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This policy is designed to help you understand what kind of information we collect in connection with our products and services and how we will process and use this information. In the course of providing you with products and services, we will collect and process information that is commonly known as personal data.
This policy describes how we collect, use, share, retain and safeguard personal data.
This policy sets out your individual rights; we explain these later in the policy but in summary, these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.
Personal data is information relating to an identified or identifiable natural person. Examples include an individual’s name, age, address, date of birth, their gender and contact details.
Personal data may contain information which is known as special categories of personal data. This may be information relating to an individual’s health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to or sexual orientation. Personal data may also contain data relating to criminal convictions and offences.
For the purposes of safeguarding and processing criminal conviction and offence data responsibly, this data is treated in the same manner as special categories of personal data, where we are legally required to comply with specific data processing requirements.
We will only gather data that is necessary for us to provide our services to you. This data will include both personal and special category data. The following are examples of the data we will gather:
We may also need to collect personal data relating to others in order to provide and administer insurance. In most circumstances, you will provide us with this information. Where you disclose the personal data of others, you must ensure you are entitled to do so.
The protection of your information is important to us and we, therefore, have security measures in place which are appropriate to the nature of the information we hold and to the harm that might result from a breach of security.
We will share your personal data within our group of companies including affiliates and subsidiaries. This is normal practice within the insurance industry where it is necessary to share information in order to place, quantify and underwrite risks, to assess overall risk exposure and to process claims. It is also necessary to determine the premium payable and to administer our business.
We also share personal data with authorised third parties, this is necessary where we are required to do so by law, where we need to administer our business, to quote for, source, place and administer your insurances including arranging insurance premium finance, to perform underwriting activities and to process claims. Some examples follow:
Most of the insurers we deal with have entered into a sharing of information agreement to help prevent insurance fraud. Whenever you arrange your insurance through us, this will be on the basis that you agree to your Insurer passing your claims information onto the Claim Underwriting Exchange. To help prevent fraudulent claims most of the insurers with whom we deal will exchange information with other insurers through various databases. In order to help detect vehicle owners who break the law by not having insurance, your insurer will supply details of your motor insurance to a database which can be accessed by the police or other insurers.
A selection of telephone calls will be recorded for training and quality purposes.
Below we list the lawful bases under which we may process your personal data
In the table below we summarise how we collect data, for what purpose and our legal bases for processing it:
|Purpose||Type of information||How the data is collected||Legal basis for processing|
|To carry out our business:
If you give us information about another person, it is your responsibility to ensure and confirm that these people are aware and agree for you to do so.
Our legal obligations
|To improve our offer and service||
|Our legitimate interests|
|Competitions and prize giveaways||
Marketing and Offers
||Our legitimate interests
Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.
These rights are known as Individual Rights under the Data Protection Act 2018. The following list details these rights:
Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests. However, if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee.
In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request. For example, if you make a request for us to delete all your personal data, we may be required to retain some data for taxation, prevention of crime and for regulatory and other statutory purposes.
You should understand that when exercising your rights, a substantial public or vital interest may take precedence over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health-related matters.
The flow of data within the insurance sector is complex and we ask you to keep this in mind when exercising your ‘rights of access’ to your information. Where we may be reliant on other organisations to help satisfy your request this may impact on timescales.
If you require further information on your Individual Rights or you wish to exercise your Individual Rights, please contact our data privacy representative by e-mailing firstname.lastname@example.org or by writing to Plan Group Ltd, Prospero, 73 London Road, Redhill, RH1 1LQ.
We will retain your personal data at the end of any contractual agreement for a period of 7 years. We will retain special category and criminal conviction data for a period 7 years. Where you have submitted a claim, we will retain your data for a period of 7 years if it is a non-injury claim; where an individual has been injured (physical and physiological), we will retain your data for 7 years. Where you have requested a quote, we will retain your personal data for 7 years, where you have contacted us for details of our services and products, we will retain your personal data for 18 months. Where you make a complaint we will retain the data for 7 years. Where you or law enforcement agencies inform us about any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data.
The retaining of data is necessary where required for contractual, legal or regulatory purposes or for our legitimate business interests for statistical analysis (profiling) and product development and marketing purposes.
Sometimes we may need to retain your data for longer, for example, if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future claim may occur.
We will take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data within our business and authorised third parties.
If you are dissatisfied with any aspect of the way in which we process your personal data please contact our data privacy representative. You also have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office (ICO). The ICO may be contacted via its website, by live chat or by calling their helpline on 0303 123 1113.
If you have any questions regarding this policy, the use of your data and your Individual Rights please contact our data privacy representative at: Plan Group Ltd, Prospero, 73 London Road, Redhill, RH1 1LQ or by e-mailing email@example.com or by telephoning 0208 655 8990.