1. Who we are
Rob Spence Ltd, trading as RSL Claims (“we”, “us”, “our”), is an independent loss assessor and insurance claims management company. We are the data controller responsible for the personal information described in this policy.
- Company: Rob Spence Ltd
- Trading as: RSL Claims
- Registered office: 38 Birkenhead Road, Hoylake, Wirral, CH47 3BW
- Phone: 0151 632 6050
- Email: [email protected]
- ICO registration number: Z1637152
- FCA reference number: 305956
- Data Protection Officer: Amy Groome ([email protected])
2. What information we collect
Depending on how you interact with us, we may collect:
Identity and contact details
- Name, address, email, phone number
- Date of birth (where required for identity verification)
Policy and claim details
- Insurance policy information and policy schedule
- Details of the incident, damage, and loss being claimed
- Photographs, videos, surveys, and reports relating to the claim
- Correspondence with you, your insurer, and any third parties involved in the claim
Financial information
- Bank account details (for receiving settlement payments)
- Invoice and payment records
Property information
- Property address, type, valuation, and condition
Technical information (collected via our website)
- IP address, browser type, device type, pages visited
- See our Cookie Policy for details on cookies and tracking
Communications
- Records of phone calls (call recordings retained for 12 months)
- Emails, messages, and contact form submissions
Marketing preferences
- Whether you have opted in to receive marketing communications
We do not deliberately collect special category data (such as health, race, religion, or sexual orientation) unless it is directly relevant to your claim and you have provided it to us.
3. How we use your information and our lawful basis
Under UK GDPR, we must have a lawful basis for using your personal information. The basis depends on the purpose:
| Purpose | Lawful basis |
|---|---|
| Providing loss assessing and claims management services to you | Performance of a contract |
| Communicating with your insurer, surveyors, contractors, and other parties on your behalf | Performance of a contract |
| Sending you service-related updates about your claim | Performance of a contract |
| Keeping records for accounting, tax, and regulatory purposes (including FCA reporting) | Legal obligation |
| Improving our website and services, analysing usage patterns | Legitimate interests (running our business effectively) |
| Marketing communications to existing clients about related services | Legitimate interests (with the right to opt out at any time) |
| Marketing communications to new prospects | Consent (opt-in) |
| Handling disputes, complaints, or legal claims | Legitimate interests / legal obligation |
| Verifying identity to prevent fraud | Legitimate interests / legal obligation |
You have the right to object to processing based on legitimate interests. See section 7.
4. Who we share your information with
We share your information only where necessary to handle your claim or run our business. Categories of recipients include:
- Your insurer and any loss adjuster they appoint
- Surveyors, structural engineers, and other expert consultants appointed to investigate or document your claim
- Contractors and tradespeople who carry out repairs or restoration work
- Solicitors and barristers, if your claim becomes contentious
- Our accountants and auditors, for financial and regulatory reporting
- IT and software providers, including our website host, email provider, and customer-management systems
- Regulators and law enforcement, where we are legally required to disclose (for example, the FCA or HMRC)
- Professional bodies (CII, CILA, FUEDI) where required for membership or oversight
We do not sell your personal information to anyone.
All third parties we share data with are required to keep your information secure and to use it only for the purposes we have agreed.
5. International transfers
Some of the third-party services we use may store or process information outside the UK and European Economic Area (EEA). Where this happens, we make sure appropriate safeguards are in place, either an adequacy decision recognised by the UK Government, or standard contractual clauses approved by the Information Commissioner’s Office (ICO).
6. How long we keep your information
We keep your information only for as long as we need it, then securely delete it. Typical retention periods are:
| Type of information | How long we keep it |
|---|---|
| Active claim records | For the duration of your claim plus 6 years (in line with FCA record-keeping and limitation period requirements) |
| Unused contact data (enquiries that don’t proceed to instruction) | 12 months, then automatically deleted |
| Call recordings | 12 months |
| Accounting and tax records | 6 years (HMRC requirement) |
| Marketing contacts (opted in) | Until you withdraw consent or unsubscribe |
| Website analytics | See Cookie Policy |
7. Your rights under UK GDPR
You have the following rights regarding your personal information:
- Right of access – to ask for a copy of the personal information we hold about you
- Right to rectification – to ask us to correct information that is inaccurate or incomplete
- Right to erasure (“right to be forgotten”) – to ask us to delete your information in certain circumstances
- Right to restrict processing – to ask us to limit how we use your information
- Right to data portability – to ask us to provide your information in a portable format, or to transfer it to another provider
- Right to object – particularly to direct marketing, and to processing based on legitimate interests
- Rights regarding automated decision-making– we do not currently make decisions about you using only automated means
We will respond to any request within one calendar month. There is no charge for exercising your rights, unless the request is unfounded, excessive, or repetitive.
How to exercise your rights: Email [email protected] or write to us at the address in section 1.
8. Marketing communications
We will only send you marketing communications where:
- You have given us consent (for new contacts who have not previously instructed us), or
- You are an existing client and the communication is about services related to ones we have already provided you (legitimate interests, with the right to opt out)
You can unsubscribe at any time using the link in any marketing email, or by emailing [email protected].
We will not pass your information to third parties for their marketing purposes without your explicit consent.
9. How we protect your information
We take the security of your personal information seriously. We use appropriate organisational and technical measures to protect it from unauthorised access, accidental loss, alteration, or disclosure. These include:
- Restricted access to client records (staff only, on a need-to-know basis)
- Encrypted email and secure file transfer for sensitive documents
- Secure cloud backup and password-protected systems
- Confidentiality agreements with all staff and contractors
If a personal data breach occurs and there is a risk to your rights and freedoms, we will notify the ICO within 72 hours and inform you directly where the law requires it.
10. Children’s privacy
Our services are aimed at adult policyholders and businesses. We do not knowingly collect personal information from anyone under the age of 16. If you believe we have collected information about a child, please contact us and we will delete it promptly.
11. Cookies
Our website uses cookies and similar tracking technologies. These are explained in detail in our separate Cookie Policy, including which cookies we use, what they do, and how you can manage your preferences.
12. Changes to this policy
We may update this policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. The “Last updated” date at the top of this page will always show when it was last changed. We encourage you to review it periodically.
13. How to contact us, and how to complain
For any questions or to exercise your rights:
- Email: [email protected]
- Phone: 0151 632 6050
- Post: Rob Spence Ltd, 38 Birkenhead Road, Hoylake, Wirral, CH47 3BW
If you are not satisfied with how we have handled your personal information, you have the right to complain to the Information Commissioner’s Office (ICO):
- Website: www.ico.org.uk
- Phone: 0303 123 1113
- Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
We would, however, appreciate the chance to address your concerns first, so please consider contacting us before approaching the ICO.