First Title Insurance

PRIVACY NOTICE

Introduction

The Data Protection Act 2018 (DPA) and the General Data Protection Regulation, as applicable in the UK (GDPR) seeks to protect and enhance the rights of data subjects. We are committed to protecting and respecting privacy of data subjects. We take privacy seriously and will only use personal data in connection with our business as set out in this privacy notice.

The legal bases that we rely upon in processing personal data are as follows:

  • The performance of a contract or in contemplation of a contract, for example, in providing and/or offering an insurance policy and administering that policy).
  • Legitimate interest, for example, in providing and/or administering an insurance policy for a service provider or adviser. Activities promoting our services include direct marketing which individuals may opt-out of at any time. Enabling our suppliers and service providers to be able to provide products and services to us.
  • Legal obligations: Certain statutory and/or regulatory rights and obligations apply to us which require us to process personal data, and in some circumstances to provide it to third parties, such as our regulators and supervisory authorities, law enforcement authorities and agencies, or other such competent authorities.

In what capacity will First Title hold personal data?

In providing insurance services, we will act as a data controller, and shall comply with the GDPR at all times.

In most cases, personal data will be provided to us by a legal professional or an insurance broker.

Personal data may be provided to us via our websites (www.firsttitle.co.uk, www.firsttitleresidential.co.uk and https://secure.first-title.co.uk) or provided to us by telephone, post or email.

What happens if a service provider or advisor cannot provide us with personal data?

Please note, if we are unable to obtain all the necessary information, we may be unable to offer an insurance policy or administer any existing policy.

What are your rights relating to the use of your personal data?

Under the GDPR you have rights around our processing of your personal data, which depend on the legal basis for our collection of your personal data and the uses we make of personal data. For all uses made of your personal data, you have the right to be informed about how we use your data and this notice discharges that obligation. However, further rights apply in different circumstances, these rights are set out below:

  • Right of access – You have a right to request a copy of the personal data we hold about you by contacting our Data Protection Officer.
  • Right of rectification – You have a right to ask us to correct personal data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – In certain circumstances you can ask for the data held about you to be erased from our records. Please note our retention period set out in this notice.
  • Right of portability – You have the right to ask us to transfer the personal data we hold about you to another organisation.
  • Right to restriction of processing – You have a right to ask us to restrict our processing of your personal data.
  • Right to object – You have the right to object to certain types of processing such as direct marketing and automated processing.

What personal data will First Title hold?

Personal data to enable us to offer or provide an insurance policy and/or to administer that policy (including fraud prevention and financial crime checks, as well as claims handling), such as:

  • title and full name
  • current and new home addresses
  • email address
  • telephone or other contact number
  • post code
  • IP address
  • bank details

Should First Title need to process any Special Category personal data in relation to you, we will seek consent to process such data or otherwise process the same in accordance with the other legal bases set out through Article 9 GDPR (Section 10 DPA).

How will First Title use personal data?

First Title will use personal data for:

  • processing a request for an insurance policy
  • internal record keeping
  • for fraud prevention; we may share personal data with fraud prevention agencies
  • undertaking financial crime checks

If you give us personal data regarding another person, you are confirming that you have their consent to provide their personal data to us.

In some cases, we may be required to disclose personal data by law or regulation to Government bodies or to our Regulators, but First Title is committed to only doing so where it is necessary for us to do so.

How long will First Title retain personal data?

In most cases, the policies we offer provide insurance coverage in perpetuity. We are therefore required to retain personal data indefinitely, in order to continue administering those policies.

Will personal data be transferred outside the UK?

On occasion we may transfer personal data to companies within our group or other affiliates in countries outside the UK for policy administration or reinsurance purposes.

Where we make such a transfer, we will take any measures necessary to ensure personal data is protected. Such steps can include entering into recognised mechanisms, such as Standard Contractual Clauses or the International Data Transfer Agreement.

Data Protection EU Representative

In accordance with Article 27 GDPR we have designated an EU representative to act on our behalf if and when we undertake data processing activities to which article 3(2) of GDPR applies.

Our representative is:

First European Title Insurance Company Limited
Portomaso Business Centre, Portomaso, St Julians,
PTM 0001, Malta

How do we use Cookies?

A cookie is a small file of letters and numbers that is downloaded onto your computer when you visit our website. These cookies are used by us to secure sessions and improve access to our websites. You can use your web browser to control cookies.

Further information

In the event you wish to learn about the technological or organisational controls we have in place to protect personal data, please contact the Data Protection Officer by email: compliance@firsttitle.co.uk.

Contact & Complaints

If you would like to make a subject access request, raise a concern or make a complaint about how your personal data is being processed by First Title you may contact the Data Protection Officer, by email: compliance@firsttitle.co.uk or in writing to Compliance team, First Title Insurance plc, ECA Court, 24-26 South Park, Sevenoaks, Kent, TN13 1DU.

You also have the right to complain to the Information Commissioner’s Office who would normally expect that we have first been given the opportunity to respond to your concerns or complaint.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

PrivacyPolicy/V29/10/2023

First Title Insurance plc is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. First Title Insurance plc is registered in England under company number 01112603.

Registered office: First Title Insurance plc, ECA Court, 24-26 South Park, Sevenoaks, Kent TN13 1DU.