Privacy & Data Policy June 2025 (v3)

PRIVACY & COOKIE NOTICE

Ross Gower Group is a provider of Channel Island insurance services including car insurance, home insurance and commercial vehicle insurance. Ross Gower Group also offers support to Isle of Man residents.

This Privacy Notice sets out how the Ross Gower Group will process personal information as a controller or joint controller in connection with the provision of products and services and marketing to individuals.

If you have any questions about our use of your personal information, please contact our Data Protection representatives at [email protected]

We may amend this Notice from time to time to keep it up to date with applicable legal requirements and our group operating model.

Why Do We Collect & Process Data and How Will We Us It?

We ask you to provide us with data so that we can:

Fulfil our contract with you
Fulfil our legitimate interests
Meet our legal and regulatory duties
Understand your needs so we can provide you with suitable products & services
Contact you including sending you information on our services
For security of our premises and employees

Legitimate Interest When we have a business or commercial reason of our own to use your personal information, this is called a 'legitimate interest'. We'll tell you what that is, if we are going to rely on it as the reason for using your personal information. Even then, it must not unfairly go against your interests.

How Do We Collect Data?

We will do this through various means, including website registration, surveys, games, questions, comments and communications to the website, and postings to chat and bulletin areas, if any.

You may telephone us, and we will record information that you provide to us during the call.

We have closed-circuit television (CCTV) in use at our physical offices.

What Data Do We Collect?

We will ask you for:

Your name, address, phone number and e-mail address and information relating to your insurance history for motor and home insurance.
In the case of named drivers on a motor insurance policy we will also ask for their name, address, phone number and e-mail address and information relating to your insurance history.
If home insurance is for landlord cover for rented properties, we will ask for the name(s) of any tenant(s).
We may collect your IP (Internet Protocol) address to help diagnose problems with our server, and to administer our Site. Your IP address is also used to help identify you and to gather broad demographic data.
We will collect your physical image by way of CCTV, when you visit our premises.

Consent

In data protection terms, consent is the act of you choosing to give us your permission to do something specific with your personal data. This is known as lawful processing.

The lawful processing for Ross Gower Group is providing you with an insurance product specific to your circumstances.

Online Applications

You will be directed to this Privacy and Cookie Policy, Internet Terms Conditions and Ross Gower Group Limited Charges and Terms and Conditions. You will then be asked to confirm your consent to continue, based upon the conditions set out in the document.

On acceptance of the conditions, the data will be forwarded from your browser and processed in accordance with the type of application. Should you be unwilling to share the data at this point, the application will not be forwarded from your browser and you are free to discard without further interaction with Ross Gower Group Limited.

What Data Protection Legislation Applies?

Guernsey

Ross Gower is registered with the Office of the Data Protection ('ODPA') in Guernsey.

As a Data Controller and Processor, it must comply with the requirements of the Data Protection (Bailiwick of Guernsey) Law.

Jersey

Ross Gower is registered in Jersey with the Jersey Office of the Information Commissioner (JOIC').

As a Data Controller and Processor, it must comply with the requirements of the Data Protection (Jersey) Law 2018.

Controller: Any person or entity who is responsible for the decisions made about why and how they use personal data about staff, customers, suppliers, or any other people.

Processor: Any person or entity that is given the task of processing personal data by a controller. Processors do not determine the nature or the means of the processing, they just do what the controller tells them to do.

Your Data Subject Rights

You have the following rights, in certain circumstances and subject to certain exceptions, in relation to your personal data

Right to information for the personal data collected When you are asked to provide any information (i.e. personal data) to us, there is a legal requirement for us to make it clear who we are and what exactly is going to happen to your data. We are required to supply this 'fair processing information' to you in the form of our privacy policy.
Right of access You can ask what data we hold about you and why by submitting a 'data subject access request' (also known as a 'SAR', or a 'DSAR').
Right to object to processing for direct marketing purposes You can request that we stop processing your personal data for direct marketing purposes.
Right to object to processing on grounds of public interest You have a right, in the following two circumstances, to request that processing of your personal data ceases:
1. Where we are processing your personal data based on the grounds that is in our 'legitimate interests'
2. Where a public authority says it is processing your personal data based on the grounds that is in the 'public interest'.
Right to object to processing for historical or scientific purposes If we are processing your personal data based on it being necessary for historical or scientific purposes, you have a right to request we stop.
Right to rectification If you dispute the accuracy or completeness of personal data about you, you have the right to require us to rectify or change the data.
Right to erasure For data processed in certain circumstances, you have a right to require us to erase your personal data.
Right to restriction of processing For data processed in certain circumstances, you have a right to obtain a restriction of processing by us.
Right not to be subject to decisions based on automated processing Automated decision making' often means that no human is involved in the processing of personal data. The Law recognises that individuals should be protected against unfair and harmful practice and provides you with a right not to be subjected to an automated decision.
Right to data portability This allows you to instruct for your personal data to be transmitted from us to another organisation who you wish to have control of your data

Who Might We Share Your Data With?

Under the conditions of your policy, you must tell us about any incident (e.g. accident, fire, theft or malicious damage) which may or may not give rise to a claim. When you tell us about an incident, we may share that with:

Motor Insurance Database

Information relating to motor insurance policies will be added to the Motor Insurance Database (MID) managed by the Motor Insurers' Bureau (MIB). MID and the data stored on it may be used by Insurers, the Police, DVLA/DVANI, the Insurance Fraud Bureau or other bodies permitted by law for purposes including, but not limited to:

Claims and Underwriting Exchange Register

Run by Insurance Database Services Ltd and the Motor Insurance Anti-Fraud and Theft Register run by the Association of British Insurers.

Your data may also be shared with:

IT Hosting Platforms
Credit Reference Agencies
Payment Gateway Providers
Auditors
Suppliers of services
Financial Organisations
Debt Collecting, Tracing and Private Investigators
An organisation processing data on behalf of Ross Gower Group
Regulatory Authorities
Ombudsman
Electronic Vehicle Licensing
Continuous Insurance Enforcement
Law enforcement

How We Protect & Secure Your Information

We capture your personal information, over a secure link using recognised industry standard Secure Sockets Layer (SSL) technology which encrypts the data whilst passing it over the web. This will be indicated on most browsers by a lock in the status bar at the top of the screen. Firewalls are used to block unauthorised traffic to the servers and the actual servers are locked in a secure location which can only be accessed by authorised personnel.

All information transferred between your browser and our website or third-party applications are encrypted using HTTPS protocol, using Digital Certificates with secure TLS Cyphers. This can be verified by looking for the secure padlock symbol in the browser address bar.

In order to prevent un-authorised access or disclosure, we have proprietary physical, electronic and managerial procedures in place to safeguard and secure the information we collect.

How Long Will We Keep Your Data For?

We will retain your data for as long as required for us to perform our contracted services to you:

Customer Information - 6 years after the completion of the last product provided.
Premium Loan Data - 6 years after the completion of the agreement.
Insurance Application Data - 6 years after the completion of the policy.
Application not leading to the sale of a product – 31 days.

At the completion of the retention period, all data will be securely destroyed.

We will also retain your data for the period required by anti-money laundering and know-your customer regulations and as long as necessary for you to be able to bring a claim against us and for us to defend ourselves against any legal claims. In certain circumstances, data may need to be retained for a longer period of time, for example where we are in ongoing correspondence or there is a continuing claim or investigation

Images collected by way of CCTV will be held for 60 days then securely deleted.

Sensitive Personal Data

Ross Gower Group Limited will not enquire or procure sensitive personal data from you.

It is necessary in some cases, to record medical history in relation to motor, travel and medical insurance plans. For motor insurance, this is limited to recording if a prospective policy holder has a generic medical condition, however this will not include procuring or holding any sensitive personal data.

Data Relating to Children

Data relating to children, (an individual aged under 13 years) will be gathered only in the case of a family travel insurance policy. Information will be provided to us by the parent or guardian.

Links

Our website contains links to a websites specific to the Ross Gower Group and which are used to support our services to you. Please be aware that we have no control over these sites and our privacy policy does not apply to these sites.

Cookies

When you visit our website, it may store or retrieve information in your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the website work as you expect it to.

We may use cookies to:

Customize your experience on our website.
To record how many times you have visited our website and what pages you have accessed.

You may disallow receiving cookies at any time through your web browser. Consent Preferences

Data Subject Access Request

You can ask what data we hold about you and why by submitting a 'Data Subject Access Request' or 'DSAR', by e-mailing us at [email protected] or calling us on 01481 722222.

We will not make a charge for providing this information to you and will respond within one month of the day we receive your request, or the day we receive any information reasonably necessary to confirm your identity.

If your request is complex, data protection legislation permits that our response period may be extended by a further 2 months and we will notify you of this prior to the expiry of the initial response period.

Complaints

We work hard to ensure that your personal information is treated safely and securely. However, if you have a complaint, you can call us on 01481 722222, or by e-mailing us at [email protected].

Contacting The Supervisory Authorities

You have the right to complain to the Office of Data Protection Authority (ODPA) in Guernsey and the Jersey Office of the Information Commissioner in Jersey. Contact information is shown on each of these authorities websites.

Registration and Contact Information

Ross-Gower Group Limited is a Guernsey registered Company No 20027. Licensed by the Guernsey Financial Services Commission to advise on all classes of General Insurance. Ross Gower Group Limited is regulated in Jersey by The Jersey Financial Services Commission in the carrying on of general insurance mediation business.

Guernsey registered office: PO Box 2, Insco House, Rohais, St Peter Port, Guernsey,
GY1 3AA.

Telephone: 01481 722222
E-mail: [email protected]