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Data Privacy & Modern Day Slavery Policies

This privacy policy sets out how we use and protect any information that you give when you use this website.

Sea Change London is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy statement.

Sea Change London reserves the right, at its discretion, to make changes to any part of the Website, the Information or these Terms. Sea Change London may change this policy from time to time by updating this page. This privacy policy was last updated in July 2020. By continuing to use the Website you agree to be bound by these Terms as amended.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have encrypted electronic systems and managerial procedures to safeguard and secure the information we collect online.

What we collect

We may require basic information which identifies you as an individual (“Personal Information”), such as your name, email address and phone number, in order to enable you to take advantage of particular services that we offer. We will only use such Personal Information for the purposes of providing information which you have requested, or for other purposes set out in these Terms.

We may collect the following information:

· Name and job title

· Company or organisation

· Contact information, including email address and telephone number(s)

· Information pertinent to fulfilling our services on an individual’s or organisation’s behalf

What we do with the information we gather

We require this information for the purpose of:

· Internal record keeping

· Sending marketing emails about new services and other information which we think you may find interesting using the email address which you have provided.

· We may contact you by telephone or post. If you do not wish us to make use of your Personal Information in this way, please email info@seachangelondon.com.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site or page. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. Sea Change London use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. Sea Change London does not use cookie technology to collect Personal Information. You may also wish to refer to www.allaboutcookies.org.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

The Internet is a global environment and using the Internet to collect and process data can involve the transmission of data on an international basis. Therefore, by browsing our website and communicating electronically with us, you acknowledge our processing of data in this way. However, we will endeavour to protect all Personal Information collected through our website in accordance with our data protection standards.

Privacy Policies of other websites

Our website may contain links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should also read their privacy policy.

Controlling your personal information

We will not sell, distribute or lease your personal information to third parties unless we have your explicit permission or are required by law to do so. Employees, associates and agents of Sea Change London may be given access to any Personal Information which we collect, but their use shall be limited to the performance of their duties and in line with the reason for processing. Our employees, associates and agents who have access to your Personal Information are required to keep that information confidential and are not permitted to use it for any purposes other than to enable you to use the website or to deal with requests which you submit to us. All of our employees, associates and agents are have Non Disclosure Agreements (NDA) built into their contacts.

We may use your personal information to send you promotional information about our services and other information related to your industry.

You may request details of personal information which we hold about you. If you would like a copy of the information held on you please write to us at

If you believe that any information we are holding on you is incorrect or incomplete, or have any other data protection related issues or queries, please email as soon as possible. We will promptly correct any information found to be incorrect.

If you are concerned that we have breached a privacy law or code binding on us, please send an email marked “Urgent” to info@seachangelondon.com. We aim to respond in a reasonable time (normally 24 hours).

You have the right to complain to the Information Commissioner’s Office (ICO) if you believe we do have not handled your request in an appropriate manner. For information on contacting the ICO please see their website or call them on 0303 123 1113.

Statement under the Modern Slavery Act 2015

Introduction

This statement is made on behalf of Sea Change London Limited (SCL).

SCL is a niche consultancy business in the Lloyd’s and London insurance markets. Our policies and procedures are designed to ensure that we are supportive of our employees at all times, and that our suppliers operate to the highest ethical and business standards.

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or supply chains.

Because of the nature of our business size and activities, the risk of our organisation becoming involved in the support or encouragement of slavery or human trafficking is very small. For this reason, other than the processes and procedures described in this statement, no other specific activities have been undertaken by SCL in respect of slavery and human trafficking.

Organisational Structure : SCL has its head office in London, UK

Our Business : SCL’s business consists entirely of supplying consulting services to insurance firms and intermediaries in the London and international re/insurance market. We are not licensed to carry out insurance activities, nor to act as producer or retailer of physical goods, and have no supply chain relating to such activities.

Our Policies : Modern Slavery and Human Trafficking Policy

Our modern Slavery Act Policy reflects latest guidance. This policy applies to all persons working for us or on our behalf in any capacity, including employees, directors, contractors, external consultants, agency representatives and business partners.

Our Supply Chains

As a provider of consultancy services to our customers, our supply chains are very limited. We outsource some ancillary functions relating to our consultancy services from professional firms. We also engage external parties to provide support services to our firm. We undertake ongoing review of our existing supplier contracts / agreements and assess the risk associated with those suppliers, based on sector and jurisdiction. This includes reviewing how we can reduce the potential for risk of modern slavery in our supply chain.
Our approved clause “the supplier shall comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015; and comply with the Anti Slavery Policy and maintain throughout the terms of this agreement its own policies and procedures to ensure its compliance”. The clause is now included where appropriate in all newly entered into supplier contracts or other terms.

Due Diligence Processes for Slavery and Human Trafficking

SCL operates a set of risk management policies and procedures designed to identify and mitigate a wide range of risks, including that of suppliers or business partners engaging in illegal or improper activity. These include our Fraud, Anti Bribery & Corruption and Conflicts of Interest policies, as well as our onboarding process for any new associate to verify ID and ability to work in the UK. Implementation of and adherence to these policies is continuously monitored by SCL management.

These policies and procedures, in combination with SCL’s commitment to ensuring that its employees act ethically at all times, enable us to identify and minimise the risk of slavery and human trafficking occurring within our organisation and our supply chains. We will seek to promote adherence to our policy on slavery and human trafficking by our material third party suppliers through our outsourcing and audit procedures.

Training : In order to promote awareness of the risks of slavery and human trafficking, we will communicate this policy to our staff and associates include it as part of the induction materials provided to all new employees, associates and partners.

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