This Fair Processing Notice, which is also referred to in rule 24.5 as the 'data sharing document', tells you about processing of 'personal data' by The Standard Club and companies in the Charles Taylor Group who manage the business of The Standard Club.
We may hold and process your personal data in order to provide services relating to insurance of the shipping industry. Our activities (‘the Services’) include claims handling, underwriting and performing contracts of insurance which can include facilitating medical assistance abroad, salvage, and pollution insurance claims. We also provide other services related to our core business. When providing the services we are 'data controllers' of your personal data. We are committed to processing all personal data fairly, lawfully, and transparently.
To make things simpler, we have nominated one data controller, Charles Taylor & Co Ltd, to handle all requests or queries you might have about our processing of your personal data. We have jointly appointed a Data Protection Officer to oversee compliance with data protection law, and their contact details are: The Minster Building, 21 Mincing Lane, London, EC3R 7AG; +44 20 3320 2258, email@example.com.
You have various legal rights in your personal data including the right of: information and access to your data, including a “portable” copy of your data; erasure and rectification of your data; and rights to restrict or object to processing of your personal data. Where we rely on your consent to process your personal data you can withdraw that consent at any time. To exercise these data subject rights please contact the following email address: firstname.lastname@example.org.
The data we generally hold and process includes names, contact details, dates of birth, insurance policies or claims in which you may have been involved. This may include special category personal data including, potentially, information about your medical history, race, ethnicity, sexual orientation, religious beliefs, trade union membership, genetic and biometric data, political opinions, and any other physical or mental health details. This personal data is held only for the purposes of performing the Services.
Charles Taylor will obtain your data from The Standard Club, who in turn will have obtained it from their members (those individuals or companies, mostly ship-owners, who are insured by The Standard Club), lawyers, brokers, correspondents and others who deal with shipping incidents.
Our lawful bases for processing personal data include:
- Where you have given us your consent, we rely on that consent, including your explicit consent to publish special category personal data.
- Where you are party to a contract, and that contract requires your personal data to be processed.
- Where we may have legal obligations that mean we have to process personal data, including anti-money laundering obligations, checking criminal convictions, and checking international sanctions registers.
Some aspects of processing personal data in insurance may fall within the 'public interest' lawful basis. In all circumstances, however, we also rely on our legitimate interests, and those of the members of The Standard Club, to ensure that our members and innocent third parties are properly protected by the provision of adequate insurance against the risk of misfortune. Where we rely on our legitimate interests, we will always balance them against the rights and freedoms of the people whose personal data we process. Where their rights override our legitimate interests we will cease to process personal data.
From time to time, we may need to disclose personal data to third parties. Sometimes, these will be companies who process on our behalf and only act upon our instructions. Sometimes, these will be individuals and companies who are needed to provide services such as: lawyers; maritime experts; surveyors; technical consultants; agents; and correspondents.
From time to time we may need to transfer your personal data outside the European Union. We will, save for exceptional circumstances, only do so:
- to a country in the European Economic Area or that the European Commission has certified as having adequate data protection law
- under Binding Corporate Rules within our group of companies
- with your consent, to protect your vital interests, for important reasons of public interest, to perform a contract in your interests, for the defence of legal claims.
We will always keep records of where your data has been sent out of the EU and you can have access to these records if you wish. We will generally keep personal data for as long as we have a lawful basis, or where that lawful basis comes to an end, for six years and three months hereafter, for the purposes of any potential litigation, subject to our Data Retention policies. Any data kept after this time will be pseudonymised so that you are no longer identifiable from such data.
 Charles Taylor & Co Ltd’s address is: The Minster Building, 21 Mincing Lane, London, United Kingdom, EC3R 7AG, and is registered with the ICO (registration number Z6773825, accessible here: https://ico.org.uk/ESDWebPages/Entry/Z6773825).