General Data Privacy Notice

Legal framework for protecting your personal data

This data privacy notice is written to comply with the European Union General Data Protection Regulation (GDPR). GDPR gives control to citizens and residents over their personal data.

Data Controller

  • Name: Thomas Miller
  • Phone: +44 (0)207 283 4646
  • Email: contactus@thomasmiller.com
  • Address: 90 Fenchurch Street London EC3M 4ST United Kingdom

Data Protection Officer 

  • Name: Jim Ashton
  • Phone: +44 (0)207 204 2545
  • Email: jim.ashton@thomasmiller.com
  • Address: 90 Fenchurch Street London EC3M 4ST United Kingdom

Data Controller's Lines of Business 

Thomas Miller Holdings Ltd. is the data controller for all lines of businesses under ownership or management. Click here to see a complete list of businesses.

How data is used 

Thomas Miller may process personal information as part of its insurance and financial services businesses: underwriting, reinsurance, claims, legal services, loss prevention, wealth management, document processing, finance, marketing, renewals, contract review, risk management and employment.

Personal data profile categories processed 

Thomas Miller maintains personal data for:

  1. Subjects of claims, investigations, proceedings etc.
  2. Advisers, consultants and other professional experts
  3. Business associates, other professional bodies, advisers
  4. Business contacts
  5. Complainants and enquirers
  6. Customers and clients
  7. Employees
  8. Employers and employees of other organisations
  9. Members and beneficiaries
  10. Offenders and suspected offenders
  11. Relatives, guardians
  12. Shareholders
  13. Suppliers and services providers
  14. Subjects of claims, investigations, proceedings and other claim related profiles
  15. Trustees
  16. Witnesses

Automated decision making 

Thomas Miller does not use automated decision making.

The legal bases we use for lawful processing 

In order for Thomas Miller to conduct business and fulfil its legal, regulatory and contractual obligations, it needs to perform legitimate and fundamental processing. These are:

  1. Establishing contracts
  2. Maintaining contracts
  3. Provision of all contracted services
  4. Invoicing, remittance, payments, collections
  5. Non-promotional communications
  6. Marketing and other promotional communications
  7. Risk management contract review
  8. Response to Subject Access Requests
  9. Performance measurement
  10. IT support services
  11. Business Continuity Planning
  12. Legal and regulatory obligations
  13. Responding to enquiries, requests and complaints
  14. Employment processing

The categories of people who will access or receive the data

Thomas Miller sometimes needs to share the personal information it processes with individuals themselves and also with other organisations. Below is a description of the types of organisations with which Thomas Miller may need to share some of the personal information it processes.

  1. Agents and brokers
  2. Business associates, other professional bodies, advisers
  3. Central / local government
  4. Claimants, beneficiaries, assignees and payees
  5. Claims investigators
  6. Complainants, enquirers
  7. Courts and tribunals
  8. Credit reference, debt collection and tracing agencies
  9. Current, past and prospective employers
  10. Customers and clients
  11. Data processors
  12. Debt collection and tracing agencies
  13. Education and examining bodies
  14. Employment and recruitment agencies
  15. Family, associates and representatives of the person whose personal data we are processing
  16. Financial organisations and advisers
  17. Healthcare professionals, social and welfare organisations
  18. Law enforcement and prosecuting authorities
  19. Ombudsman and regulatory authorities
  20. Other companies in the same group
  21. Pension schemes 
  22. Police forces
  23. Private investigators
  24. Professional advisers
  25. Share Administrators
  26. Suppliers and services providers
  27. Survey and research organisations
  28. Trade associations, professional bodies, employer associations

The countries where data will be stored, processed and transferred

Your personal data collected by Thomas Miller may be stored and processed in the United Kingdom or any other country in which Thomas Miller or associated third parties maintain facilities.
Should Thomas Miller need to transfer your personal data, Thomas Miller will take all reasonable measures to safeguard the transfer of your personal data to third parties in a manner that complies with the GDPR.

How long the data will be retained 

Retention of specific records may be necessary for one or more of the following reasons:

  1. To fulfil statutory or other regulatory requirements.
  2. To evidence events/agreements in case of disputes.
  3. To meet our operational needs.
  4. To meet any historical purposes.

Personal data that is collected and subsequently never used for any business purpose will be reviewed and may be destroyed at Thomas Miller’s discretion.

What happens if the data isn't collected

Your personal data is required for communication and setting up a contractual agreement to provide products and services. Without this data Thomas Miller will not be able to communicate with you or enter into a contractual agreement with you. This includes both business and employment contracts.

Thomas Miller needs personal data to:

  1. enable consensual bilateral communications;
  2. engage in pre-contractual activities;
  3. honour contractual obligations; and
  4. enable it to employ people.

Without this data, Thomas Miller will not be able to perform these four primary activities.

The right to withdraw consent

In situations where Thomas Miller requests and receives your consent to perform processing, we are also obliged to stop such processing if you decide to withdraw your consent. Withdrawing consent is as straightforward as giving consent. Withdrawing consent cannot be back-dated so it has no effect on processing already performed during the period of consent.

The right to access, change, delete, restrict, object, request a copy

You have rights regarding the personal data we store on your behalf. These are:

  1. access to a copy of your personal data;
  2. object to processing that you object to; 
  3. stop receiving direct marketing material;
  4. object to decisions being taken by automated means;
  5. have inaccurate personal data rectified, blocked, erased or destroyed;
  6. lodge a complaint with the Information Commissioner’s Office;
  7. claim compensation for damages caused by a breach of the GDPR.

Should you ever wish to exercise any of these rights, please contact the Data Protection Officer.

The right to complain to the regulator

You have the right to lodge a complaint with the Information Commissioner’s Office if you think that your personal data has been inappropriately used.

Cookies

a. Cookies may be used by the Website to allow us to recognise you and your preferred settings e.g. to store your ID and password for future sessions. This saves you from re-entering information on return visits to the Website. You have the option not to use this feature, in which event no cookies will be retained on your computer.

b. If the site has a secure log-in for our registered users, it may use a temporary ’session cookie’ in order to perform the secure login to our website. This cookie contains no personal information, just a long random number, and is deleted from your web browser when you exit the Website.

c. Temporary cookies are used in the transactional part of the Website to authenticate you as an authorised user after you have logged in.

d. Your browser may be capable of being programmed to reject cookies, or to warn you before downloading cookies, and information regarding this may be found in your browser’s ‘help’ facility.

For an explanation of cookies see: http://www.allaboutcookies.org/

If you have any questions regarding the use of cookies please contact us by email at contactus@thomasmiller.com

Below is a table of all cookies on this website – their name, type and purpose:

Cookie TypeCookie Name Cookie Purpose
Session & TYPO3 Content Management Cookiesession, fe_typo_user, s_cc & s_sqWe use session cookies to record an individual users preferences that the user has specified, so that each time the user returns their preferences remain. Commonly this would be language settings, shopping carts, anything where you have indicated a preference. Where forms are used on the site, we hold the information in a session cookie so that we can improve the user experience on the site. Should a user, for example, forget to fill in parts of a form when submitting a form, we can auto-fill the values for those fields that have been filled in, thereby reducing the amount of fields a user needs to amend. This information is stored only in your browser and is destroyed once your browser is closed.
Google Analytics__utmz __utmc __utmb __utmaThese cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site for you. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

We use third party companies as suppliers for some of our functions. Their use of the data is controlled by our contract with them and they are only allowed to use the data strictly for the purpose we have stated e.g. the data is not used in connection with data from other companies and we are not tracking user behavior outside our own sites. 


Other Websites

This privacy policy only covers the Website. Any other websites which may be linked to by the Website may be subject to their own privacy policy, which may differ from ours and we are not responsible for the content provided on any third party web sites.