HMCA Privacy Notice

Scope
All data subjects whose personal data is collected, personal data processing is in accordance with the requirements of the GDPR.

Responsibilities
The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to HMCA/s PLC (HMCA) collecting and processing their personal data.

PRIVACY NOTICE

1) Who are we?

HMCA/S PLC, trading as the Hospital & Medical Care Association (HMCA), registered office: Beech Hall, Knaresborough, Yorkshire, HG5 0EA. HMCA is an intermediary and is authorised and regulated by the Financial Conduct Authority. HMCA acts as an intermediary for various products with the insurance being provided by a panel of Underwriters each of which is authorised and regulated in their own right within the relevant authority.

HMCA’s Data Protection Officer can be contacted directly here:
Andrew Baker
Telephone +44 (0) 1423 866985
dpo@hmca.co.uk

2) Personal data

HMCA would like to collect from you and that of other names you provide, information to give you quotations, and manage your policies, including underwriting and claims handling. Your information comprises all the details we hold about you and your transactions and includes information we obtain about you from third-party sources who promote HMCA’s services.

Personal data includes information HMCA obtains about you from the forms and surveys you complete, records of our correspondence and phone calls and details of your visits to our website.

HMCA will only collect the information needed so that it can provide you with the service you expect from it. HMCA does not sell or broker your data.

How we use your personal data:
To carry out our contractual obligations arising from any contracts entered into between you and HMCA or you and underwriters HMCA introduce you to. To provide you with information on products or services that you request from us or which HMCA believes may interest you using the post, telephone and email.

To enable you to participate in interactive communications concerning the services offered by HMCA, if you choose to do so. To notify you about changes to the service you get from HMCA.

HMCA may also use data obtained from you to ensure that the content from our website is presented in the most effective manner.

Our legal basis for processing personal data:
To meet HMCA’s contractual obligations to policy holders and to also respond to individuals making enquiries for specific products.

Any legitimate interests pursued by us, or third parties we use, are as follows:
To pursue HMCA’s legitimate interests of promoting private healthcare and other policies which HMCA believes may be of interest to you.

Some health data is classified as a special category of personal data
HMCA will only collect the minimum amount of health data needed to fulfil its contractual obligations to you.

Consent
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for HMCA to process both personal data and special categories of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by emailing dpo@hmca.co.uk, phoning 01423 866985 or writing to: The DPO, Beech Hall, Knaresborough, Yorkshire, HG5 0EA


Retention period
HMCA will process personal data during the duration of the policy and will continue to store personal data for six years after the policy has terminated in order to meet any subsequent legal liabilities. Where individuals have enquired about a policy but not accepted it, HMCA will continue to maintain contact for up to three years after which any personal data will be deleted.


3) Why does HMCA need to collect and store personal data?

In order for us to provide you with a service, HMCA needs to collect personal data for communicating with you concerning the policies offered and subsequently administrating any policy you purchase.

In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

For marketing purposes, HMCA responds to an initial enquiry generated by you. Thereafter HMCA will stay in contact with you during the duration of your policy or for a maximum of three years from the date of your enquiry, unless you have requested us to stop or consented for HMCA to stay in contact for longer.

4) Will HMCA share my personal data with anyone else?

HMCA sometimes needs to pass on your personal data to third-party service providers contracted to HMCA such as hospitals, underwriters and companies within the same group in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to meet HMCA’s contractual obligations to you or to communicate information about other services we offer. When they no longer need your data to fulfil this service, they will dispose of the details in line with HMCA’s procedures, which is normally within 30 days of completion of the task unless part or all of the data is required to be retained to meet legal or contractual obligations such as post-operative support. If HMCA wishes to pass your special category data onto a third party it will only do so once it has obtained your consent, or where for example you have pre-consented by requesting treatment at a specific hospital, or where HMCA is legally obliged to divulge information. HMCA does not hold personal data outside the EEA.


5) How will HMCA use the personal data it collects about me?

HMCA will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). HMCA will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary, this is normally three years after an enquiry or six years after all policies have lapsed. HMCA is required to retain certain information in accordance with the law, such as details needed for income tax and audit purposes.
How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. In certain circumstances, such as contractual disputes or with your permission, personal data may be held for longer periods.


6) Under what circumstances will HMCA contact me?

Our aim is not to be intrusive, and HMCA undertakes not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

7) Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, 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 to 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 to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that HMCA refuses your request under rights of access, we will provide you with a reason as to why.

You have the right to complain as outlined in clause 10 below.

All of the above requests should be made to:

The DPO
Andrew Baker
dpo@hmca.co.uk
HMCA PLC, Beech Hall, Knaresborough, Yorkshire, HG5 0EA
Telephone +44 (0) 1423 866985

8) Can I find out the personal data that the organisation holds about me?

HMCA, at your request, can confirm what information we hold about you and how it is processed. If HMCA does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In all cases, this will be a representative in the UK or EU.
  • 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 HMCA or a third party and 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.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • 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.
  • 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.


9) What forms of ID will I need to provide in order to access this?

HMCA accepts the following forms of ID when information on your personal data is requested:

A copy of your passport, driving licence, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If HMCA is dissatisfied with the quality, further information may be sought before personal data can be released.

10) Contact details of the Data Protection Officer (DPO)

DPO contact details
Andrew Baker
HMCA PLC
Beech Hall
Knaresborough
North Yorkshire
HG5 0EA
Email: dpo@hmca.co.uk
Telephone: 01423 866985

Complaints
In the event that you wish to make a complaint about how your personal data is being processed by HMCA (or third parties as described in 4), or how your complaint has been handled, you have the right to lodge a complaint directly to HMCA’s non-executive director and the supervisory authority.

The details for each of these contacts are:

Supervisory authority contact details
Elizabeth Denham
ICO
Wycliffe House
Water Lane
Wilmslow
SK9 5AF
Email: https://ico.org.uk/global/contact-us/email/
Telephone: 0303 123 1113

HMCA Non-Executive Director contact details
Philip Allott (EU GDPR P)
HMCA PLC
Beech Hall
High Street
Knaresborough
HG5 0EA
Email: philip@hmca.co.uk
Telephone: 01423 866985