1.1. First Assurance, a subsidiary of Absa Group Limited (Absa Group) has its head office at First Assurance House, Gitanga Road Nairobi. (First Assurance, it, we, us or our)
1.2. First Assurance promises to treat all your personal information carefully and responsibly.
1.3. Personal information includes any information that lets First Assurance identify you as a unique individual, such as your name/s and surname combined with your physical address, contact details and/or passport/identity number.
1.4. Personal information also refers to information that uniquely identifies a legal entity, such as the trading name of a company combined with the company registration number.
1.5. Special personal information includes details of your race or ethnic and social origin, gender, religious, philosophical and conscience beliefs, political persuasion, property details, marital status, family details including details of children, parents, spouse or spouses, health status, genetic, biometric information, sex or sexual orientation or any criminal behaviour which relates to alleged criminal offences or proceedings.
1.6. Personal information may be given to or collected by First Assurance in writing as part of a written application form, electronically (email), telephonically, online (firstassurance.co.ke ) or via the First Assurance App.
1.7. Processing of personal information includes any initial processing that First Assurance does when we first collect your personal information. It also includes any further and ongoing processing that First Assurance is allowed to carry out legitimately in terms of the reasons listed in paragraph 9 (below). The term ‘processing’ includes collecting, using, altering, merging, linking, organising, disseminating, storing, retrieving, disclosing, erasing, archiving, destroying or disposing of personal information.
1.8. First Assurance will only collect and process your personal information for the reason you provided it to us, or to enable us to comply with the requirements of specific laws and/or regulations that we are governed by.
1.9. First Assurance may process your personal information to protect your or our legitimate interests. First Assurance will not collect and process personal information about you that we do not need. The general purposes for which First Assurance collects and processes your personal information include, but are not limited to:
1.10. Creating a record of you on our system to verify your identity, provide you with the products and/or services you have applied for and then communicate with and keep you informed about these products and/or services;
1.11. Identifying you and verifying your physical address,
1.12. Identifying your source of income and similar information;
1.13. Assessing your personal financial circumstances and needs before providing advice to you;
1.14. Any purpose related to the prevention of financial crime, including sanctions screening, monitoring of anti-money laundering and any financing of terrorist activities;
1.15. Further processing for historical, statistical or research purposes where the outcomes will not be published in an identifiable format;
1.16. Providing income tax-related information to tax authorities;
1.17. For purposes relating to the assignment, sale or transfer of any of our businesses, legal entities or assets, in whole or in part, as part of corporate transactions;
1.18. Where you have applied for employment at First Assurance, we perform applicant screening and background checks;
1.19. Where you are a First Assurance employee (including contractors), we create an employment record of you on our system to facilitate continuous monitoring during your employment with us;
1.20. Where you are a First Assurance director, we create a record of you as a director on our system;
1.21. Where you’ve been identified as a next of kin or beneficiary by an employee or customer, we create a record of you on our system; and
1.22. Where you are a supplier to First Assurance, we process your personal information for due diligence, risk assessment, administrative and payment purposes.
1.23. Furthermore, First Assurance will not process your special personal information unless:
1.24. You have consented to First Assurance processing it;
1.25. It is necessary to exercise or defend a right or obligation in law;
1.26. It is necessary to comply with a legal and/or regulatory obligation of public interest;
1.27. It is for certain historical, research or statistical purposes that would not adversely affect your privacy; or
1.28. Your information has been made public.
1.29. There are some personal information fields that you have to fill in if you want First Assurance to provide you with any product and/or service or onboard you as an employee, supplier, director or job applicant. This information can be provided in writing, electronically or telephonically, but it must be accurate and complete. These fields are indicated by an asterisk (or as otherwise indicated) on the respective forms/websites. If First Assurance does not receive the necessary personal information, we will not be able to continue with your application. If you are already a(n) customer/employee/supplier/director and First Assurance asks you for this information and you do not provide it, First Assurance will have to suspend the provision of the product and/or services for a period of time, or as the case may be, even terminate our relationship with you.
1.30. In most cases, personal information will be collected directly from you, but there may be other instances when First Assurance will collect personal information from other sources. These may include public records, places where you may already have made your personal information public (for example, on social media), credit bureaus, or individuals/directors whom you have appointed as your representative, where you are a corporate entity. First Assurance will only collect your personal information from other sources where we are legally entitled or obliged to do so, and you are entitled to ask First Assurance which sources they used to collect your personal information.
1.31. For the purposes outlined in paragraph 9 (above), First Assurance will, in most instances, collect and process your personal information internally. However, there are times when First Assurance needs to outsource these functions to third parties, either within First Assurance or external to First Assurance, including parties in other countries. Where your personal information is shared internally within First Assurance, such sharing will be carried out only for the purposes outlined in paragraph 9 (above). First Assurance may also need to share your personal information with external organisations, such as credit bureaus, tax authorities or other regulatory or industry bodies, so that we can meet our due diligence or regulatory requirements. We may need to share your personal information with our business partners or counter-parties, where we are involved in corporate transactions relating to the sale or transfer of any of our businesses, legal entities or assets. First Assurance will not share your personal information with third parties who do not need your personal information, or where First Assurance is not legally permitted to do so. When First Assurance decides to transfer your personal information to third parties, we will only
provide it to organisations that have the same data privacy policies as First Assurance or those who are subject to laws relating to the processing of personal information that are similar to those that apply to First Assurance.
1.32. There may be instances where First Assurance will process your personal information through a secure automated tool, or perform profiling resulting in a decision that may affect you significantly. If you are unhappy about the outcome of such a decision, please contact:
1.33. your Local Customer Service centre (for customers);
1.34. your resourcing consultant (for job applicants);
1.35. your people business partner (for employees);
1.36. your supplier relationship manager (for suppliers); or
1.37. Absa’s Group Secretariat office (for directors of Absa-owned companies).
1.38. As a customer, if you have opted out of receiving electronic marketing communications (on media such as SMS, email or automated calling machines), First Assurance will not market to you using electronic media. However, if you are receiving marketing via electronic media, you have the right to opt out at any time by following the instructions on the marketing material received. First Assurance will continue to market to you using telephonic means until such time you have opted out.
1.39. As a non-customer, if you would like to receive marketing information from First Assurance through electronic media, please submit your details to First Assurance in writing.
1.40. To the extent that local legislation permits or if you are a resident of the European Union or United Kingdom, you have the following rights regarding your personal information:
1.41. The right to access your personal information that we have on record.
1.42. You have the right to ask First Assurance to correct any of your personal information that is incorrect. These requests must be sent to us in writing using this form.
1.43. You can ask First Assurance to delete or destroy your personal information. You can also object to First Assurance processing your personal information. These requests must be sent to First Assurance in writing using this form. However, the result of such a request will be that First Assurance may have to suspend the provision of products and/or services for a period of time, or even terminate our relationship with you. First Assurance’s records are subject to regulatory retention periods, which means that First Assurance may not be able to delete or destroy your personal information immediately upon request.
1.44. You may also ask First Assurance to port your personal information to another party in terms of applicable European Union and United Kingdom data privacy legislation. These
requests must be sent to us in writing using this form.
1.45. If you have a complaint relating to the protection of your personal information, including the way in which it has been collected or processed by First Assurance, please contact us using the local contact details as listed below. If you have not had your complaint dealt with satisfactorily, you may lodge a complaint with your local privacy regulator in terms of applicable privacy laws.
First Assurance reserves the right to change this statement at any time. All changes to this statement will be posted on the website. Unless otherwise stated, the current version shall supersede and replace all previous versions of this statement.
Kenya: email: email@example.com