The Ancient Order of Foresters Friendly Society Limited ("we", "us", "the Society") is registered under the Data Protection Act 1998 ("the Act"). References to "we", "us" and "the Society" in this Policy include individual Branches within our Branch network. We also use the trading name Foresters Friendly Society and POIS.
In this Policy, references to "you" means the person whose personal information (as described below) we collect, use and process. This includes anyone who contacts us in connection with our financial products and services, purchases or receives our financial products or services, or otherwise interacts with us (for example, via our website (www.pois.co.uk)).
We are committed to protecting and respecting your privacy and to managing and using your personal information in accordance with the Act.
This Policy describes how your personal information will be used by us. Please read it carefully to understand our practices regarding your personal information and how we will treat it.
What is personal information?
Personal information is information that relates to a living identifiable individual. Essentially, your personal information is information that identifies you and is about you.
Personal information includes, for example, your name, postal address, contact details (including your email and telephone number), date of birth, and details of the products and services you purchase or receive from us. Personal information also includes opinions about you and indications of a person's intentions in respect of you.
The Act distinguishes between personal information and sensitive personal information, with the latter being given greater protection by the Act. Sensitive personal information is defined as personal information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual orientation, or about the commission or alleged commission of any offence, or proceedings for any offence committed or alleged to have been committed by a person, the disposal of such proceedings or the sentence of any court in such proceedings.
Depending on the circumstances (such as the products or services you receive from us), we may need to process sensitive personal information about you (for example, information about your health).
What personal information do we collect about you?
The personal information we collect and hold about you will depend on the relationship we have with you (such as the products or services you receive from us). In particular, we may collect personal information about you in the following circumstances:
- information that you provide (or that is provided on your behalf or about you) in relation to applications for our products and services; this information could include your name, date of birth, gender, postal address, contact details (including your email and telephone number), relationship to any applicant or beneficiary under the products or services, your National Insurance number, bank/payment details, and, where applicable, the declarations you make in connection with that application;
- information contained in our own records, such as details of the products and services you order and receive from or hold with us;
- information contained in emails, letters, telephone calls and conversations with us (we may record telephone calls and conversations for monitoring and training purposes);
- information that we collect during our relationship and dealings with one another (for example, we may collect further information about you if you make a claim pursuant to a product or policy you hold with us);
- information obtained from other organisations, such as credit reference agencies and fraud prevention agencies;
- information that you provide in order to become a registered user of our website; and
- information that you provide in order to become an intermediary affiliated or associated with us.
Who is responsible for the personal information we hold about you?
For the purpose of the Act, the data controller and the person responsible for ensuring that the personal information we hold about you is used in accordance with the Act is The Ancient Order of Foresters Friendly Society Limited of Foresters House, 29-33 Shirley Road, Southampton, SO15 3EW, United Kingdom.
As described in this Policy, your personal information may be shared with other organisations that may receive and process your personal information as data controllers in their own right.
How do we use your personal information?
We will use your personal information in connection with our business activities, including for the following purposes (depending on our relationship with you):
- to process the application for, and provide you with, our financial products and services; depending on the product or service that we are providing to you, we may process your financial information and/or information regarding your health;
- to prevent, detect or investigate fraud or criminal activity and to prosecute offenders;
- to process and administer any claim you make pursuant to a product or policy held with us;
- to process your registration as a member of the Society and administer your membership to the Society;
- to provide you with statements of your account as required, and to communicate with you on any matter relating to the provision of our products or services to you, including to respond to your enquiries or complaints;
- in relation to intermediaries with whom we have a relationship, to provide you with information and updates about our products and services (including updates to our terms and conditions and literature) and to administer your relationship with us;
- to prevent, detect or investigate fraud or criminal activity and to prosecute offenders;
- to carry out market research, training and analysis so that we can develop and improve our products and services;
- to manage and operate our business and to assess risks to our business;
- to send you services communications (you may receive these communications from your Branch);
- in accordance with your preferences, to provide you with information about products, services and events which we feel may be of interest to you (you may receive this information from your Branch);
- to send you newsletters from your Branch (this is in addition to providing you with information about products, services and events in accordance with your preferences as described above); if you no longer wish to receive these newsletters, please send an email to email@example.com;
- to send you our member magazine (this is in addition to providing you with information about products, services and events in accordance with your preferences as described above); if you no longer wish to receive our magazine, please send an email to firstname.lastname@example.org; and
- to allow you to participate in interactive features of our services, when you choose to do so.
Your personal information may also be used for other purposes for which you give your permission, or when required by law or regulatory duty, or in order to enforce or apply any agreement we have with or concerning you, or to protect our rights, property or safety, or those of our customers or others, or where otherwise permitted under the Act.
We may also use aggregate information and statistics for the purposes of monitoring website usage in order to help us develop our website and our products and services, and we may provide such aggregate information to third parties. These statistics will not include information that can be used to identify any individual.
With whom do we share your personal information?
In connection with the above purposes, your personal information may be shared with our affiliates, agents, auditors, advisers, subcontractors, service providers, underwriters and persons with whom we have a business relationship. For example, we use mailing houses to send communications on our behalf. Your personal information will also be shared with the secretaries of your Branch.
We may disclose your personal information to credit reference agencies in order to enable us to use the services offered by the credit reference agency to assist us to detect and prevent crime, fraud and money laundering, and to verify your identity. The credit reference agency will add a note to your reference file to show that a check has been made.
We may disclose your personal information to third parties (including law enforcement authorities, HM Revenue & Customs, regulatory bodies and the courts) if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation, or in order to enforce or apply any agreement we have with or concerning you, or to protect our rights, property or safety, or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of prevention or detection of fraud and criminal activity and credit risk reduction.
If you make a claim under any insurance policy you hold with us, your personal information may be put onto a register of claims and shared with other insurers to prevent and detect fraudulent claims. We may also disclose your information to our agents and service providers and other insurers to investigate or prevent fraud and criminal activity.
Where an application for our products or services is made via a financial adviser on your behalf, your personal information relevant to that application may be disclosed to that financial adviser until you instruct us otherwise.
From time to time we may provide your personal information to our customer service agencies for research and analysis purposes so that we can monitor and improve the products and services that we provide. We, or our agents and subcontractors, may contact you to ask for your feedback and comments on our products and services. If you do not wish us to use your personal information in this way, please send an email to email@example.com.
In accordance with your preferences, we may share your personal information with third parties who provide complimentary financial products and services to our own so that they can provide you with information about products and services which may be of interest to you.
We may in the future wish to sell or merge part or all of our business or assets, or acquire a business or enter into a merger with it. In these circumstances, we may disclose your personal information to a potential buyer, merger partner or seller and their advisers. If the transaction goes ahead, the buyer or merger partner may use your personal information in the same way as set out in this Policy.
We may also disclose your personal information to third parties where it is necessary to do so and this is permitted by law.
How do we look after your personal information?
Our internal procedures cover the storage, access and disclosure of your personal information.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us via the internet; any transmission is at your own risk.
Once we have received your personal information, we will use specific procedures and security features to try and prevent unauthorised access.
What rights do you have with respect to your personal information?
You have certain rights with respect to your personal information pursuant to the provisions of the Act.
The Act gives you the right to access personal information held about you. Your right of access can be exercised in accordance with the Act.
If you wish to make a subject access request under the Act relating to the personal information held about you by the Society, please write to The Compliance Manager, 29-33 Shirley Road, Southampton, Hampshire, SO15 3EW, United Kingdom. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the personal information we hold about you.
You have the right to ask us not to process your personal information for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
If you believe that the personal information we hold about you is inaccurate or incorrect, please let us know by contacting us at email@example.com and, if appropriate, we will correct it.
Personal information provided by you about another person
If you provide us with personal information about another person (such as a beneficiary under one of our products) then you should not do so without their permission. Where you provide personal information about another person to us, or another person provides personal information about you to us, it will be used in the manner described in this Policy.
Linking to third party websites
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates and other third parties. If you follow a link to or from any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the use of your personal information by these websites. Please check these policies before you submit any personal information to these websites.
Changes to this Policy
We may revise this Policy at any time. Please make sure you check this page (www.pois.co.uk/privacy-policy) from time to time so that you are aware of how we use your personal information.
This Policy was last updated on 27 September 2014.
How to Contact Us