Fair Processing Notice / Data Sharing Document
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 .
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.
We have a Data Protection Team which reports into the Group General Counsel who is the dedicated Standard Club Data Protection Officer. Our Data Protection Team oversees compliance with data protection law and its contact details are: firstname.lastname@example.org, The Minster Building, 21 Mincing Lane, London, EC3R 7AG.
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: email@example.com.
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.
The Standard Club obtains data from its members (those individuals or companies who are insured by insurance companies within 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 processing of your personal data is necessary for the performance of that contract;
- 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; where it is necessary for 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.
Some aspects of processing personal data in insurance may also fall within the 'public interest' lawful basis. 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. If their rights override our legitimate interests we will cease to process personal data where we are relying solely on this 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 United Kingdom or the European Economic Area. We will, save for exceptional circumstances, only do so:
- from the United Kingdom to a country in the European Economic Area or from a country in the European Economic Area to the United Kingdom;
- from both the United Kingdom and the European Economic Area to a country that the European Commission and the UK government has certified as having adequate data protection laws;
- under Standard Contractual Clauses approved by the European Commission or the United Kingdom government (as appropriate);
- under a set of rules applicable to transfers of personal data within a group of companies. These are known as Binding Corporate Rules and are approved by a supervisory authority in the European Union;
- under a group data transfer agreement which incorporates the Standard Contractual Clauses;
- with your consent, to protect your vital interests, for important reasons of public interest, to perform a contract in your interests or for the defence of any legal claim.
We will always keep records of where your data has been sent outside of the United Kingdom or the European Economic Area. 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 the appropriate period in line with our Document Retention Policy. Any data kept after this time will be pseudonymised so that you are no longer identifiable from such data without additional information.
 The companies who form The Standard Club are: The Standard Club Ltd, incorporated in Bermuda; Standard Club Management (Bermuda) Limited, incorporated in Bermuda with a branch in Japan; The Standard Club Asia Ltd, incorporated in Singapore with a branch in Hong Kong; Standard Club Management (Asia) Pte. Limited, incorporated in Singapore with a branch in Hong Kong; The Standard Club Ireland DAC, incorporated in Ireland with a branch in the UK; Standard Club Management (Europe) Limited, incorporated in Ireland with a branch in the UK and Greece; The Standard Club UK Ltd, incorporated in the UK; Standard Club Management (UK) Limited, incorporated in the UK; The Shipowners' Mutual Strike Insurance Association Europe, incorporated in Luxembourg with a branch in the UK; Standard Club Management (Americas), Inc., incorporated in the United States; Standard Reinsurance (Bermuda) Limited, incorporated in Bermuda.