Trinity Insurance Brokers, Inc.
Privacy Policy

Introduction

The Policy describes the commitment of Trinity Insurance Brokers, Inc., (TIB) to protect and safeguard personal information. This Policy governs the handling of Personal Information by our organization and establishes a set of privacy principles for the good management of this information.

Policies and Guidelines

This Policy applies to all Personal Information processed by TIB including, but not limited to, data on employees, client personnel and third parties.

“Personal Information” – which is defined as information relating to an identifiable natural person. Examples include:
• Name,
• Address,
• Mobile phone number,
• Date of birth,
• Account number (bank account, credit card, etc.),
• Personal numbers
• Photographs and other information such as salary, performance ratings and time and expense data.

“Sensitive Personal Information” is a category of personal information that requires an extra level of protection or a higher duty of care. Examples include information that reveals:

• Racial or ethnic origin,
• Political opinions, religious or philosophical beliefs,
• Trade union membership,
• Medical or health conditions,
• Sexual preferences,
• Data relating to offences and criminal convictions,
• Financial information relating to individuals, and
• Government issued identification, such as national identification number, national insurance number and social security numbers

TIB will protect Personal Information in its custody or control in accordance with applicable law and contractual obligations, professional requirements and internal policies, procedures and practices and in accordance with the following privacy principles:

• Information Collection
We shall only collect Personal Information that is necessary, relevant and not excessive for the business purposes for which it is to be used.

• Notice
As appropriate we shall be transparent about how we collect and use Personal Information.

• Choice and Consent
We shall avoid using or sharing Personal Information in ways that are incompatible with the original purpose for which it was collected, unless subsequent authorization has been obtained.

• Update of Personal Information
We will periodically update individual Personal Information in the Practice’s Management System, as appropriate.

• Information Transfer
As appropriate we shall take reasonable steps to ensure that transfers of an individual’s Personal Information to third parties or across borders are consistent with the purposes identified to the individual and the contractual obligations that apply to us with respect to such Personal Information. We will require that third parties acting on our behalf (e.g. subcontractors) process Personal Information in accordance with our instruction and in a manner consistent with the contractual obligation applicable to us.

• Information Integrity
We shall take reasonable steps to verify that Personal Information is relevant, accurate, complete and current as is necessary for the purpose for which it is to be used.

• Information Security
We shall take reasonable steps to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration or destruction.

• Information Retention
We shall take reasonable steps to ensure that Personal Information is retained only for as long as needed to meet the purposes for which it was collected, subject to the following:

o Employee’s Personal Information will be retained by TIB as it deems necessary.
o Client’s Personal Information obtained to support and performs TIB services will be filed as part of client data and will be retained in accordance with applicable laws. This includes information obtained when performing background check of key owners and officers of Client.

• Compliance and Enforcement
TIB shall address inquiries or complaints regarding personal information promptly and courteously.

All TIB employees are responsible to know, understand, and comply with the Policy. Failure to comply could result in significant risk for TIB, our clients and our people. We may subject any individual to disciplinary action including, if deemed appropriate, termination for non-compliance.

If you have any questions or concerns about the interpretation or operation of this policy please contact our Data Protection Officer Mr. Iñigo M. Garcia at dpo@trinity-insures.com, (02)8101653 loc 605.

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