstances we have set out above:

• Ecclesiastical Insurance Office plc (EIO) (which provides administration services for us).

• Service providers we have contracted with relating to the website such as our subcontractors and agents and website providers.

3.8 Applications for Grants including bursaries

3.8.1 What personal information will we collect?

• Your name, title, address, telephone number, email address.

• Your image(s) – See 3.8.4 below.

3.8.2 What sensitive personal information might we collect?

• Information which reveals or is likely to reveal your religious or philosophical beliefs.

3.8.3 How will we collect your personal information?

Information is collected through an applicant’s direct input into the application form.

3.8.4 What will we use your personal information for?

Your personal information will be used for the assessment and awarding of any grant or bursary. We may, subject to your consent or embedded terms and conditions, use your image for promotional activities relating to a successful grant application.

When we use your “sensitive personal information" (such as information about your religion), we need to have an additional “legal ground". When using your "sensitive personal information", we will rely on the condition you have made this information public.

3.8.5 What are the legal grounds on which we will use your personal information?

We may use your personal information to provide you with information about our products and services, or other content that may be relevant or of interest to you. When we refer to “marketing” we mean using your personal information to understand what updates, services or information may be relevant to you and contacting you in line with your marketing preferences. We aim to keep marketing communications relevant and proportionate, and limited to information that is likely to be useful or appropriate to you.

This may include, for example, risk guidance articles (such as Environment & Weather, Fire Safety and Building Works), newsletters, product and service updates, or invitations to events or webinars. We may send these communications where you are a prospective, existing or former client or policyholder, depending on your marketing preferences and our lawful basis for contacting you.

We use information we hold about you, such as your preferences and interactions with us, to help decide what marketing information may be relevant to you. This is sometimes called profiling for marketing purposes.

If you no longer wish to receive marketing communications from us, you can unsubscribe at any time using the link in our emails or by contacting us using the details set out in section 10. If you opt out, you may no longer receive marketing information about our products or services or general updates.

Marketing communications are sent on behalf of Baptist Insurance. Under the Joint Administrative Agreement (JAA), Ecclesiastical Insurance Office plc ("EIO") provides certain operational and administrative services, which include supporting marketing communications. EIO and any other service providers will only process personal information in accordance with our instructions and for the purposes set out in this Notice.

If you opt out of marketing communications, we may still send you service‑related communications where necessary, such as important information about your policy, renewal or changes to the service we provide. This may include guidance, tools or resources designed to support the safe, effective and sustainable operation of insured premises.

We rely on our legitimate business interests when sending marketing communications, or your consent where this is required by law.

4.1 Targeted Advertising

We may use selected advertising channels such as online communities (for example, LinkedIn) to display advertisements that are personalised based on things like interests, characteristics or demographics.

We may use limited personal information, such as your email address, to create audience groups on advertising platforms such as LinkedIn to help us promote Baptist Insurance products and services to people who may be interested in them.

These advertising activities are a form of direct marketing.

To use your personal information in these ways, we may transfer your personal information overseas, but only where your personal information is appropriately protected, as is our legal obligation (as set out in section 7 of this notice).

If you have an existing relationship with us, we may use your personal information to help us display our adverts to prospective customers who may share similar interests, characteristics or demographics as you. We may share limited personal information about you (such as your email address) with LinkedIn who will use that information, in a secure and limited way, to identify others who have similar attributes. This is sometimes known as a “lookalike audience”. LinkedIn will then use that lookalike audience to help direct our adverts to prospective customers who are likely to be interested in them.

If you do not have an existing relationship with us and you have been identified by LinkedIn as someone who may be interested in our advertisements (for example, via a “lookalike” feature as set out above), you may be presented with one of our targeted adverts. We will not be able to identify you unless you choose to interact with our advert by sharing it, commenting on it or reacting to it. Where you do not interact with our advert, any other information which relates to the advert and whether it was displayed to you will be provided to us only in an aggregated form so we will not be able to directly or indirectly identify you as a recipient of the advert.

When conducting the advertising activities above, we rely on our legitimate business needs (to advertise our services). You have the right to object to direct marketing at any time, including this type of targeted advertising. You can object to any processing which we carry out on this basis by contacting us using the details set out in section 10.

Where we have your consent, we may use advertising cookies as part of our advertising campaigns (see our cookies policy).

We make some decisions automatically by inputting your personal information into our systems and the decision is reached using certain processes and algorithms, rather than our employees making the decisions themselves. This is called 'automated decision making' (ADM) and we will use this on certain insurance products at the underwriting stage.

We use your personal information (for example, address and property details and details of your charitable or commercial activities) to determine your eligibility for particular cover under an insurance policy and your insurance premium. This takes into account whether the risk presented fits our risk appetite, and if so, allows us to calculate the price to be charged.

You have the right to contest any ADM conducted on you, including obtaining human intervention. You should refer to the contact details in Section 10 of this notice to do this.

We also use artificial intelligence (AI) and machine learning (ML) technologies. AI focuses on creating systems that can perform tasks typically requiring human intelligence, such as learning, reasoning, problem-solving, perception, and language understanding. ML is a type of AI that teaches machines to learn and interpret from information and then provide a response. One type of AI that we use is natural language processing which involves reading, understanding and analysing speech and text.

The models, algorithms, and tools we use do a number of things including:

• understanding our customers and potential customers better, for example, how they feel about Baptist Insurance, whether they might be displaying characteristics meaning that they may require additional support from us;
• managing underwriting and claims, for example, underwriting assessments, determining liability, valuing claims;
• monitoring and improving our processes and services, for example, by generating summaries of claims notes, looking how to prevent complaints;
• predicting the likelihood of events arising to assess insurance risk, the likelihood a product will be purchased or to predict if a claim might be fraudulent; and
• ensuring data quality and accuracy, for example, checking the way our models, algorithms, and machine learning tools work.

We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out in section 3 above and to comply with our legal and regulatory obligations.

For example, we keep property claim files for at least 6 years, and where long-term liability claims may arise, we keep policy information for at least 80 years.

If you would like further information about how long we will keep your personal information for, please contact us using the details set out in section 10.

There may be some instances where your personal information is transferred to countries outside of the UK such as when we transfer information to third party suppliers who are based outside the UK or when third parties who act on our behalf transfer your personal information to countries outside the UK.

Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including:

• we will only transfer personal data to countries deemed to provide an adequate level of protection for personal information. You can find out more about this here.

• in the event a country is not deemed adequate we will enter into data transfer contracts using specific contractual provisions that have been approved for use in the UK which give personal data the same protection as it has in the UK. For further details see here

We are also entitled under UK data protection laws to transfer your personal information to countries outside the UK in the following circumstances:

• it is necessary for the performance of the contract we have with you; and/or

• it is necessary to protect your vital interests i.e. it is a life-or-death situation.

Depending on our relationship and your particular circumstances, we might transfer personal information anywhere in the world. A summary of our regular data transfers outside the UK and the EEA is set out below:

If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in section 10.

We implement and maintain appropriate technical and organisational measures to ensure ongoing confidentiality, integrity, availability and resilience of processing systems and services. These include but are not limited to the following key activities:

• We adopt a framework of information security controls operating at different levels within the company to restrict access and safeguard systems, in accordance with a ‘defence in depth’ methodology (which is the coordinated use of multiple security controls to protect the integrity of the information and assets in the company’s IT network);
• We have an established, documented information security and data protection policy framework which is regularly reviewed to consider changes in technology, regulations and threats;
• We maintain encryption technologies to encrypt data stored on portable computers and portable media, and ensure security when data is transferred;
• We maintain awareness and education on information security and data protection in all areas of our business;
• We conduct risk based due diligence on our suppliers;
• We operate a programme of testing the effectiveness of our information security measures.

You have several data protection rights which entitle you to request information about your personal information, to dictate what we do with it or to stop us using it in certain ways.

If you wish to exercise the rights set out below, please contact us at any time using the details set out in section 10.

There will not normally be a charge for this.

We respect your rights in relation to personal information we hold about you, however we cannot always comply with your requests, for example:

• we may not be able to delete your information if we are required by law to keep it for a longer period of time; or

• we may not be able to provide a copy of your personal information if it is subject to legal professional privilege (or in Scotland confidentiality of communications), or consists of the records of our intentions in relation to any negotiations with you if disclosure would be likely to prejudice those negotiations; or

• we may not be able to delete your information if we would not have the necessary information we need to provide insurance cover or pay out on a claim.

However, we will always inform you why we cannot comply with your request.

In some circumstances, complying with your request may result in your insurance policy being cancelled or your claim being discontinued.

The right to access your personal information

You can request a copy of the personal information we hold about you and certain details of how we use it.

Your personal information will normally be provided to you in writing unless you request otherwise or where you have made a request by electronic means such as email, we will provide such information in electronic form where possible.

The right to withdraw your consent

Where we rely on consent as the legal ground to use your personal information, you are entitled to withdraw that original consent.

Please note that for certain uses of your personal information, we need your consent in order to provide your policy. If you exercise this right and withdraw your consent, we may need to cancel your policy or we may not be able to pay your claim. We will inform you of these consequences when you withdraw your consent.

The right to rectification

We make reasonable efforts to keep your personal information where necessary up to date, complete and accurate. We encourage you to ensure that your personal information is accurate so please regularly let us know if you believe that the information we hold about you may be inaccurate or not complete. We will correct and amend any such personal information and notify any third-party recipients of necessary changes.

The right to restriction of processing

Subject to the circumstances in which you exercise this right, you can request that we stop using your personal information, such as where you believe that we no longer need to use your personal information.

The right to data portability

Subject to the circumstances in which you exercise this right, you can request that we port across personal information you have provided to us to a third party in a commonly used and machine-readable format.

The right to erasure

You can request that we delete your personal information. For example, where we no longer need your personal information for the original purpose we collected it for or where you have exercised your right to withdraw consent. Whilst we will assess every request, this request is subject to legal and regulatory requirements that we are required to comply with.

The right to object to direct marketing

You can request that we stop sending you marketing messages at any time by clicking on the "unsubscribe" button in any such emails that we send to you or by contacting us using the details set out in section 10.

Please note that even if you exercise this right because you do not want to receive marketing messages, we may still send you service-related communications where necessary.

The right to object to processing

Where our processing is based on the legal ground of us having a legitimate business need to process your personal information, you can object to such processing. If you raise an objection, we will consider your request and balance this against any other compelling legitimate grounds in favour of the processing and inform you of our decision.

Rights relating to automated decision-making

If you have been subject to an automated decision and do not agree with the outcome, you can contact us using the details set out in section 10 and ask us to review the decision.

Right to complain about your processing

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) relating to the processing of your personal data. Where possible we would like to resolve any complaint directly with you through our internal complaint handling process. If you would like to lodge a complaint with us, please contact us via the email address in Section 10 below.

Alternatively, you can raise a complaint directly with the Information Commissioner's Office (ICO) directly via this link. You should note that exercising this right and lodging a complaint will not affect any other legal rights or remedies that you have.

If you would like further information about the ways we use your personal information, further clarity on how we use your personal information or anything referred to in this notice, please contact our Data Protection Officer at compliance@baptist-ins.com or by writing to the Data Protection Officer, Baptist Insurance, Benefact House, 2000 Pioneer Avenue, Gloucester Business Park, Brockworth, Gloucester, GL3 4AW.

We are continually improving our methods of communication and alongside changes in the law and the changing nature of technology, our data practices and how we use your data will change from time to time. If and when our data practices change and you are a customer of Baptist Insurance, we will notify you and we will provide you with the most up-to-date notice. We will also update it on this website.