Your privacy matters to us - not as a legal formality, but because trust is the basis of everything we do. This notice explains, in plain language, what information we hold about you, why we hold it, who we share it with, and the rights you have over it.
Contents
- 1 · Who we are
- 2 · What this notice covers
- 3 · The information we collect
- 4 · Health information
- 5 · How and why we use it
- 6 · Who we share it with
- 7 · International transfers
- 8 · How long we keep it
- 9 · Cookies
- 10 · Marketing
- 11 · How we protect it
- 12 · Automated decisions
- 13 · Your rights
- 14 · Contact & complaints
- 15 · Changes to this notice
1Who we are
Private Health Partners Ltd ("we", "us", "our") is a specialist private medical insurance intermediary. We are the data controller of the personal information described in this notice, which means we decide how and why it is used.
Registered in England & Wales, company number 17199113. Registered office: Commerce House, Carlton Boulevard, Lincoln LN2 4WJ. ICO registration number: ZC229742. Authorised and regulated by the Financial Conduct Authority, Financial Services Register number 1057326.
Privacy questions should be directed to [email protected] or by post to our registered office, marked for the attention of the Data Privacy Lead.
2What this notice covers
This notice covers personal information we collect through this website (including our enquiry form, telephone, email and WhatsApp), and information we collect and use in the course of providing our advice and arranging private medical insurance. It applies to prospective clients, clients, the people named on their policies, and visitors to this website.
Where you give us information about other people - for example, family members or employees to be covered under a policy - you should make sure they are aware of this notice.
3The information we collect
When you enquire through this website
Our enquiry form collects your name, age, telephone number, email address and postcode (or, for company enquiries, the scheme size and a key contact's name, number and email), whether you currently hold private medical cover and with which insurer, and anything you choose to tell us in the message box. We deliberately do not ask for health information through this website.
When we advise you
To recommend and arrange cover we will typically collect: identity and contact details; details of the people to be insured; occupation and lifestyle details relevant to underwriting; existing and previous policy details; premium and payment information (we do not hold client money and do not store payment card data); and our records of the advice given, including notes of our conversations. Telephone calls may be recorded for training, quality and regulatory purposes.
Technical information
When you use this website we receive limited technical information necessary to serve it (such as your IP address in server logs held by our hosting provider). We do not run analytics or advertising trackers unless you consent - see Cookies.
4Health information
Because we advise on medical insurance, our work can involve information about your health - for example medical history disclosed for underwriting, or details of a condition when we help you deal with your insurer. Health information is special category data under UK data protection law and is given extra protection.
We process it only where a condition under Article 9 UK GDPR and Schedule 1 of the Data Protection Act 2018 applies - principally the insurance purposes condition (Schedule 1, Part 2, paragraph 20), which exists precisely so that insurance can be advised on and arranged, and, where required, your explicit consent. Where we rely on your explicit consent you may withdraw it at any time, although this may mean we cannot continue to advise you or assist with your policy.
We hold an appropriate policy document for this processing, as the Data Protection Act 2018 requires.
5How and why we use your information
UK GDPR requires a lawful basis for everything we do with your information. These are ours:
| What we do | Lawful basis |
|---|---|
| Responding to your enquiry and arranging your free consultation | Legitimate interests (responding to a request you initiated); steps at your request prior to entering a contract |
| Advising on, arranging and renewing your cover; helping you deal with insurers, including at claim | Performance of our contract with you; for health data, the conditions in section 4 |
| Meeting our legal and regulatory obligations, including FCA record-keeping, complaints handling and financial crime prevention | Legal obligation |
| Reviewing your cover and contacting you about renewal | Performance of our contract; legitimate interests |
| Sending marketing about our services (only where permitted) | Consent, or the "soft opt-in" for existing clients - see section 10 |
| Improving this website (analytics) | Consent - see section 9 |
| Establishing, exercising or defending legal claims | Legitimate interests |
Where we rely on legitimate interests we balance them against your rights, and we will not use your information where your interests override ours.
Call recording
We record all calls with you. We do this so we can show the advice we gave you was suitable, check the quality of our service, train and supervise our advisers, and deal with any complaint. Recordings and transcripts may include health information you tell us. We check calls for quality using software, including artificial intelligence, that compares what was said against our call standards. A member of our team always makes the final decision. Nothing about you is decided by the software alone.
6Who we share it with
We never sell your information. We share it only where necessary, with:
- Insurers and underwriters - to obtain quotations and arrange, service and renew your cover;
- Service providers acting on our instructions - including our website hosting provider; Web3Forms, which relays website enquiry submissions to our mailbox; our email provider; WhatsApp (Meta Platforms), where you choose to contact us on our business WhatsApp; our telephone system provider; and our compliance consultants;
- Regulators, ombudsmen and law enforcement - including the Financial Conduct Authority, the Financial Ombudsman Service and the Information Commissioner's Office, where we are required or permitted to do so;
- Professional advisers - such as our lawyers, accountants and auditors, under duties of confidentiality;
- Service providers who work for us under contract, including:
- telephony and call recording providers
- IT, software and secure hosting providers
- artificial intelligence service providers that help us check call quality
- Meta Platforms Ireland Limited - only if you choose "Accept all" on our cookie banner, in which case the Meta Pixel sends Meta information about your visit to this website (see Cookies). For that information Meta and we are joint controllers, and Meta also uses it for its own purposes under its own privacy policy. We do not send Meta your name, contact details or anything you enter into our enquiry form;
- A buyer or successor - if our business is sold or reorganised, in which case your information would remain protected by this notice.
Each provider is contractually bound to protect your information and to use it only on our instructions.
7International transfers
We keep your information in the United Kingdom wherever possible. Some of our service providers - for example WhatsApp (Meta) and certain telephony, hosting and email services - process information outside the UK, in the European Union and the United States. When this happens we make sure your information is protected by approved safeguards, such as a UK adequacy decision, the UK International Data Transfer Agreement, or the UK International Data Transfer Addendum to the EU Standard Contractual Clauses. You can ask us for more detail about these safeguards using the contact details in this notice.
8How long we keep it
| Information | Retention period |
|---|---|
| Enquiries that do not become a client relationship | 12 months from our last contact, then deleted |
| Client files, advice records and policy documentation | 6 years after the relationship ends, in line with FCA record-keeping expectations and limitation periods |
| Financial and accounting records | 6 years, as required by law |
| Cookie consent record | 6 months, in your own browser - see section 9 |
When information is no longer needed we delete it securely or fully anonymise it.
9Cookies
This website uses the strictly necessary cookies it needs to function. Your cookie choice itself is stored in a single first-party cookie (php_consent) in your own browser for six months; it never leaves your device and is not shared with anyone.
With your consent, we also use the Meta Pixel, a tool provided by Meta Platforms Ireland Limited. It sets cookies in your browser (including _fbp) and tells Meta that your browser visited pages on this website. We use it to measure whether our advertising on Facebook and Instagram brings people to this site, and to show our advertising to people who have visited it. Meta may link this information to your Facebook or Instagram account if you have one, and uses it for its own purposes as described in Meta's privacy policy.
The Meta Pixel loads only if you choose "Accept all" on our cookie banner. If you choose "Essential only" or "Decline", it does not load and nothing is sent to Meta. You can change your choice at any time using the Cookie preferences link in the footer of our website, and you can also control how Meta uses information about you through your Facebook or Instagram ad settings.
We do not use any other analytics or marketing cookies.
10Marketing
We will only send you marketing where you have consented, or where you are an existing client and the message relates to similar services of ours (the "soft opt-in" permitted by the Privacy and Electronic Communications Regulations). Every message will include a simple way to opt out, and you can opt out at any time by contacting us - we will action it promptly.
We do not share your information with anyone else for their marketing.
11How we protect it
We apply technical and organisational measures appropriate to the sensitivity of what we hold, including encryption in transit, access restricted to those who need it, reputable UK-facing providers, offline and off-site backups, and staff confidentiality obligations. No client money is held and no payment card data is stored, which materially limits our exposure. If a breach were ever to put your rights at risk, we would notify the ICO and, where required, you, in line with our legal duties.
12Automated decisions
We do not make decisions about you by wholly automated means, and we do not profile you. Any recommendation we make is made by a qualified adviser. Insurers may use their own underwriting processes; their privacy notices explain these.
13Your rights
You have the right to:
- Access - ask for a copy of the information we hold about you;
- Rectification - have inaccurate or incomplete information corrected;
- Erasure - ask us to delete information, where no legal duty requires us to keep it;
- Restriction - ask us to pause our use of your information in certain circumstances;
- Portability - receive information you gave us in a reusable format;
- Objection - object to processing based on legitimate interests, and to any direct marketing at any time;
- Withdraw consent - wherever our processing relies on it, without affecting what was done beforehand.
To exercise any right, contact us using the details in section 1. There is no fee, and we will respond within one month. We may need to verify your identity first.
14Contact & complaints
If you have any question or concern about how we handle your information, please contact us first at [email protected] - we take this seriously and will do our best to resolve it.
You also have the right to complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.
15Changes to this notice
We review this notice regularly and will update it when our practices or the law change. Material changes will be highlighted on this page.