Privacy Policy

Privacy Policy

We are committed to ensuring your privacy is protected.


Baxters take the protection of your privacy and the confidentiality of any personally identifiable information, seriously. The purpose of this Privacy Policy is to make you aware how and why we collect and control and process your personal data, both before, during and after our contract with you. 

Personal Information means any information that may be used to identify an individual, which may include, but not be limited to your first and last name, your address, an email address of any other information which may identify you.

In line with data protection legislation, data can only be processed lawfully if done so in compliance with one of the six conditions listed below;

1. Contract – necessary for the performance of a contract

2. Legal Obligations – where there is a legal, or regulatory requirement

3. Vital Interest – necessary to protect a person’s life

4. Public Interest – necessary for tasks deemed in the public interest

5. Legitimate Interests – use of data in a way reasonably expected, with minimum privacy impact, or with compelling justification

6. Consent – Active opt-in, with a real choice and opt-out at any time

We have considered these conditions and will process data on the basis of the lawful conditions in line with our business as an insurance broker and independent financial adviser. As Baxters offer both insurance and financial services advice, it may be possible that not all examples shown within this Privacy Policy will apply to the services provided to you.

This Privacy Policy is to be read in conjunction with your Terms of Business Agreement with us.


How we collect your Personal data

We will collect information from you, either in person, over the phone, or by electronic communication. We may also receive information from the following sources;

• Insurers and their agents

• Your family members, employers or your representatives

• Generally available sources, such as information about you in the public domain

• Searches that we undertake in relation to sanctions, money laundering and credit reference agencies

• Government agencies such as the DVLA and HMRC

• In relation to claims, third parties including other parties to the claim (the claimant/defendant), experts (including medical experts), loss adjusters, solicitors 

Please also note that telephone calls may be recorded, or monitored, to improve our service and for security and regulatory purposes.

We will only process your Personal Data obtained, or received, from any of the above sources, or indeed from elsewhere, to the extent necessary where we have legitimate interest in relation to your requirements for insurance or financial services advice.


What Data do we collect

We will collect data, including, but not limited to, personal information and risk details, solely to enable us to provide advice in relation to your insurance and financial services needs, quotations and to allow us to arrange and administer your insurance and financial services requirements. Such data may include, but not limited to, the following;

• your name, address, telephone number and personal email address, marital status, date of birth

• financial information

• identification details (i.e. passport, driving licence details)

• previous and current claims

We may also collect ‘special categories’ of personal data about you and other parties to your insurance and financial services requirements. This information may include information about your health, ethnic or racial origin, trade union membership, criminal convictions and other categories as defined within the General Data Protection Regulation. We will only collect and use special categories of personal data when the law or regulatory requirements, require us to do so, or where it is required to fulfil our service to you as detailed above.

Data collected by us is contractual and for our legitimate business interest as an insurance broker and independent financial adviser and we may be unable to offer any quotation or insurance if you refuse to provide certain personal data, which is collected under the lawful basis of public interest, where these would affect the provision of cover and/or performance of such contracts.


How we will use your information

Your information will be held securely by us and we have put in place measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage. Your personal data may be stored within our IT systems, our Data Processors systems, or on our premises.

We also have procedures in place to deal with a suspected data security breach and will notify the Information Commissioners Office (ICO) and you of a suspected breach where we are legally required to do so.

Your personal data will only be used to allow us to fulfil our contractual obligations and our legitimate business interest of providing insurance quotations, independent financial advice, arranging contracts of insurance and any other risk management or financial advice services that we may provide.

We will use your information to;

• assess your requirements and your demands and needs

• prepare and present details to insurers/providers for the purpose of obtaining quotations and securing cover

• manage your contracts which we have arranged on your behalf

• process claims

• arrange premium finance agreements

• satisfy any legal, regulatory, or professional governing body obligation

• analyse data and to allow us to identify other services that may be of interest to you

We will only use your personal data for the legitimate business purposes for which we collect and retain it. If we wish to use your data for any other purpose, we will seek your approval prior to processing.


Sharing of personal data

The information that you provide and which we obtain from parties mentioned above, will be accessible by all relevant employees of W B Baxter Ltd for use as detailed in this Privacy Policy.

We share information with insurers, and other product providers, which could include reputable providers in other countries, who may in turn share this data with various anti-fraud databases, such as the Claims and Underwriting Exchange (CUE) as well as publicly available websites and credit referencing agencies in the conduct of their activities to provide insurance cover or investment or protection policies on your behalf.

We may also share the information you provide with other organisations that perform activities on our behalf. These may include, but not be limited to the following;

• other insurance providers such as Wholesale Brokers or Managing General Agencies

• loss adjusters and other claims handlers or parties involved in the processing of any claim

• premium finance companies

• sanctions checking agencies and fraud prevention agencies

• our regulators and supervisory authority (for example the Financial Conduct Authority – FCA and the Information Commissioners Office – ICO)

Your data will also be held on our IT systems provided, or hosted, by third party software providers for the sole purpose of conducting our business activities on your behalf.

We will not give anyone else your personal information, except on your instructions or authority, or where we are required to do so by law, or our regulatory requirements. 



As an existing client of Baxters, we may contact you about relevant products and services that we can offer, which we believe may be of interest to you as part of your potential insurance, risk management or financial services requirements. We will only do so where we consider these to be of legitimate interest to you.

If you were a previous client, but ceased to have a relationship with us, or if we have held data from you before for the purposes of securing insurance quotations, we will retain your data for a period not exceeding 3 years from the date of our last contact or engagement with you and will use this data to contact you to provide news, or information relating to our business and the insurance market, which we believe may be of legitimate interest to you.

We of course respect your privacy and in any communication we have with you, we will remind you of your right to opt out of future marketing related communications we send to you.


How long will we hold your data?

We will retain your data for as long as necessary to meet the purposes for which it was originally collected, subject to our legal and regulatory requirements, or to enable us to manage our legitimate business interest.


Our Website and Cookies

Our website places cookies (text files) on your computer. The cookies contain a reference which is used to uniquely identify your browser and track each site you visit that has Google Analytics enabled. 

We use the information provided by cookies to determine the number of people visiting our website. It helps us to understand how people use our website. This information can then be used to help us improve our website and service to our browsers.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information, which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Cookies [via Google Analytics] store the following data;

• time of visit

• pages visited

• time spent on the website

• referring domains (which domain a user may have come from to enter our website)

• web browser type

• operating system type

• device type

• geographic location of IP address

• Any links followed

If you already have Google Analytics cookies, they will be updated with the latest information about your visit to our website. We cannot access these cookies and are not the data controller for information held by Google Analytics.

Your consent is generally required for cookies to be placed on your computer and for the use and storage of personal information, relating to you provided by the cookies. You may withdraw your consent at any time by updating your cookie settings.

The use and storage of any personal information provided by the cookies will be based on legitimate interests. The legitimate interests are relating to the operation of our website and general promotion of our business and services.


Your rights in connection with your Personal Data

You have a number of rights relating to your personal data, which will include the right to ask for, see and correct, personal information about you that we hold. You may also request us to restrict the processing of your personal data, object to the processing of your personal data, or request the erasure of your personal data. Any such requests will be considered in line with the legitimate and lawful purpose for which we hold and use your data.  

Should you wish to exercise any of these rights, or if you have any questions about the use of your data please write to our Data Protection Officer, David Stingemore, who may be contacted by email on, or by letter addressed to David Stingemore, W B Baxter Ltd, 263 Cranbrook Road, Ilford, Essex, IG1 4TG.


This version of the privacy notice was last updated on 24 May 2018.