The provision of this service is through our business partner Covea Insurance, who are a separate data controller
How we use your information
If you are claiming under another person’s plan as a third party claimant, we collect information about you when you make a claim under the insurance plan.
If you are a witness to an event giving rise to a claim, we collect your information to help us handle the claim.
We only collect information that is relevant and necessary for us to provide the insurance product and to handle claims made under the insurance plan.
If you contact us by telephone, we may record calls for training and monitoring purposes to help improve our service and to detect and prevent fraud.
What type of information do we collect?
- Personal information provided by you, about you and any additional drivers, directly or via the company who sold you the plan:
- Contact details
- Date of birth
- Homeowner status
- Marital status
- Driving licence details
- Residency status
- Driving behaviour
- Images and videos from dash camera footage
- Other information about you provided by the company who sold you the plan
- Financial information provided by you, directly or via the company who sold you the plan:
- Payment details
- Details of County Court Judgments (CCJs) and bankruptcy
- Transactions and payments made to us for your plan
- Sensitive information provided by you, directly or via the company who sold you the plan:
- Motoring criminal convictions and offences
- Health information including medical conditions and associated restrictions on your driving licence
- Information about what you are insuring and the cover you require provided by you, directly or via the company who sold you the plan:
- Your vehicle details including the car registration, car make and model, annual mileage, value, class of use, where the vehicle is kept etc.
- Information about your insurance history provided by you, directly or via the company who sold you the plan:
- Recent quotes for insurance
- Your insurance history
- Claims details
- Information relating to fraudulent or potentially fraudulent activity provided by fraud agencies and databases or collected from publicly available sources of information:
- History of fraud
- Indicators of fraudulent behaviour
- Investigations into fraud
- Your credit information provided by credit reference agencies:
- Your credit history and score
- Information on the electoral register
- In addition to the information above, we also collect information from third parties, to assist us in assessing your insurance risk. Some of this information is publically available such as census data. We also collect information regarding your vehicle from HPI Ltd.
Why we use your information
When we process your sensitive personal information, we must always have an additional lawful basis.
For each reason for processing your information, we have set out our lawful basis:
|Why do we use your information||Our lawful bases for processing||Our legitimate business interest, where applicable||Retention Guide|
|To provide you with a quote
13 monthsor 4 years if linked to Fraud.
|To administer and manage your insurance plan
||7 years from end of the last active policy across Vitality Group as per standards|
|To handle claims made against an insurance plan
As above.21years & 4mths for claims involving minors.
|To resolve any complaints you may have
||3 years from date of closure.|
|To recover any debt that you owe to us
||7 years after debt recovered or end of policy whichever is longer|
To conduct credit reference checks and to assess your application for credit
|To prevent, detect and investigate fraud or money laundering
Civil cases & criminal cases: 6 years.Upon sentence 3 years after length of sentence.
|For management information purposes and internal analysis of products and services
7 years after which personal data removed
|For training purposes to improve your customer experience
||Call recordings 3 years.|
Insurance plan renewals
For all of our annual plans, we will contact you prior to your plan expiration date with details of whether we can provide you with another insurance plan and the price of the plan, if you choose to stay with us.
Some of our plans will automatically renew so that you have continuity of cover. This means you need to contact us advising that you do not wish to renew otherwise the plan will automatically renew. We will always make it clear in your renewal letter if this will happen and we will always give you enough time to notify us of the lapse of your plan.
Fraud prevention and detection
Applying for a quote and holding an insurance plan with us: If you apply for a quote and/or take out an insurance plan with us, we will carry out checks with fraud prevention agencies and databases. This helps us to prevent and detect fraud and money laundering.
If we suspect fraudulent behaviour, we may not offer you insurance or we may void your plan.
We will keep a record of individuals and any associated investigations to prevent and detect future fraud or money laundering.
Making a claim: If you make a claim against one of our insurance plans, we will carry out checks with fraud prevention agencies and databases. This helps us to prevent and detect fraud and money laundering.
If we suspect fraudulent behaviour, we may not be able to accept your claim. We investigate potentially fraudulent claims and where appropriate, we will use surveillance to assist our investigation. We appoint fraud investigation and surveillance suppliers to conduct these investigations on our behalf. We also conduct searches with publicly available sources of information including internet searches and social media searches.
We will keep a record of individuals and any associated investigations to prevent and detect future fraud or money laundering.
Fraud agencies and databases: To prevent and detect fraud, we check your details against a range of databases and agencies including other insurers' databases. If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies, fraud databases and other insurers. Law enforcement agencies may access and use this information.
We access and use the information recorded by fraud prevention agencies or fraud databases to prevent fraud and money laundering. These checks are done to identify, predict, investigate and evaluate potentially fraudulent behaviour.
We use the following fraud prevention agencies and databases:
- CIFAS National Fraud Database
- CUE (Claims and Underwriting Exchange)
- IFB (Insurance Fraud Bureau)
- IFIG (Insurance Fraud Investigators Group)
- IFED (Insurance Fraud Enforcement Agency)
- IFR (Insurance Fraud Register)
- NFIB (National Fraud Intelligence Bureau)
- NCA (National Crime Agency)
- OFSI (Office of Financial Sanctions Implementation)
- Motor Insurance Database
- MIAFTR (Motor Insurance Anti-Fraud and Theft Register)
- DVLA (Driver and Vehicle Licensing Agency)
Credit checks with credit reference agencies
We will perform credit and identity checks on you with one or more credit reference agencies (CRAs) in the following circumstances:
- When you apply for an insurance quote with us;
- Prior to renewals on all existing planholders;
- When you apply for credit from us.
To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
- Assess your creditworthiness and whether you can afford to take the product;
- Verify the accuracy of the data you have provided to us;
- Prevent criminal activity, fraud and money laundering;
- Manage your account(s);
- Trace and recover debts; and
- Ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.
When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you and your partner successfully files for a disassociation with the CRAs to break that link.
The identities of the CRAs, their role also as fraud prevention agencies, and the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at www.transunion.co.uk/crain.
Some of our reasons for processing will involve automated decision making. These decisions are set out below. You have a right to obtain human intervention for any of our automated decisions. If you object to an automated decision, we may not be able to offer you an insurance quotation or renewal.
Offering an insurance plan and pricing: We ask you a series of questions when you obtain a quote for insurance from us. This is so we can understand the insurance risk that we are being asked to consider and make an underwriting assessment and decision. The information you provide along with other information helps us to decide whether we can offer you a quote and the price you will need to pay for insurance.
We use lots of factors to assess whether we can provide insurance cover, the price of your plan and any other terms of your plan. These factors include, but are not limited to, your age, your health/lifestyle, your geographical location, claims history, the past performance of the insurance product, etc.
Based on this information, an automated decision will be produced on acceptability of cover, the price you will need to pay for your plan and any other terms we need to apply.
Credit checks: When we carry out credit checks, an automated score is produced by the credit reference agency. We use this to assess the terms and price on which cover may be offered, verify your identity and prevent and detect fraud.
Driving score: When you participate in the Good Driving programme, we receive information on your driving behaviour and habits from our technology and analytics providers. We use your driving information to assess the terms on which cover may be offered and your driving habits may affect your premium.
How we share your information
Motor Insurance Database
The Motor Insurers’ Bureau (MIB) is the Data Controller for the Claims Underwriting and Exchange Register (CUE) and the Motor Insurance Anti-Fraud and Theft Register (MIAFTR). For more information please visit www.mib.org.uk.
Information about your insurance plan will be added to the Motor Insurance Database (MID), managed by MIB. MIB process personal information about you, this information may include your personal details, goods and services, financial details, education and employment details. On occasion MIB may collect special category data such as records of any personal injury claims. The police, the Driver and Vehicle Licensing Agency (DVLA), the Driver and Vehicle Agency (DVA), the Insurance Fraud Bureau and certain other authorised organisations may use the MID and the information stored on it for purposes including:
- Electronic licensing;
- Continuous insurance enforcement (to reduce the number of people driving without insurance)
- Enforcing the law (preventing, detecting, cautioning or prosecuting offenders)
- Providing government services or other services aimed at reducing the number of uninsured drivers.
MIB’s legitimate interests in providing the CUE/MIAFTR data to the industry is detecting and preventing fraud. By preventing consumers from making multiple or illegitimate claims against insurance plans it will save the insurance industry a considerable sum of money. This in turn will reduce the cost of insurance premiums for the insurance industry, benefiting the wider consumer public.
The purpose of MIB processing your personal information is to provide access for the insurance industry to the MIAFTR database and facilitate access for the insurance industry to CUE; to enable underwriting decisions to be made by subscribers; validating claim information; verifying facts during a claim investigation; law enforcement to detect suspected cases of fraud; activities relating to the provision or administration of motor insurance plans; the provision of motor vehicle condition history checks (commonly known as "vehicle provenance checks") to trade and general public consumers; and to maintain MIB accounts and records and to promote MIB services and to support and manage MIB employees.
If you're involved in a road traffic accident (either in the United Kingdom, the European Economic Area or certain other territories), insurers and the MIB may search the MID for relevant information.
People (including citizens of other countries) making an insurance claim following a road traffic accident (and their appointed representatives) may also get relevant information which is held on the MID. You can find out more about this from us, or at www.mib.org.uk
We have detailed third parties that we share your information with in the 'How we share your information' section. Some of these third parties may be in countries outside of the European Economic Area (EEA).
Under data protection law, when personal information is being transferred outside the EEA, we as data controller, are under an obligation to ensure that such transfers are performed in a manner that ensures that your personal information is adequately protected.
In the event that we transfer your personal information outside of the EEA, we will always put in place adequate safeguards to ensure that your personal information is protected. Adequate safeguards may include placing contractual obligations on the third party that we are transferring your information to or ensuring that the third party is certified to the EU-US Privacy Shield Framework, if we are making transfers to third parties located in the United States.
There may be some circumstances where we will be required to transfer your information outside of the EEA and we will rely on it being necessary for the performance of your insurance contract. For example, claims made abroad where we need to instruct a local supplier so that we can handle your claim.
How long we keep your information for
If you get a quote from us but do not take up the plan, we will keep your information for 4 years from the expiry date of the quote. This is to support customers returning in the near future and to prevent and detect fraud.
In most cases, we will keep your information for 7 years from the expiry date of the plan or from the settlement/closure of the claim, whichever is the latter. This is applicable if you get a quote from us and you buy the plan, if you have a plan with us, if you make a claim under one of our plans (including if you are a third party claimant) or if you are a witness to an event giving rise to a claim under one of our plans. This is so that we can administer the contract of insurance and handle claims made against the plan.
There are some exceptions to this, for example, we need to keep the information where there has been or is the potential (for example a minor was present at an accident) to have claims from minors and we will hold the data for 21 years and 4 months. This is so that we can handle potential future claims and meet our legal requirements.
If we suspect, detect or investigate fraud or money laundering, information will be held on a case by case basis for up to 7 years.
How to contact us
In the first instance we would ask that you notify us of any concerns you have about how we handle your data but if you are still unhappy then you can contact the Information Commissioners Office here.
Our Privacy Notice on how we will use your personal data in relation to your driving behaviour is under development and will be published in May 2021.