Privacy

Last updated: 15/08/2020

Orchard Administration are committed to protecting and respecting your privacy.

Orchard Administration Limited (“We” or “Orchard Administration”) are committed to protecting the privacy of the individuals we encounter in conducting our business.

“Personal Information” is information that identifies and relates to you or other individuals (the Data Subject).

Orchard Administration is the Data Controller for all Personal Information collected. Orchard Administration offers third party claims management services and is registered with the Information Commissioners Office under the General Data Protection Regulation.

Where we are processing your data in relation to an insurance claim that you are pursuing, our lawful basis for processing your data, as set out in Article 6 of the GDPR, is for the performance of the insurance contract that you have purchased. The processing of the collected data is necessary for the claim. If an individual does not wish to provide the necessary Personal Information, Orchard Administration will be unable to process a claim.

Orchard Administration does not participate in any marketing activities and will not use your Personal Information in this way.

This Privacy Policy describes how we handle Personal Information that we collect through this website.

We may collect your information through other means - for example, claim forms, telephone calls, emails, other communications, claim investigators, medical professionals, witnesses or other third parties involved in our business dealings with you.

The General Data Protection Regulation provides the following rights for individuals:

The right to be informed;
The right of access;
The right to rectification;
The right to erasure;
The right to restrict processing;
The right to data portability;
The right to object;
Rights in relation to automated decision making and profiling.

1. Who to contact about your Personal Information

If you have any questions about our use of your Personal Information, you can contact our Compliance Team via email: compliance@orchard-administration.co.uk. You can also write to the Compliance Team, Orchard Administration, Third Floor Riverside House, 40-46 High Street, Maidstone, ME14 1JH.

2. Personal Information That We Collect

We will only collect data than is necessary for the purpose of the processing.

Depending on your relationship with us (for example, as a claimant, non-policyholder insured, authorised contact, witness or other person relating to our business), Personal Information collected about you may include:

General identification and contact information
Your name; address; e-mail and telephone details; gender; date and place of birth; passwords (including on our systems); activity records, such as driving records; photos; relationship to the policyholder, insured or claimant; and date and cause of death, injury or disability.
Identification numbers issued by government bodies or agencies
Passport number; tax identification number; or driver’s or other license number.
Financial information and account details
Bank account number and account details; and other financial information.
Medical condition and health status
Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.
Other sensitive information
In certain cases, we may receive sensitive information about your trade union membership, religious beliefs, political opinions, family medical history or genetic information (for example, if you apply for insurance through a third-party marketing partner that is a trade, religious or political organization). In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud. We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).
Telephone recordings
Recordings of telephone calls to our representatives and call centres. Information to investigate crime, including fraud and money laundering (for example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose).
Information enabling us to provide products and services
Location/identification of property insured (for example, vehicle license plate or identification number); travel arrangements including reservation numbers; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organiaation; and other insurance you hold.

3. How We Use Personal Information

We use this Personal Information to:

Communicate with you and others as part of our business.
Send you important information regarding your claim and other administrative information.
Make decisions about insurance and assistance services, including claim assessment, processing and settlement; and, where applicable, manage claim disputes.
Process your settlement.
Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks.
Carry out market research and analysis, including satisfaction surveys.
Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management.
Resolve complaints, and handle requests for data access or correction. Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).
Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.
Orchard Administration does not take part in any automated decision making, including profiling.

4. International Transfer of Personal Information

Due to the global nature of our business, for the purposes set out above we may transfer Personal Information to parties located in other countries (including the United States and other countries that have a different data protection regime than is found in the country where you are based). We may transfer information internationally to our service providers, business partners and governmental or public authorities. Any transfers of data outside of the EU are covered by a framework which is appropriate for the data protection regulation within the EU (for example, the EU-U.S. Privacy Shield).

5. Sharing of Personal Information

Orchard Administration Limited may make Personal Information available to:

Insurance and distribution parties
In the course of providing insurance and processing claims, Orchard Administration may make Personal Information available to third parties such as other insurers; reinsurers; insurance and reinsurance brokers and other intermediaries and agents; appointed representatives; distributors; and financial institutions, securities firms and other business partners.
Our service providers
External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel and medical assistance providers; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; third-party claim administrators; document and records management providers; claim investigators and adjusters; examiners; jury consultants; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
Governmental authorities and third parties involved in court action
Orchard Administration may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.
Other Third Parties
We may share Personal Information with payees; emergency providers (fire, police and medical emergency services); medical networks, organisations and providers; travel carriers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim. To check information provided, and to detect and prevent fraudulent claims, Personal Information (including details of injuries) may be put on registers of claims and shared with other insurers. We may search these registers when dealing with claims to detect, prevent and investigate fraud. Personal Information may also be shared by you via blog messages or email to which you are able to disclose any information or materials you wish. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, when using the our blog system.
After purchase review
We have contracted with Trustpilot to contact you so that you can provide a review of your experience with us. You will receive an email around 14 days after the start date of your policy. We would be grateful if you could take the time to complete a review as this is invaluable to us in developing our website, products and services. We provide Trustpilot with your email address in order to review and improve our service – this data is processed under the lawful basis of legitimate interests. If you have been contacted by Trustpilot and do not wish to be contacted by them again, you can unsubscribe by clicking on the relevant link on the Trustpilot email that you have received.

6. Security

Orchard Administration will take appropriate technical, physical, legal and organisational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us. (See the “Who to Contact About Your Personal Information” section above.)

When Orchard Administration provides Personal Information to a contracted service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Information.

7. Retention of Personal Information

Orchard Administration always takes reasonable steps to ensure that the Personal Information we process is reliable for its intended use, and as accurate and complete as is necessary to carry out the purposes described in this Privacy Policy. Orchard Administration will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

8. Personal Information of Other Individuals

If you provide Personal Information to Orchard Administration regarding other individuals, you agree: (a) to inform the individual about the content of this Privacy Policy; and (b) to obtain any legally-required consent for the collection, use, disclosure, and transfer (including cross-border transfer) of Personal Information about the individual in accordance with this Privacy Policy.

9. Marketing Preferences

Orchard Administration does not participate in any marketing activities.

10. Access and Correction Requests, Questions and Concerns

In certain countries, an individual may have the right to access, correct or object to the use of, or request deletion or suppression of Personal Information on certain grounds. Please contact us as set out in the “Who to Contact About Your Personal Information” section above with any such requests or if you have any questions or concerns about how we process Personal Information. Please note that some Personal Information may be exempt from access, correction, objection, deletion or suppression rights in accordance with local privacy and data protection laws.

11. Other Information We Collect Through Our Website

“Other Information” is any information that does not reveal your specific identity, such as:

Browser and electronic device information;
Information collected through cookies, pixel tags and other technologies;
Demographic information and other information provided by you; and
Aggregated information

We and our third-party service providers may collect Other Information in a variety of ways, including:

Through your internet browser or electronic device:
Certain information is collected by most websites or automatically through your electronic device, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, electronic device manufacturer and model, language, time of the visit and page(s) visited. We use this information to ensure that the Site functions properly.
Using cookies:
Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to recognize your computer and to collect information such as internet browser type, time spent using the Site, pages visited, language preferences and relevant country website. We may use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Site, or to gather statistical information about the usage of the Site.

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “Other Information We Collect” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

12. Third Party Websites

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Site links. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us or by our group companies.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the information security practices) of other organizations, such as Facebook, Twitter, Apple, Google, Microsoft®, RIM/Blackberry or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or electronic device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Site.

13. Use of the Site by Minors

The Site is not intended for the use individuals under the age of sixteen (16), and we request that these individuals do not provide Personal Information directly through the Site.

14. Complaints

If you are concerned that we have breached a privacy law or code binding on us, please send an email to compliance@orchard-administration.co.uk. We aim to respond in a reasonable time (usually no later than 5 working days). Our Compliance Team will handle your complaint and will give you additional information about how it will be handled.

You also have the right to complain to the Information Commissioner’s Office (ICO) if you believe we have not handled your request in an appropriate manner. For more information, please see: www.ico.org.uk/concerns.

15. Changes to This Privacy Policy

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.

Please look at the "LAST UPDATED" date at the top of this Privacy Policy to see when it was last revised.