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Privacy Policy

 

TC2 Underwriting – Privacy Notice

TC2 Underwriting (“we”, “us”, or “our”) is committed to protecting your privacy and safeguarding the personal data we handle. Personal data refers to any information that can identify an individual either directly or indirectly. This Privacy Notice explains how we collect, use, share, and protect your information in connection with our underwriting and insurance activities.

We are registered as a data controller under UK Data Protection legislation and comply with all applicable laws, including the UK GDPR and Data Protection Act 2018.


1. How We Use Your Personal Data

We collect and process personal data in the course of normal insurance operations. This may include:


  • Providing insurance services, such as advising on, arranging, underwriting, or managing insurance contracts.
     
  • Handling claims, including assessing, investigating, adjusting, and settling claims.
     
  • Meeting legal or regulatory obligations, including the prevention and detection of fraud.
     

Where necessary, we may supply personal data to fraud prevention agencies. If inaccurate or fraudulent information is identified, details may be shared with relevant bodies to help reduce financial crime.


2. Lawful Basis for Processing

We will process personal data only where a lawful basis applies. For most of our insurance-related activities, this includes:

  • Performance of a contract, where processing is required in order to provide insurance or administer a claim.
     
  • Legitimate interests, including underwriting, pricing risk appropriately, managing claims, and maintaining the integrity of the insurance market.
     
  • Legal obligations, particularly where regulations require the retention or sharing of certain information.
     

Where personal data is handled within the EEA outside the UK, it will be processed in accordance with local data protection requirements. If there are no significant differences, we follow UK GDPR standards.


Special Category personal data (e.g., health information) will only be processed where necessary and where you have provided explicit consent, unless another valid GDPR condition applies.
We do not process personal data relating to criminal convictions unless necessary for insurance purposes and legally permitted.


3. Insurance Market Data Sharing

Insurance often involves the movement of personal data between multiple participants such as brokers, insurers, reinsurers, coverholders, and claims specialists. Our use and disclosure of data aligns with the London Market Core Uses Information Notice, which outlines the standard data flows within the UK insurance market.


We limit the personal data we request or disclose to what is strictly relevant and required to perform our functions.


4. What Personal Data We Collect

We may receive personal data directly from you, from your broker, or from other market participants. The types of information we may handle include:

  • Name, contact details, and identifying information
     
  • Address and property details
     
  • Occupation and policy-related information
     
  • Claims history and risk information
     
  • Details of family members included in a policy
     
  • Special Category data where needed (e.g., health details for certain claims)
     

Any sensitive information is processed only where necessary to provide insurance or fulfil a legal requirement.


5. Who We Share Your Data With

Where necessary, we may share your personal data with:

  • Insurance intermediaries and brokers
     
  • Insurers and reinsurers
     
  • Claims handlers, adjusters, and investigators
     
  • Service providers and subcontractors assisting us in our operations
     
  • Regulatory or law enforcement bodies when legally required
     

We will provide a full list of third-party recipients upon request. We do not share your information with any unrelated third parties for marketing purposes.


6. Children’s Data

Where we process personal data relating to children, we will ensure a lawful basis for processing. If consent is required, we will take reasonable steps to confirm the child understands the processing or that the individual providing consent has parental responsibility.


7. Requests to Limit Processing

If you ask us to stop processing your personal data, we will explain how this may affect the insurance services we provide. Some data must be retained or processed for legal or regulatory reasons, and we will inform you where deletion or cessation is not possible.


8. Automated Decision Making

TC2 Underwriting does not carry out automated decision-making or profiling that would produce legal or significant effects without human involvement.


9. Data Retention

We retain personal data for at least seven years from the end of the insurance relationship or longer if required for legal, regulatory, or contractual purposes. We do not keep data for longer than necessary.


10. International Transfers

Personal data may occasionally be transferred outside the UK or the European Economic Area. Where this occurs, we ensure appropriate safeguards are in place, such as adequacy decisions, contractual protections, or equivalent mechanisms under data protection law.


11. Non-Core Uses of Personal Data

We do not use personal data for purposes unrelated to insurance activities beyond those outlined in the London Market Core Uses Information Notice.


12. Your Rights Under Data Protection Law

Under the UK GDPR, you have several important rights regarding your personal data:

  • Right to be informed – to receive clear details about how your data is used.
     
  • Right of access – to request a copy of personal data we hold.
     
  • Right to rectification – to correct inaccurate or incomplete information.
     
  • Right to erasure – to request removal of data where no valid reason for retention exists.
     
  • Right to restrict processing – to limit how your data is used.
     
  • Right to data portability – to move your data between service providers.
     
  • Right to object – to processing based on legitimate interests or for direct marketing.
     
  • Rights related to automated decision-making – to protection against decisions made solely by automated systems.
     

13. Access or Updates to Your Personal Data

If your information changes, or if you wish to exercise any of your rights, you can contact us at:
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14. Questions, Requests, or Complaints

If you have any questions about this Privacy Notice or how we process your personal data, please contact:
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If you are unhappy with our response, you may raise a complaint with the Information Commissioner’s Office (ICO):
https://ico.org.uk/

Copyright © 2025 TC² Underwriting - All Rights Reserved.

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