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25 May 2018 marks the start of enforcement of the European Union’s General Data Protection Regulation. This new piece of legislation has had a great impact on anyone whose business involves handling personal data about EU residents or within the EU. Naturally, personal data is at the core of working in sales, so IC insurance and our users have also been busy to make sure that we are compliant.

This article provides an overview of the data-related roles and responsibilities when you’ve chosen IC Insurance Solutions as your CRM platform and will explain IC Insurance Solutions’ efforts to live up to the values and requirements of the GDPR.

IC Insurance Solutions as the data processor

The people you store in IC Insurance Solutions as Contacts are your data subjects, and you are considered the data controller for this personal data. In our Terms of Service and Privacy Policy, we refer to this data as Client Data.

Using the IC Insurance Solutions app to manage your customers means that you have engaged IC Insurance Solutions as a data processor to carry out certain processing activities on your behalf.
According to Article 28 of the GDPR, the relationship between the controller and the processor needs to be made in writing (electronic form is acceptable under subsection (9) of the same Article). This is where our Terms of Service and Privacy Policy come in. These two documents also serve as your data processing contract, setting out the instructions that you are giving to IC Insurance Solutions with regard to processing the personal data you control and establishing the rights and responsibilities of both parties. IC Insurance Solutions will only process your Client Data based on your instructions as the data controller.

Lastly, it is important to check Section 17 of our Terms of Service to see which IC Insurance Solutions entity is your contractual partner.
All EU customers have a contractual relationship with our EU entity, based in Estonia.

Data transfers

One topic that often comes up with customers is data transfers outside of the EEA.
The GDPR establishes strict requirements for moving data outside of its scope of protection. This is only natural – otherwise it would be impossible for the law to fulfill its purpose.

Who is responsible for meeting these data transfer requirements? As our EU customers have a legal relationship with our EU entity, this data transfer remains within the EEA. If IC Insurance Solutions subsequently engages sub-processors outside the EEA, it is our job to ensure that we transfer the data lawfully.

We will keep an up-to-date list of sub-processors in our Terms of Service to be fully transparent about these transfers. This list will also explain what data is involved and how we have ensured that the data is adequately protected even after it leaves the EEA. We do this by making sure that our third-party service providers have either certified under the EU-US Privacy Shield framework or signed the EU Commission’s standard contractual clauses for data transfers with us.

IC Insurance Solutions as the data controller

Additionally, IC Insurance Solutions acts as the data controller for the personal data we collect about you, the user of our web app, mobile apps, and website.
First and foremost, we process data that is necessary for us to perform our contract with you (GDPR Article 6(1)(b)).
Secondly, we process data to meet our obligations under the law (GDPR Article 6(1)(c)) — this primarily involves financial data and information that we need to meet our accountability obligations under the GDPR.
Thirdly, we process your personal data for our legitimate interests in line with GDPR Article 6(1)(f).

What are these ‘legitimate interests’ we talk about?

Hopefully this helps you to better navigate the EU’s data protection requirements. If you have any questions with regard to the above, you’re welcome to reach out to us at info@icinsurance.co.uk  and we’ll do our best to explain things further.

What is IC Insurance Solutions doing for the GDPR

As a company with roots in Europe, IC Insurance Solutions is very much up to speed with the implications that the EU General Data Protection Regulation has for businesses.
We appreciate the privacy needs of IC Insurance Solutions users as well as their customers and, as such, have implemented — and will continue to improve — technical and organizational measures in line with the GDPR to safeguard the personal data processed by IC Insurance Solutions.

Internal processes, security and data transfers

A large part of GDPR compliance is making sure that there are procedures in place that ensure that data processes are mapped and auditable. We have added elements to our application development cycle to build features in accordance with the principles of Privacy by Design. Any access to the Client Data that we process on your behalf is strictly limited. Our internal procedures and logs make sure that we meet the GDPR accountability requirements in this regard.

We have established a process for onboarding third-party service providers and adopting tools that makes sure that these third-parties meet the high expectations that IC Insurance Solutions and its customers have when it comes to privacy and security. We have further launched a datacenter in Germany to store the databases of EU customers to improve performance and provide additional assurance that your data enjoys the level of protection envisioned by the GDPR.

Readiness to comply with subject access requests

Data subjects’ ownership of their personal data is at the heart of the GDPR. We have created a readiness to respond to data subject requests to delete, modify, or transfer their data. This means that our Customer Support Specialists along with the Engineers that assist them in their work are well-prepared to help you in any matters involving your personal data, in addition to providing the awesome customer support experience that you are accustomed to.


Our Terms of Business and Privacy Policy are constantly being revised to increase transparency and to make sure the documents meet GDPR requirements. As these are the basis for our relationship for you, it is very important for us to comprehensively and openly explain our commitments and your rights in these documents. Additionally, we’re constantly mapping all our data processing activities to be able to comply with the GDPR accountability requirements.


All of the above is supported by extensive training efforts within the company so that the GDPR compliant processes we’ve put in place are followed. Sessions on data privacy and security are an integral part of our onboarding process and each department receives training that is tailored to their work involving personal data.

IC Insurance Solutions is firmly convinced that meeting GDPR requirements is much more than just checking off boxes in a list. For us, the GDPR is truly a lifestyle of respect to individuals’ privacy and responsibility in handling personal data.[/vc_column_text][/vc_column][/vc_row]

We are a team of experienced insurance
brokers working together with our customers to understand and fulfil their insurance needs.
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