How we use your information
If you are a beneficiary under the plan, we collect information about you when you make a claim under the investment 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 plan and to handle claims made under the investment 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 and anyone named on the plan, directly or via the company who sold you the plan:
- Contact details
- Date of birth
Financial information provided by you, directly or via the company who sold you the plan:
- Payment details
- Transactions and payments made for your plan
- Health information including medical conditions and your doctor/hospital details
- Information about what you are insuring provided by you, directly or via the company who sold you the plan:f
|Why do we use your information||Our lawful bases for processing||Our legitimate business interest, where applicable|
|To provide you with a quote
|To administer and manage your insurance plan
|To handle claims made against an insurance plan
|To resolve any complaints you may have
|To recover any debt that you owe to us
|To prevent, detect and investigate fraud or money laundering
|For management information purposes and internal analysis of products and services
|For training purposes to improve your customer experience
Fraud prevention and detection
Applying for a quote, holding an insurance plan with us and making a claim: In certain circumstances, where we suspect fraudulent behaviour, we will carry out checks with fraud prevention agencies and databases. We also conduct searches with publicly available sources of information including internet searches and social media searches.
If we suspect fraudulent behaviour, we may not offer you insurance, we may void your plan or 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 will keep a record of individuals and any associated investigations to prevent and detect future fraud or money laundering.
Fraud prevention agencies and databases: When we check your details against fraud prevention agencies and databases, we will use 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)
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.
How we share your information
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.
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 up to 13 months 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.
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.