The main purpose for which we process your personal data is to provide you with services that you request from us. We may need some information from you about health or criminal convictions to do this. We cannot provide you with quotes or policies without this data. We will also process personal data for other purposes, such as marketing (where you have consented), market research and fraud prevention. We will only ever keep your personal data for as long as is necessary for the purpose for which we need that personal data.
We will need to share some of your personal data with some third parties, for example insurers and suppliers, and we will make checks against various databases to verify the information you provide and to help us assess your quote. Some of the decisions that we make in relation to our relationship with you will be made by wholly automated means. These decisions can be reviewed if you ask us to, but this does not necessarily mean that they will be changed.
2. Who is processing your data?
Beagle Street is a trading name of BGL Direct Life Limited, an appointed representative of BISL Limited. BGL Direct Life Limited and BISL Limited are the data controllers in relation to the data you provide.
Data will be shared with Scottish Friendly who underwrite the policy to allow Scottish Friendly to consider your application and to deal with any claims made on your policy. Scottish Friendly will also be a data controller in relation to the data they receive from us and any additional data that they may collect about you and will be responsible for how that data is processed.
If you use the free Will service the provider of the Will service will be a data controller of any data that you provide to them to use this service.
3. Where do we get the data from?
Most of the data that we process will be data that we collect from you directly when you request a quote. We will ask you various questions to collect the data we need for the purpose of your policy. We will not be able to provide a quote unless you answer the mandatory questions.
From your use of our website and services
From price comparison sites or other websites providing quotes
If you have been directed to us from a price comparison site or from another website which provides quotes for our products then that website will have provided us with data that you entered in order to allow us to provide you with a quote.When you purchase one of our policies through a price comparison site or if you click through to our website from another website that has provided a quote in order to complete your purchase we will need to share some information with the price comparison site or other website, for example, information relating to whether the policy has been purchased or the status of the policy. We will also exchange information that is necessary to help resolve any queries or complaints.
Our service providers
We or the insurer will sometimes use third parties to process personal information on our behalf. Where third parties process your personal information on our behalf, we will have a contract in place with them placing obligations on them to keep your data secure and only use it for the purposes that we authorise. The third parties that we use may include, for example, IT service providers or market research agencies.
From other companies
As part of considering your quote, administering (including amending) your policy or dealing with any claims on your policy, we or our insurer (or the re-insurer) will exchange information about you with other companies and/or carry out checks with various databases, which is standard practice in the insurance industry. This includes:
- Undertaking checks against publically available information such as the electoral register, County Court Judgments, bankruptcy or repossession information.
- Carrying out searches against data held by Credit Reference Agencies.
- Using information relating to you which is provided to us or the insurer or re-insurer by other parties for example other insurance companies or fraud prevention agencies.
The credit reference agencies will keep a record of the search and you may see this recorded on your credit file. If you want to check the information that the credit reference agencies hold about you then you can contact them directly.
We will check our existing records to see if you have ever held a policy or obtained a quote with us or any of the brands BISL Limited administer. We will also share personal data with our other brands, other companies in the BGL Group of Companies and insurers for these purposes.
Checking and comparing this data helps us to assess your quote. This data will also be used for fraud prevention, research and analysis in accordance with the section headed “What do we use your data for?” below.
Publicly available sources
We or the insurer use some open sources of data which are not personal data (such as information about particular geographic areas) and combine this with the personal data that we hold about you (such as your own address) in order to assess insurance risk and provide you with an accurate quote.
4. Providing data about other people
5. What do we use your data for?
The data that we hold is used for the following purposes:
Part 1 – Providing you with a quote and administering your policy
The personal data that we use for the purposes set out in this Part includes information you provided during your quote, information about previous or existing policies held by us or the insurer, identification information, information from credit reference agencies, your policy and payment history and behavioural information that we gather from your use of our website and how you manage your policy.
Providing you with a service
As you would expect, this data is used to provide you with the service you have requested, for example a quote or an insurance policy.
We also use this data (including data held in relation to our other brands) to help us build up a picture of you a customer. This allows us to carry out more accurate assessments of you as a customer when you apply for products with us, including creditworthiness assessments. It helps us to provide you with more relevant information such as making sure we show you the right content at the right time. We also use this information to help calculate your future quotes. This information will also be shared with the insurer for these purposes.
Data protection law says that we have to tell you the legal basis on which we process your personal data.
In relation to personal data used for the purposes described in this Part 1, we process this data because it is necessary to perform the contract that we have in place with you to provide you with the quote or the policy that you have requested.
Part 2 – Fraud Prevention
In order to prevent and detect fraud we and/or the insurer or the re-insurer may use the personal data set out above at any time to:
- Undertake credit searches;
- Check and/or share your details with fraud prevention and detection agencies; and
- Share information about you with other organisations including the police, where necessary and proportionate.
If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information.
We, the insurer or other organisations may also access and use this information to prevent fraud and money laundering, for example when: recovering debt and tracing beneficiaries; checking details on applications for new products and dealing with claims for all types of insurance.
In relation to personal data used for the purposes described in this Part 2, we process this data because we have a legitimate business interest in carrying out these activities to protect against fraud and because there is a substantial public interest in preventing and detecting crime including fraud.
Part 3 – Other Uses of Data
From time to time we will ask you when you request your quote whether you would like to receive marketing material from us. Where you do tell us you are happy to receive this material, we will use your postal address, email address and telephone number to send you marketing materials by post, email, telephone call or SMS. We do not pass your data to third parties for marketing purposes.
Where we have asked you about your marketing preferences, you can change your mind at any time by visiting our website and updating your preferences. Where we do send you any marketing emails you can also unsubscribe from emails by clicking on the unsubscribe link or by contacting us.
If you tell us you don’t want to receive marketing or if we don’t ask you about your marketing preferences it means that your data will not be used for marketing.
This will not impact any communications that we need to send you for the purpose of your policy, for example updates about your policy or information about any quotes we’ve provided to you.
We use the data we hold to help us understand our customer demographic to help us improve the services that we provide to you and to help us target our advertising and marketing so that we show customers adverts or marketing which may be more relevant to them. We may sometimes work with carefully selected third parties to do this for example using advertising services provided by organisations such as Google and Facebook and may share data with them to carry out this research and analysis, however we will not sell your data to third parties for them to market to you. We use a process called hashing to protect your details when we share data with third party social media sites such as Facebook. “Hashing” is similar to encryption and means that we scramble the plain text of your email address to create a unique and irreversible message. This means that the social media sites do not receive a plain text version of your email address. If you don’t want your data to be used for these purposes you can let us know by contacting us and you can find more information in the “Your Rights” and “Contacting us about data” sections below.
From time to time we may want to use your postal address, email address and/or telephone number to contact you to assist us with our research by asking you a few questions about the service you have received or by asking if you would like to complete a review of our services. We may sometimes ask market research companies to contact you on our behalf.
If you would prefer us not to contact you for market research purposes then you can let us know by contacting us.
Competitions, Special Offers and Referral Schemes
From time to time we may run promotions such as competitions or special offers. If you decide to participate in a promotion, the personal data collected as part of that promotion (such as your name, contact details and other information provided for the promotion, for example, responses to any questions asked as part of the promotion) will be used to administer the promotion and your participation in it. We may need to share your data with third parties for this purpose. For example, we may need to send your contact details to our suppliers so they can send you your prize/reward.
We may, from time to time, offer a functionality on the website to allow you to ask us to send details regarding the website to a friend. Before you provide us with your friend’s details for us to send them an email you will need to make sure you’ve checked your friend is happy for you to do this. When we email the friend we will also include your name so that they know who asked for the email to be sent.
Research and Analysis Activities
We use data relating to your quotes or your policy, including your claims history, to carry out various research and analysis activities to help us to regularly review and improve the products and services we provide and carry out research relating to underwriting, claims and pricing. We also share this data with the insurer to enable them to use this data for these purposes. Where possible, data will be shared on an anonymised basis. The data will not be used to make any decisions that will affect you or any other individual.
We also use the data that we collect about you through your website usage to carry out research and analysis into usage and activities on our website to enable us to continue to improve our website and our products and services.
In relation to personal data used for the purposes described in this Part 3, we process this data because we have a legitimate business interest in carrying out these activities to promote and improve our business. We have ensured appropriate safeguards to protect your rights when processing this data for these purposes.
Part 4 – Special Personal Data and Criminal Convictions
In order to provide your quote and administer your policy we may ask you to provide data which data protection law classifies as “special personal data”. This includes information about your health (such as any medical conditions) or information relating to criminal convictions or alleged or actual criminal offences.
Where we collect special personal data and criminal conviction or offence data to provide you with your quote and your policy, we process this data because it is in the substantial public interest to do so for the purposes of advising on, arranging, underwriting or administering an insurance contract,
It may also be necessary for us to retain a copy of any special personal data and criminal conviction or offence data for the purpose of making or defending claims or preventing or detecting crime, including fraud.
6. How long do we keep data?
We’ll only keep your personal data as long as we need it and ensure it is securely destroyed when it is no longer required. We do however need to keep certain data after your policy has ended for certain periods as detailed below.
Generally, if you take out a policy with us, you can expect us to keep your data for a period of 10 years following the end of your policy unless there is a requirement for us to keep the data for longer, for example if there are any ongoing queries or claims relating to the policy.
When you obtain a quote, if the policy is not purchased, we will not keep the data you provide for any longer than 5 years from the date of your quote.
We keep data for these periods as it plays an important part in allowing us to undertake fraud detection and prevention activities, allows us to deal with any queries or complaints that may arise regarding the quote and allow us to carry out research and analysis to help us improve our products and services (as described in the section headed “What do we use your data for?” above).
7. Overseas Transfer of Data
We may use third party suppliers to process personal data about you. Some of these suppliers may be located in countries outside the UK which may not have equivalent laws in place to protect your personal data. For example, we use third party software suppliers to process data such as your IP address and email address. The insurer may also process personal data in countries outside the UK which may not have equivalent laws in place to protect your personal data. The insurer is data controller in respect of any such processing.
8. Your Rights
Data protection law gives you various rights in relation to your personal data. All the rights set out below can be exercised by contacting us using the contact details set out under the “Contacting us” section below. Those rights include:
- You have the right to ask us to provide a copy of the personal data that we hold about you. This is called a Data Subject Access Request or “DSAR”.
You can access information about your policy and your policy documents by logging into your account. If you want to receive other personal data that BISL Limited holds then please contact us using the contact details below. When contacting us please describe the information you require and include the following: your full name, your date of birth, your full address and your quote/policy number. For security purposes we may need to ask you for further information to verify your identity. If you require information sending to different contact details to those held on your policy please include a copy of your passport or driving licence and proof of address such as a recent utility bill to assist us in verifying your identity. We might also need to ask you for additional information to help us locate the data that you are looking for.
Once we have all the information that we need to process your DSAR, we will respond within one month unless your DSAR is very large or complex, in which case we may need to extend this period. If we need to do this we will let you know.
If you want to make a DSAR in relation to personal data that is held by Scottish Friendly then you will need to contact them directly. You can find their details in your policy documents or you can contact them at https://www.scottishfriendly.co.uk/contact-us/email-enquiry
- You have the right to ask us to correct inaccurate personal data that we hold about you. If you think any of your personal data is inaccurate, please contact us and, provided we can verify your identity and are satisfied as to the accuracy of the correction requested, we will correct the relevant personal data as soon as we can.
- You have the right to request that we provide a copy of your personal data in a machine readable format or to ask us to send your personal data to another company. This applies to personal data that you have provided to us, which we have processed electronically, such as data you entered on our website when you obtained a quote.
- You also have the right to ask us to delete personal data that we hold about you. We are obliged to delete personal data in some circumstances, such as where it is no longer needed. However, data protection laws allow us to keep the personal data if we need to, for example if the data is needed to allow us to administer your policy or if the data is needed for fraud prevention. In any case, we will retain your personal data in line with the retention periods detailed under “How long do we keep data?” above.
- You have the right to ask us not to do anything with your personal data except store it in limited circumstances, such as if you and we do not agree on the accuracy of personal data and steps are required to validate it.
- You have the right to object to us processing certain personal data about you. For example, you can ask us to stop processing data for marketing or market research purposes. However, where we need to continue to process the personal data, for example to administer your policy or for fraud prevention purposes, we are not obliged to stop processing it.
- You have the right to ask to review significant decisions that we have made about you wholly by automated means. The nature of the quotes that we provide to you means that we have to use this kind of automated decision making in relation to your personal data (including special categories of personal data) to assess your quotes. This means that our computers will consider lots of different pieces of information about you and about the policy you have requested in order to calculate whether or not we are able to offer you a quote and at what price this should be. Automated decision making will be used when you request a quote, and if any changes are made to your policy. If you ask us to review the decision, we will make sure that it is examined by a human and we will confirm the outcome to you. This does not necessarily mean that the decision will be changed.
9. Contacting us about data
If you would like to contact us about one of your data rights set out under “Your Rights” above, then please contact firstname.lastname@example.org or write to: Data Requests, BGL Customer Services, Fusion House, Bretton Way, Bretton, Peterborough PE3 8BG. Please make sure you include details of the product and brand that your request relates to.
10. Information Commissioner’s Office
If you have a complaint regarding how your personal data has been processed by us then please contact us first using the complaints procedure set out in our Terms and Conditions.
You also have the right to complain to the Information Commissioner’s Office, which regulates data protection compliance. You can find more information by visiting their website www.ico.org.uk.
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