Terms of Business

Patton Insurance Ltd trading as Harte Insurance
TERMS OF BUSINESS
EFFECTIVE FROM 23rd MARCH 2026 UNTIL FURTHER NOTICE

These Terms of Business set out the basis on which Harte Insurance will provide services to you, our valued client. By proceeding with your policy through Harte Insurance you agree to the terms as per this Terms of Business document. Please ensure that you have BOTH READ AND UNDERSTOOD these terms and if there are any aspects you don’t understand or if you have any queries whatsoever, please don’t hesitate to contact us. This Terms of Business document supersedes with immediate effect any others that we have previously issued to you. Your direction to bind cover and/or your payment related to your insurance placement will be deemed your full, informed, agreement to be bound by the provisions of this Terms of Business Agreement.

ABOUT HARTE INSURANCE
Patton Insurance Ltd trading as Harte Insurance is regulated by the Central Bank of Ireland.

Address:25 A Academy Court, Oliver Plunkett Road, Letterkenny, Co Donegal. Telephone Number: 074 91 26243.

Email information@harteinsurance.ie

REGULATORY & AUTHORISED STATUS

Patton Insurance Ltd trading as Harte Insurance is Regulated by the Central Bank of Ireland and as an Insurance Intermediary under the European Communities (Insurance Distribution) Regulations 2018. Our status as an Insurance Intermediary can be verified by checking the registers held by the Central Bank of Ireland on their website: www.centralbank.ie.
Harte Insurance is also authorised by the Competition and Consumer Protection Commission as a Credit Intermediary.

CODES OF CONDUCT

Harte Insurance is subject to and complies with the following Central Bank of Ireland Codes of Conduct: Consumer Protection Code, Minimum Competency Code, Insurance Distribution Regulations, Supervision & Enforcement (Section 48) Consumer Protection Regulations, Standards for Business Regulations and the Fitness & Probity Standards. These codes offer protection to consumers and can be found on www.centralbank.ie

REGULAR REVIEWS

You should keep your insurance arrangements under review as there may be other alternatives in the market that could provide savings for you for similar cover. The Competition and Consumer Protection Commission’s website provides guidance on what to look out for when getting general (non-life) insurance quotes: https://www.ccpc.ie/consumers/money/insurance/getting-insurance-quotes/

CONSUMER INSURANCE CONTRACTS ACT 2019: New Business and Renewal

All consumer insurance contracts are governed in accordance with the Consumer Insurance Contracts Act 2019 (CICA), which can be found on: irishstatutebook.ie.

The Consumer Insurance Contracts Act 2019 does not apply to non-Consumer Clients who are defined as a Company (including as a member of a Group of Companies) with a turnover of greater than €5 million in the previous financial year.

The Consumer Insurance Act 2019 (the Act) applies where a policy holder is a consumer as per the definition set out below;

Definitions

The following are set out in the Act;

1. Natural person, not acting in the course of business
2. Sole trader, partnership, trust club or charity (not being a body corporate, with an annual turnover in the previous financial year
of €5 million or less
3. An incorporated body that;
i. Had an annual turnover in its previous financial year of €5 million or less; and
ii. Is not a body corporate that is a member of a group of companies with a combined annual turnover in the previous
financial year greater than €5 million

That

1 is a consumer of a financial services provider
2 is a person or body to whom a financial services provider has offered to provide a service; or 3 has sought the provision of a financial service
A consumer who was, in relation to a credit agreement, a customer of the
financial service provider in a case where a credit service firm undertakes credit servicing in respect of the credit agreement concerned
an actual or preferred beneficiary of a financial service or an employee or a former employee entitled to benefit from an income

Consumer-duty not to make a misrepresentation

If you are a consumer as defined by the Financial Services and Pensions Ombudsman Act you must answer all questions posed by us or the insurer honestly and with reasonable care so as not to make a misrepresentation to insurers. Failure to comply this duty may mean that the policy is void and the insurer may not be liable to pay all or some of your claim. Specific questions will be asked. Where you do not provide additional information (after being asked to do so) it can be presumed that the information previously provided remains unchanged.

Commercial Clients – non-consumers duty to disclose material facts

It is your responsibility to fully disclose all material facts. A material fact is any information which may influence the insurer the judgement of the insurer in deciding whether to accept the insurance and the terms to apply. You must provide complete and accurate information to insurers throughout the period the policy is in force, and when you are renewing it. It is important that you ensure that all information provided and all statements made on proposal forms, claim forms and other documents are complete and accurate to the best of your knowledge and belief. Failure to disclose any material information could invalidate your insurance and result in all or part of a claim not being paid.

CONSUMERS: DUTY OF DISCLOSURE WHEN COMPLETING DOCUMENTATION FOR NEW BUSINESS, RENEWALS AND MIDTERM ALTERATIONS

Section 8 and Section 14 (1) – (5) of the Consumer Insurance Contracts Act, outlines the Consumers Duty of Disclosure:
• You are required to answer all questions posed by us or the Insurer honestly and with reasonable care – the test will be that of the ‘Average Consumer’. ‘Average Consumer’ as per Directive No. 2005/29/EC of the European Parliament and of the Council of 11 May 2005, is reasonably well-informed and reasonably observant and circumspect considering Social, Cultural and Linguistic factors.
• Specific questions will be asked. Where you do not provide additional information (after being requested to do so) it can be presumed that the information previously provided remains unchanged.

An Insurer may repudiate liability or limit the amount paid on foot of the contract of insurance, only if it establishes that non-disclosure of material information was an effective cause of the Insurer entering into the relevant contract of insurance and on the terms on which it did.
Failure to comply with your duty to answer questions honestly and with reasonable care could result in your policy being void.

Completed Proposal Forms / Statement of Fact

Completed Proposal Forms or Statement of Facts will be provided to you. These are important documents as they have been relied on by the insurer in considering whether to provide cover and the terms and conditions to apply You should review and confirm that the answers contained within are true and accurate. If any of the answers are not true and accurate please contact our office immediately. Any corrections that are deemed necessary may result in the risk being resubmitted to the Insurer whose Premium and / or Terms and Conditions may be subject to change as a result.

Non-Consumer Clients: Disclosure of Information

It is essential that you bring to our attention any material alteration in risk such as change of address or use of premises. Any failure to disclose material information may invalidate your claim and render your policy void.

SERVICES PROVIDED

Harte Insurance is an Insurance Broker and a Credit Intermediary. As an Insurance Broker, we are in a position to place your business with a wide range of product producers in the Irish & European Insurance markets. We don’t have a ‘tied’ relationship with any product producer which would compromise our ability to provide you with qualified advice and choice. You must inform us immediately of any changes in circumstances which may affect the services provided by us or the cover provided by your policy. If you are unsure about any matter, please contact us for guidance. A full list of insurers, product producers and premium finance providers is available on request. We arrange insurance in respect of motor, home, farm, commercial vehicle, motor fleets and commercial insurances including liability, shops, offices, pubs, hotels and garages, travel, pet and gadget insurance.

PRODUCTS

Our authorisations enable us to provide our customers with a wide range of non -life Insurance products.

RECEIVE and TRANSMIT ORDERS

We can receive and transmit orders, on your behalf, for products from each insurance company with whom we hold an agency. A list of our current product producers is available on request from our office or on our website harteinsurance.ie

FAIR and PERSONAL ANALYSIS

We provide all our services on the basis of a fair and personal analysis of the market. This means we will research the market on your behalf and recommend the product(s) that, in our professional opinion, are best suited to your own needs and objectives.

FAIR ANALYSIS vs. LIMITED ANALYSIS

We will advise you on either a fair analysis or a limited analysis basis. A fair analysis of the market means assessing a sufficiently large number of product providers and insurance contracts to recommend a policy that best meets your needs. In contrast, a limited analysis of the market means our advice is based on a limited number of providers and products, although we are not tied to any single insurer. Most of our services are provided on a fair analysis basis.

In order to ensure that the number of contracts and providers is sufficiently large to constitute a fair and personal analysis of the market we will consider the following criteria:

• The needs of the customer
• The size of the customer order
• The number of providers in the market that deal with brokers
• The market share of these providers
• The number of relevant products available from each provider
• The availability of information about the provider
• The quality of the product and service provided by the provider
• Cost and;
• Any other relevent information

REMUNERATION

Harte Insurance is remunerated by a combination of commission and fees.

COMMISSION

We are remunerated by commission paid to us by Product Producers on placing of your insurance business with them. This commission compensates us for the work involved in placing an order and finalising the product with them on your behalf. The amount of commission earned will vary greatly depending on the product type and the product producer. Details of the commission earned by us on your policy will be disclosed to you at your request. Details of our remuneration policy can be found on our website
Harte Insurance also charge administration fees for work carried out on the client’s behalf. The fee is separately disclosed to clients on documentation issued by us.

SCALE OF FEES

SCALE of FEES and CHARGES
Our Schedule of Fees & Charges can be found in office and on our website:

General (Non-Life) Insurance
www.harteinsurance.ie/compliance/scale-fees-charges-general-insurance/

Harte Insurance scale of fees & charges varies according to the category of insurance product that you purchase from us or seek advice on.
We reserve the right to amend these fees should the complexity of the product require a higher fee. Any increased fee will be notified to you at least 30 days in advance of the due date. Fees may be waived by in certain circumstances.

DEFAULT ON PAYMENTS/CHARGES ON DIRECT DEBIT DEFAULTS and DISHONOURED CHEQUES

Product Producers may withdraw cover in the event of a default on payment due under policies of insurance. We would refer you to policy documents for details of such provisions. We will charge a minimum of €20 for processing each & every: (i) Direct Debit Default by the client and (ii) cheque received from the client which is subsequently dishonoured by the bank. Cheques may be dishonoured for various reasons including: insufficient client funds (bounced cheques), payments stopped by clients (stopped cheques) etc. This charge is in addition to any charge that may be levied by the Product Producer and/or Premium Finance Company.

Return Premiums

Where a policy amendment or cancellation results in a premium rebate being due to you we will refund the premium to you within 5 working days of the rebate becoming due. The premium rebate becomes due to you once we have received the premium rebate from the Product Producer.

Renewals

Once a policy has been arranged, to which you have agreed, the placement of that policy will not be reviewed at each renewal unless you request it.

Claims

You must tell us as soon as reasonably practicable of any incident or circumstance which may result in a claim under any insurance arranged by us and of all relevant facts relating to it. Failure to do so may result in the insurer not paying the claim. We will notify insurers in accordance with the facts and circumstances notified by you and you will be required to give all necessary information and assistance required by insurers in order to deal with your claim.

The insurer is not obliged to pay the full claim settlement amount until any repair, replacement or reinstatement work has been completed and specified documents for the work have been forwarded to the insurer.

The claim settlement deferment amount cannot exceed
• 5% of the claim settlement amount where the claim settlement is less than €40,000;or
• 10% of the claim settlement amount is more than €40,000.

An insurer may refuse a claim made by you under a contract of insurance where there is a change in the risk insured as described in the “alteration of risk” clause in the contract and the circumstances have so changed that it has effectively changed the risk to one which the insurer has not agreed to cover.

If you become aware of information after a claim is made that would either support or prejudice the claim you are under an obligation to disclose it. The insurer is under the same obligation.

If you make a false or misleading claim in any material respect (and know it to be false or misleading or consciously disregards whether it is) the insurer is entitled to refuse to pay and to terminate the contract.

THIRD PARTY CHARGES

Harte Insurance will, on occasion, source your insurance needs through a Wholesale Broker, who may charge a Fee (howsoever titled) for their services. Any charges levied by a Wholesale Broker will be disclosed in your Invoice, Endorsement or Renewal Notice.

INSURANCE PREMIUM HANDLING

Harte Insurance will accept payments in cash, by credit / debit card, electronic fund transfers, by bank draft and by cheque from clients in respect of all classes of Insurance in the circumstances permitted under Section 25G of the Investment Intermediaries Act, 1995. Harte Insurance is not authorised to accept cash or negotiable instruments as payment for insurance policies in any other circumstances. In compliance with Central Bank legislation, Harte Insurance cannot pay insurance premiums to Product Producers, where payment has not been received from clients. Insurance premiums must be paid by the policy inception date outlined on your invoice or the renewal date appearing on your renewal notice, as applicable.

RISK TRANSFER

When handling client money we are required by law to act as agent for the insurer ie risk transfer applies. Where risk transfer applies you will be protected to the extent that any premiums we receive from you is treated as having been received by the insurer when they are received by us. When the agreement extends to premium refunds any premium refund will be treated as received by you only when actually paid to you.

SANCTIONS

We will not provide and services and will not be liable to pay any sums or provide any benefit to you to the extent that such services, payment of such sums or provision of such benefits would breach or expose us to any enforcement or other adverse action under sanctions, prohibition or restrictions under United Nations resolutions or the trade or economic sanctions, laws or regulations of the EU, UK or USA. If you have any concerns in relation to any of the above you should let us know.

RECEIPT

A receipt is issued for all Insurance transactions and should be kept in a safe place.

PREMIUM FINANCE

As a credit intermediary, Harte Insurance can arrange finance for your insurance premium.

COOLING OFF PERIOD

Under the Consumer Insurance Contracts Act 2019, you have a statutory right to cancel your insurance policy within 14 working days if you decide it does not meet your requirements. This is known as the “Cooling Off period”. The Cooling Off period begins from the later of: (1) your policy inception/renewal date or (2) the date you received your Insurance Policy Documents, issued on behalf of your Insurer. The right of withdrawal may be exercised by notice in writing to Harte Insurance, quoting your policy number. Should this right be exercised the Insurance Company may charge a pro rata premium and/or an administration charge for the period you are on cover. Any Fee or Charge paid by the consumer to Harte Insurance for work carried out prior to cancellation, shall not be refundable. If the policy is for motor insurance the premium cannot be refunded until the Certificate of Insurance and Windscreen Disc have been returned to Harte Insurance along with a declaration that the Insured persons and insured vehicle have not been involved in any accident or incident during the cooling off period. This is provided for information purposes only, and you must refer to your Insurance Policy Documents for the specific Cooling Off terms applicable to your policy.

CONFIDENTIALITY

Please note that we agree to keep and maintain all your confidential information in strict confidence and not disclose such information except as is required by law or to carry out our services to you.

CANCELLATION

You, the client, can cancel your policy by notice in writing at any time. Provided that all reasonable Fees & Charges due to Harte Insurance have been paid and provided that no incident giving rise to a claim has occurred in the current period of insurance, you will be entitled to a proportionate return of the premium for the un-expired period of insurance. The exceptions to this general principle are as follows: (1) if the policy is on a minimum and deposit basis, no return will be allowed on the policy and this will be noted on your policy schedule; (2) if you cancel a property insurance policy during the first year of insurance, no return premium will be allowed by your Insurer; please see your policy terms & conditions for details. Please note that your Insurer may require you to return your policy documents prior to cancellation. In the case of cancellation of motor insurance, you must return the Certificate of Insurance and Windscreen Disc to Harte Insurance before the policy can be cancelled. A Professional Fee of up to €150 will be charged by Harte Insurance on policy cancellations. Harte Insurance and your Insurer both reserve the right to cancel your policy at any time by notice in writing to your last known address.

A non-exhaustive list of reasons for cancellation includes:

You fail to pay the premium due at policy inception, at renewal or following a mid-term alteration or adjustment; Your bank returns your payment cheque due to insufficient funds or any other reason; You fail to pay your direct instalments and do not pay the outstanding amounts; You fail to disclose material facts in accordance with Insurance law or any other reason outlined in your policy terms & conditions.

We recommend that you read your policy documents in full in order to familiarise yourself with these terms & conditions and if there is any aspect that you don’t understand, please contact us.

CANCELLATION BY INSURERS

Please note that your insurer may cancel your policy in certain circumstances. These conditions are outlined on all policy documents, which you should read and note.

RIGHT TO DECLINE OR CEASE SERVICING

Harte Insurance reserves the right, at our sole discretion and subject to applicable law and regulatory requirements, to decline to accept instructions from a prospective client and/or to cease providing services to an existing client. Circumstances may include (without limitation) where required information is not provided or is inaccurate; where fees, charges or premiums remain unpaid; where a material conflict of interest arises; where we reasonably believe our services are being used for unlawful or improper purposes; where client conduct is abusive, threatening or otherwise unacceptable; where regulatory, compliance or anti-money laundering obligations cannot be satisfied; or where continued engagement would, in our reasonable opinion, compromise our professional, legal or ethical duties. Where practicable, we will provide 6 weeks’ notice of our decision and any steps necessary to transfer your business or documentation. This discretion will not be exercised in a manner that is unlawfully discriminatory, and we will at all times comply with our obligations under applicable consumer protection, data protection, and financial services regulation.

CONFLICT OF INTEREST

It is Harte Insurance’s policy to avoid any conflict of interest when providing services to our clients. However, where an unavoidable conflict of interest arises, we will advise you of this conflict before proceeding to provide you with any further services. We will ensure, in any case, that you are treated fairly at all times. If you have not been advised of any conflict of interest, you are entitled to assume that none arises. Furthermore, we do not have a holding, direct or indirect, representing 10 per cent or more of the voting rights or of the capital in any insurance undertaking and likewise no insurance undertaking has such a holding in the Harte Insurance.

COMPLAINTS

If you are unhappy with any aspect of our service or products you can let us know by contacting the manager of Harte Insurance. You can make your complaint in writing (by letter or e-mail), over the phone or in person. Our aim is to resolve all customer complaints as expeditiously as possible. Where we cannot resolve your complaint there and then, however, we will write to you formally within 5 business days of the date of your complaint, confirming the facts as we understand them and informing you of the person within Harte Insurance who will manage the investigation of your complaint and providing you with details of our procedure for handling complaints. We endeavour to investigate and resolve all customer complaints within 40 working days of receiving them. You will, in any event, be provided with a written update of the progress of your complaint every 20 working days. In the unlikely event that we have not completed our investigation within 40 working days we will advise you in writing of the anticipated timeframe in which we foresee the investigation being concluded. Once our investigation has concluded we will, within 5 working days, issue you with a letter setting out the results of our investigation and our final response to your complaint.

FINANCIAL SERVICES and PENSIONS OMBUDSMAN

If we have not resolved your complaint within 40 working days, or if you have received a final response from us and you remain dissatisfied, you have the right to refer your complaint to the Financial Services and Pensions Ombudsman, 3rd Floor, Lincoln House, Lincoln Place, Dublin 2 | D02 VH29 | T: (01) 5677000 | E-Mail: info@fspo.ie

The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (“the Act”) commenced on 15 July 2010. The Act transposes the Third Money Laundering Directive (2005/60/EC) and it’s Implementing Directive (2006/70/EC) into Irish law, bringing Ireland into line with EU requirements and the recommendations of the Financial Action Task Force. Designated persons under the Act, including all credit and financial institutions (as defined in the Act) are required to comply with their obligations under the Act with immediate effect.

ANTI-MONEY LAUNDERING PROCEDURES ANTI-MONEY LAUNDERING PROCEDURES

We are not, as non-life insurance brokers, “Designated Persons” under the terms of The Act. However, we do have obligations to have in place adequate systems and controls to ensure compliance with anti- money laundering / international sanctions (AML)
In light of our obligations in respect of AML legislation /international sanctions and in order to comply with our obligations under AML legislation /international sanctions we have assessed:

1. The risks posed by the products we offer.
2. The channels through which we conduct business.
3. The countries in which business is done.

and we have reviewed our internal money laundering procedures in relation to:

1. The level of understanding of, and compliance with, training provided to staff particularly with regard to identifying suspicious activity and reporting such suspicions to the person designated to receive, consider and report such suspicions.
2. Implementing recommendations from previous reviews and from the Central Bank of Ireland.
3. Reporting requirements in respect of suspicious activities/transactions.
4. Ensuring that law enforcement is not hampered in its investigations by the subject of the suspicion becoming aware of the
allegations.

Reporting

1. Procedures are in place to ensure that any suspicious transaction identified will be reported to the designated person.
2. We will comply with local jurisdiction legislation.
3. We will retain documentary evidence of the reporting undertaken.

CONSUMER PROTECTION

ICCL: Harte Insurance is a member of the Investor Compensation Company Limited (ICCL) established under the Investor Compensation Act, 1998. The ICCL Scheme provides for the payment, in certain circumstances, of compensation to the clients of an ICCL member firm, provided that those clients fall within the definition of an eligible investor contained in the Investor Compensation Act. In the event that a right to compensation is established, the ICCL Scheme provides for payment of up to 90% of an eligible loss or €20,000, whichever is the lesser.

BROKERS IRELAND CLIENT’S COMPENSATION AND MEMBERSHIP BENEFITS SCHEME: Harte Insurance is a member of the Brokers Ireland Client’s Compensation Benefits Scheme. Subject to the rules of the scheme the liabilities of its members firms up to a maximum of €100,000 per client (or €250,000 in aggregate) may be discharged by the fund on its behalf if the member firm is unable to do so, where the above detailed ICCL Scheme has failed to adequately compensate any client of the member. Further details are available on request.

Professional Indemnity Insurance: For your further protection we carry Professional Indemnity cover for errors and omissions.

LIMIT OF LIABILITY

To the extent permitted by law, Harte Insurance’s and/or its affiliates’ aggregate liability for breach of contract, negligence, breach of statutory duty or other claim arising out of or in connection with this Terms of Business agreement or the services provided hereunder shall be limited as follows:
(i) in respect of personal injury or death caused by Harte Insurance’s negligence, no limit shall apply;
(ii) in respect of any fraudulent acts (including theft or conversion) or wilful default by Harte Insurance, no limit shall apply;
(iii) in respect of other claims, the total aggregate liability of Harte Insurance shall be limited to the sum of €2.5 million; and (iv) subject to clauses (i) and (ii) above, in respect of the following losses: loss of revenue; loss of opportunity; loss of reputation; loss of profits; loss of anticipated savings; increased costs of doing business; or any other indirect or consequential loss, Harte Insurance will
have no liability in any circumstances.
The above limitations on liability shall not apply in circumstances where our client is a consumer within the meaning of the Central Bank of Ireland’s Consumer Protection Code.

SOLVENCY OF INSURANCE PROVIDERS

In selecting an Insurer, a wide variety of factors are considered including the financial status of the Insurer in question. However, we cannot and do not guarantee the solvency of any Insurer with which we place business. We deny any liability in the event of an Insurer becoming insolvent.

DATA PROTECTION

Data Protection Laws; means the Data Protection Act 2018
We collect your personal details in order to provide you with insurance products, services and advice and to provide the highest standard of service to you. We fully respect your right to privacy. Any personal information which you provide to us will be treated with a high standard of security and confidentiality strictly in accordance with the Data Protection Acts 1988 -2018 and the General Data Protection Regulation 2018. We take great care with the information we obtain, taking steps to ensure that it is only used for legitimate purposes. To fulfil these objectives we may share information with other affiliated professionals. You have the right at any time to request a copy of any personal data within the meaning of the Data Protection Acts 1988 -2018 that our office holds about you and to have any inaccuracies in that data corrected. A copy of our GDPR Privacy Notice is available for inspection on our website.

We are committed to respecting and protecting your privacy and would like you to feel safe when you give us your personal details. We will always clearly identify ourselves in correspondence. Our business is to provide advice and arrange transactions on behalf of clients in relation to general insurance products.
To provide you with relevant information and respond to your requests we sometimes request that you provide us with information about yourself. This Privacy Notice will inform you of the information we gather and how it is used. We maintain the same privacy practices with respect to data that is collected off-line and on-line and this notice also covers both those methods of data collection and use. Harte Insurance complies with EU General Data Protection Directive (GDPR) for the collection, use, and retention of all personal data. Our Data Privacy Policy is available on request.

Use of the information we gather

When we collect information about you, we intend to tell you why we are asking for the information and what we intend to do with it. You will have the option of not providing the information. The information we collect about you is used to provide our services, respond to your requests or process any transactions you have requested. It may also be used to verify your identity.

Sharing information with third parties

In certain instances, we may make your information available to third parties with whom we have a relationship where that third party is providing services on our behalf. We will only provide those third parties with information that is necessary for them to perform the services and we take measures to protect your information.

We may disclose information it has collected about you in the course of transacting business, if required to do so by law or when necessary to protect the rights of Harte Insurance or its employees.

Data security

Our intent is to strictly protect the security of your personal information; honour your choice for its intended use; and carefully protect your data from loss, misuse, unauthorised access or disclosure, alteration or destruction. We have taken appropriate steps to safeguard and secure information we collect. However, you should always take into consideration that the internet is an open forum and that data may flow across networks with little or no security measures, and therefore such information may be accessed by people other than those you intended to access it.

How to update and/or amend the personal information you have provided

You are entitled to know whether we hold information about you and if we do, (subject to certain limitations), to have access to that information and have it corrected if it is inaccurate or out of date. To exercise your Right of Access or to update your details under your Right of Rectification or Erasure please forward your request to the contact address below with proof of identity.

Contacting Us

If you have any questions or comments about our privacy notice or practices, please contact us. Harte Insurance may modify or update this privacy notice from at any time without prior notice.

DATA RETENTION POLICY

1.0 Overview
The need to retain data varies widely with the type of data. Some data can be immediately deleted and some must be retained until reasonable potential for future need no longer exists. Since this can be somewhat subjective, a retention policy is important to ensure that the company’s guidelines on retention are consistently applied.

2.0 Purpose
The purpose of this policy is to specify our guidelines for retaining different types of data.

3.0 Scope
The scope of this policy covers all company data stored on company owned systems and media.

Note that the need to retain certain information can be mandated by local industry regulations and will comply with EU General Data Protection Regulation (GDPR) and the Data Protection Act 1988 and the Data Protection (Amendment) Act 2003. Where this policy differs from applicable regulations, the policy specified in the regulations will apply.

4.0 Policy
4.1 Reasons for Data Retention

We do not wish to simply adopt a “save everything” approach. That is neither practical nor cost effective and would place an excessive burden on staff to manage the constantly growing amount of data.

Some data, however, must be retained in order to protect the company’s interests, preserve evidence and generally conform to good business practices. Some reasons for data retention include:
• Litigation
• Accident investigation
• Security incident investigation
• Regulatory requirements
• Intellectual property preservation

4.2 Data Duplication

As data storage increases in size and decreases in cost, companies often err on the side of storing data in several places on the network. A common example of this is where a single file may be stored on a local user’s machine, on a central file server and on a backup system. When identifying and classifying the company’s data, it is important to understand where that data may be stored, particularly for duplicate copies, so that this policy may be applied to all duplicates of information.

4.3 Retention Requirements

This section sets guidelines for retaining the different types of company data:
• Personal customer data: personal data will be held for as long as the individual is a customer of the company plus six years.
• Personal employee data: general employee data will be held for the duration of employment and then for six years after the
last day of contractual employment. Employee contracts will be held for six years after the last day of actual employment.
• Tax payment records will be held for six years.
• Recruitment details: interview notes of unsuccessful applicants will be held for one year after interview. This personal data will
then be destroyed.
• Health and Safety: data will be held for seven years for records of major accidents.
• Critical data including tax: critical data must be retained for seven years.

4.4 Data Destruction

Data destruction is a critical component of a data retention policy. Data destruction ensures that we will use data efficiently thereby making data management and data retrieval more cost effective.

When the retention timeframe expires we will destroy the data in accordance with our Data Retention schedule. If a user feels that certain data should not be destroyed, he or she should identify the data to management, so that an exception to our policy can be considered. Such a decision can only be taken by management.

We specifically direct users not to destroy data in violation of this policy. Destroying data that a user may feel is harmful to himself or herself is particularly forbidden as is destroying data in an attempt to cover up a violation of the law or company policy.

4.5 Applicability of other policies

This is part of our cohesive set of security policies. Other policies may apply to the topics covered in this document and, as such, the
applicable policies will be reviewed as needed.

5.0 Enforcement

This policy will be enforced by management. Violations may result in disciplinary action which may include suspension, restriction of
access or more severe penalties up and including termination of employment. Where illegal activities or theft of company are suspected, the company may report such activities to the relevant authorities.

By engaging with our services, you acknowledge that you have been informed of where these details can be accessed and understand that they form an integral part of our Terms of Business.

GOVERNING LAW & LANGUAGE

The laws of Ireland form the basis for establishing relations between you and Harte Insurance. All contracts, terms, conditions and communications relating to any policies you may enter with us will be in English.

Please Note: This Terms of Business letter supersedes with immediate effect any others that we have previously issued to you and is in date.

Patton Insurance Limited trading as Harte Insurance