- 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.
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.
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).
8. Your RightsData 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 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.
10. Information Commissioner’s OfficeIf 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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