Privacy Statement

Napier Lane Associates Limited (we, us, our, Napier Lane) is the owner and operator of www.napierlane.com (the Site).  We are committed to protecting and respecting your privacy.  We design and manage bespoke, outsourced employee benefit programmes.  We pride ourselves on quality, service and relationships and are committed to protecting and respecting your privacy through your interactions with us and when you use our Site.  We are registered with the Information Commissioner’s Office (ICO) under registration number ZA239458.

This privacy notice tells you what to expect us to do with your personal information.

Napier Lane is the controller of your personal information.  This means Napier Lane decides why and how your personal information is processed.  Our contact details are provided below.

This Privacy Notice may change from time to time so please check this Privacy Notice occasionally to ensure that you are happy with any changes.  This Privacy Notice was last updated on the date set out at the end of this Notice.

 

1. Contact Details

Our contact details are provided below:

Post:
71-75 Shelton Street, London, WC2H 9JQ, GB

Telephone:
+44 207 998 3678

Email:
michelle@napierlane.com

Website:
www.napierlane.com

2. What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

  • Names and contact details

  • Addresses

  • Gender

  • Occupation

  • Date of birth

  • Marital status

  • Third party information (such as family members or other relevant parties)

  • Payment details (including bank information for transfers and direct debits)

  • Financial data (including income)

  • Transaction data (including details about payments to and from you and details of products and services you have purchased)

  • Usage data (including information about how you interact with and use our website, products and services)

  • Employment details (including salary, sick pay and length of service)

  • Health information (such as medical records or health conditions)

  • Information relating to compliments or complaints

  • Video recordings

  • Audio recordings (e.g. calls)

  • Records of meetings and decisions

  • Account access information

  • Website user information

We collect or use the following personal information for the operation of client or customer accounts:

  • Names and contact details

  • Addresses

  • Purchase or service history

  • Account information, including registration details

We also collect or use the following information for the operation of client or customer accounts:

  • Health information

We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:

  • Names and contact information

  • Financial information e.g. for fraud prevention or detection

We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details

  • Address

  • Payment details

  • Account information

  • Purchase or service history

  • Call recordings

  • Customer or client accounts and records

  • Information relating to health and safety (including incident investigation details and reports and accident book records)

  • Correspondence

We also collect or use the following information for dealing with queries, complaints or claims:

  • Health information

 

3. Lawful basis and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website: 

If you make a request, we will respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

4. Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

    • Processing required to design and manage outsourced bespoke employee benefit programmes dependent on employee needs, analyse business strategies, prevention of fraud, to inform clients of updates to our terms and conditions and policies, for general administration including queries, complaints, claims, help and support.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

    • Processing required to design and manage outsourced bespoke employee benefit programmes dependent on employee needs, analyse business strategies, prevention of fraud, to inform clients of updates to our terms and conditions and policies, for general administration including queries, complaints, claims, help and support.

Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

    • Processing required to design and manage outsourced bespoke employee benefit programmes dependent on employee needs, analyse business strategies, prevention of fraud, to inform clients of updates to our terms and conditions and policies, for general administration including queries, complaints, claims, help and support.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

    • Processing required to design and manage outsourced bespoke employee benefit programmes dependent on employee needs, analyse business strategies, prevention of fraud, to inform clients of updates to our terms and conditions and policies, for general administration including queries, complaints, claims, help and support.

5. Where we get personal information from

  • Suppliers and service providers

  • Third parties:

    • Policyholders

  • Information contained in or relating to any communication that you send to us or send through our site

6. How long we keep information

The length of time we retain your personal information is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.  We do not retain personal information in an identifiable format for longer than is necessary.

We may need your personal information to establish, bring or defend legal claims.  For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under paragraph 2 above (What information we collect, use and why).  The only exceptions to this are where:

  • the law requires us to hold your personal information for a longer period, or delete it sooner;

  • you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see paragraph 3 (Lawful bases and data protections rights) above); or

  • you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see paragraph 3 (Lawful bases and data protection rights) above).

7. Who we share information with

Others we share personal information with:

  • Insurance companies, brokers or other intermediaries

  • Professional or legal advisors

  • Organisations we’re legally obliged to share personal information with

  • Suppliers and service providers

8. Where we store your personal information

Where permitted by applicable law, we may transfer your personal information to jurisdictions outside of the UK for the purposes set out in this privacy notice.  We will implement appropriate safeguards to secure the transfer of your personal information to jurisdictions outside the UK.  These safeguards include:

  • relying on declarations made by regulators or governments (e.g. adequacy decisions/regulations);

  • where the third country where data is being sent is not subject to such declaration, the standard contractual clauses approved by relevant regulators or governments, as applicable;

  • ensuring that the recipients are subscribed to international frameworks; or

  • such alternative measures as are valid and appropriate at the time.

If you use our services whilst you are outside the UK, your information may be transferred outside those territories in order to receive those services.

9. How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

 

Last updated:
07 February 2025