/ Privacy Policy

 

Introduction
We want you to be confident that we take data protection and your privacy seriously. As a regulated company and data controller we are responsible for the security and management of the personal information we hold about an individual. That’s why we have invested in our systems and processes to ensure that the way we collect, use, share, and store your information meets the legal, regulatory and our own standards.

This notice explains how we collect, use and store your personal information when you use our services or contact us (including any personal information given to us about other people named on the quote, policy, quote or claim).

If you have approached us via a comparison website you may already have given consent for your information to be shared with us, however we urge you to read this Privacy Policy for completeness.

If you provide us with another person’s personal data, you should ask them to read this Privacy Policy. By giving us information about another person you are confirming that you have their consent to provide the information to us.

How we act
We act as the data controller in respect of your personal data and are committed to protecting your privacy.  We will process the information you have given us (this includes information provided to us via a comparison website) in line with the UK’s Data Protection laws and any other laws that apply.

If your quote originated from a comparison website you should be aware that they act as the data controller of the data that they collect on their site(s). When you click through to our website or disclose information to us directly we are the data controller of the information we collect.

Legal basis for processing and your consent
The collection of and processing of data about you and other persons connected with your insurance is necessary for the entering into and performance of a contract or contracts and this forms the legal basis we have for processing information. We also have legal obligations to perform in which case processing of your information is necessary for compliance with the legal obligations to which we are subject, for example Proceeds of Crime Act 2002.

We rely on your actions to indicate your consent for us to collect, process and disclose your information (which may include information about your health and criminal convictions), for example your voluntary provision of your personal data (including if it is given by a representative, agent of your employer), or where you have provided your express consent within a written, verbal or electronic document or other communication.

If you do not consent to processing
You are not obliged to provide us with your personal information but we cannot provide our services without it.

Further details about your rights and how you can contact us are provided below.

Variations to our privacy policy
We reserve the right to amend or modify this Privacy Policy at any time and any changes will be published on our website or issued to separately when we do so.

Collecting and processing your personal information
For us to provide our services and to administrate insurance quotes, insurance policies, service policies, and/or deal with any claims or complaints we need to collect and process information (including personal data) about you and any other individuals you may disclose. We may also collect and process information classified as “special categories” or sensitive data.

Information you provide about other people will be processed on the basis that you have provided this information with their explicit consent.

The types of personal data that we process may include but not be limited to:

Individual details such as name, address, contact details, martial status, date and place of birth, nationality, employer, job title, family details
Identification details identification numbers issued by government bodies or agencies, including your national insurance number, employers reference number, passport information, tax and driving licence information, utility bills, certificates of incorporation (for businesses)
Financial information bank account and payment card details, income, expenditure or other financial information
Risk information information about you or other persons named or eligible to claim benefits under a policy in order to assess the risk to be insured and provide a quote. This might include data relating to health, criminal convictions, offences, garaging details, mileage details, details of valuable items. For certain types of policy, this could include information such as telematics data.
Policy information Information about the quotes you receive and the policies you arrange
Credit and anti-fraud data see the heading “Credit Searches and fraud prevention” below.
Previous and current claims Information about previous and current claims (including unrelated insurances) which may include data about your health, criminal convictions and surveys.
Special categories of personal data It is possible that special categories of data may be collected through our interactions with you or other parties, in which case we will ensure we meet the additional levels of protection required under the data protection laws.

In the event of an incident or claim we may also collect information from third parties (such as the other party involved in the claim), law enforcement agencies (e.g. the police), witnesses, experts, loss adjusters, loss assessors, solicitors and claims handlers.

We also use “cookies” to collect data when you use our website(s). Further details about cookies and how we use them can be found in our website notices.

We may also collect personal information when you or your representative or anyone named or contact us, for example to ask us a question, or update your personal information.

To ensure that your personal details are protected, we may ask questions to confirm your identity before we can communicate with you or your representative.

What we do with your information
We process and use your personal information to enable us to act as an insurance intermediary and to promote products and services to you. This means we will exchange the information we collect with insurers, other brokers or intermediaries, agents and service providers for this purpose. This includes maintenance of our own accounts and records and to support and manage our staff. Below gives an overview of what we might use your personal information for and whom we might exchange it with:

  • Obtain and Provide quotations and arranging your insurance cover
  • Administering your insurance policies
  • Claims processing or assisting you in your claim
  • Complaint handling
  • Processing renewals and adjustments
  • Complying with our legal or regulatory objectives
  • Debt collection
  • Marketing
  • Premium payment and premium finance arrangements
  • Business transfers (where we sell all or part of our business and/or assets to another party)

We may also need to share your personal information with:

  • Professional advisors and auditors
  • Law enforcement agencies
  • Claims handlers
  • Ombudsmen
  • The MID and MIB
  • Any other party as referred to in this privacy notice
  • Credit reference agencies

We will also use your personal information to:

  • Help train our staff and improve our customer service, website and data bases
  • Help us understand our customers and prospective customers
  • Prevent fraud and other financial crime
  • Ask you to provide feedback to us on the products and services we provide
  • Identify risk and manage risk exposure
  • develop, improve, and personalise the products we offer
  • develop and improve pricing and underwriting and risk selection strategies and processes
  • develop and improve our administration, security systems and insurance applications
  • promote responsible lending and help prevent over-indebtedness

Your contact information will be used to contact you throughout the duration of your policy and may continue beyond that, for example if you have given consent to receive marketing or other communications or make a complaint or a claim is made. Other parties that we share your contact information with may also need to contact you during your policy term and beyond, for example if a claim has been made or you have a complaint.

We will disclose your personal information to insurers, intermediaries, our service providers, contractors, agents and group companies that perform activities on our behalf for these and other purposes described in this policy. We may also disclose your personal information to anyone you have nominated to handle your insurance on your behalf.

To help improve customer service and for quality control and training purposes, telephone calls may be recorded and monitored.

We must make you aware that insurers are legally required to provide details of motor insurance policies to the Motor Insurance Database (MID) managed by the Motor Insurers’ Bureau (MIB). MID data may be used by certain statutory and authorised bodies including but not limited to the Police, the DVLA, the DVANI, the Insurance Fraud Bureau and other bodies permitted by law. Insurers also share information with each other via the Claims and Underwriting Exchange Register (CUE), and the Motor Insurance Anti-fraud and Theft Register, and other data bases (including our own). This exchange of information enables us and insurance companies to verify the information that is provided during the quote or claims process (including information about any third party who is named on the policy) and help prevent fraud.

We must also make you aware that insurers and/or their agents and intermediaries may pass your information to countries within the EU and in some cases may pass your information to countries outside of the EU, for example the United States. On such occasion they must ensure that adequate levels of data protection are in place. The insurers documents will explain how your data will be used.

No Claims Discount database
We may use your no claims discount information to check your entitlement, examine the potential risk in relation to your prospective policy and help prevent fraud. If we do this your information will be checked against the MIB database. Such searches may be carried out against you or the relevant person included on the proposal and may be carried out at point of quote and, if a policy is incepted, at the renewal stage.

Driving Licence Numbers
If you provide your driving licence number this may be passed to the DVLA for a search to be carried out to confirm your (or any named driver’s) licence status, entitlement and relevant restriction information and endorsement/conviction data.

Searches may be carried out as part of your quote and at any point throughout the duration of your insurance policy. A search with the DVLA will not show on your (or the named driver’s) driving licence record. For details relating to information held about you by the DVLA, please visit www.gov.uk/view-driving-licence. Undertaking searches using your driving licence number helps insurers check information to prevent fraud and reduce incidences of negligent misrepresentation and non-disclosure.

We or your insurer may also request your (or another relevant person included on the proposal/insurance policy) driving licence information, licence share code and/or a copy of the photocard at any time, for example when a claim arises or in order to validate information you have provided.

Other forms of physical information
When we arrange and administer your policy we might ask you to provide physical forms of identification which might include (but not be limited to) a copy of your driving licence information, utility bills, bank statements, V5, passports, mileage readings etc.For companies (other than listed ones) this might include but not be limited to of a copy of certificate of incorporation, a list of directors, a list of shareholders and the registered address. We may ask for this information at any time.

Credit searches and fraud prevention
We may check your personal data or exchange it with credit reference agencies, fraud prevention agencies, and other public and privately available sources of information. These checks may include electoral roll and credit information (including credit history and credit score), sanctions, details of criminal offences, county court judgements, vehicle taxation status, MOT status, and bankruptcy. Insurers may also perform these checks as well. We perform these activities to check your identity, assess credit worthiness, credit scoring, help prevent fraud and money laundering.

Such checks are registered as general insurance searches. They will appear on your credit report and may be viewed by other companies when you apply for credit or insurance. These searches should not harm your credit profile or adversely affect your credit profile.

These checks may be performed at any time including at the time of a quote, purchase process or when your insurance is due for renewal. This may happen regardless of whether you get a quote via the internet or phone. We might need to perform these checks on named individuals on your insurance policy or policies, subject to their consent.

If you make an application for credit the premium finance provider may perform a full credit check which will leave a record on your credit report.

Credit reference agencies will keep records of searches and will share information with other organisations, enabling applications for financial products or services to be assessed, to assist in tracing debtors or to prevent fraud. You have the right to access your credit report held by a credit reference agency.

If you deliberately misrepresent or provide false or inaccurate information and we suspect fraud we will record this on our own data bases and may exchange it with fraud prevention agencies or other authorities, for example the Police.

Profiling and automatic decision making
We carry out automated decision making to decide whether we can provide insurance products to you. We may compare your personal data against industry averages. This data may also be used to help us to sell you other products, help us decide which other products might be of interest to you, and help our risk selection processes. Pricing and underwriting decisions may be performed using automated means or with staff intervention or a combination of both. This can also assist us to understand fraud patterns and help combat fraud. We use an automated quote engine to provide insurance quotes, using the information we have collected.

Use of your information for marketing
We carry out analysis of products and services based on your use of our website and other services. Provided you have consented to receive such information from us we may contact you about products and services that may be of interest to you via Post, Email, SMS or Phone.

We do not sell or pass on any client or user information to any third-party companies for marketing purposes, but we may inform you of services or products available from third parties. It is your choice whether you wish to request more information from them. These communications may cover but not be limited to travel, leisure, financial services, charities and shopping.

Remember, if you would prefer not to receive this information from us you can ask us to stop at any time by emailing us at opt-out@grove-dean.co.uk. If you change your mind about how we may contact you, you can also manage your preferences at any time by emailing us at mypreferences@grove-dean.co.uk.

Retention of your personal data
We will keep your personal data for so long as is necessary and for the purpose for which it was collected. In particular, for as long as there is any possibility that either you or we may wish to bring a legal claim or a complaint under your insurance, or where we are required to keep your personal data due to tax, legal or regulatory reasons.

To store your information, we may use storage services which are located within the UK or outside the EEA. Where services are based outside the EEA we will ensure that appropriate measures are in place to remain compliant with our obligations in respect of data protection.

International transfers
When we pass your personal data to insurers, their agents, intermediaries or other service providers you should be aware that they (including their affiliates or sub-contractors) may have offices located outside the European Economic Area (EEA). Transfer of your information should be made in compliance with the applicable data protection laws to ensure your information is properly protected. Your policy documents will set out how your data is used and whether it might be transferred outside the EEA. You should also be aware that those parties and ourselves might use the services of digital storage providers because of the amount of data we collect and process. We ensure that appropriate measures are in place to ensure we only use the services of those providers who meet the standard expected in the applicable data protection laws.

On-line information
We may record information about your computer or mobile device, including hardware and software used and general location when you use or interact with our websites. We use this information to note your interest in our websites, the products and services we offer, and to improve our marketing strategies, customer journeys, and for anti-fraud purposes.

Your rights
You have rights under the Data Protection laws including the right to access the information we hold about you (subject to any legal restrictions that may apply), to have the information corrected if it is inaccurate, and to have it updated if it is incomplete. In certain circumstances you may have the right to restrict or object to processing, and to receive an electronic copy of your data under data portability, or to have your data deleted.

You can withdraw consent to us processing your information at any time however, should you do this we will no longer be able to provide our services or administer any contracts and we will need to cancel any insurance policies or service contracts you hold with us, in order to comply with your request.

If you exercise your rights to object to us using your personal information you can do this at any time by telling us. We will consider your request and either stop using your information or explain why we are not able to.

Sometimes we will not be able to stop using or delete your personal information when you ask us to (for example where we need to use it because the law requires us to do so, or when we need to retain the information for regulatory purposes).

If you have any concerns about the way we use your personal information, please contact:

Data Access Team
Grove & Dean Ltd
Tollgate House
96 Market Place
Romford
Essex
RM1 3ER

For more information about Data Protection or if you wish to complain about how we treat your personal information you can contact the Information Commissioner’s Office at:

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 or 01625 54 57 45
Website: www.ico.org.uk

Tollgate Private Clients. Tollgate House, 96 Market Place, Romford, Essex RM1 3ER
tel: 01708 609609    email: enquiries@tollgateprivateclients.co.uk    web: www.tollgateprivateclients.co.uk

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Tollgate Private Clients is a trading name of Grove & Dean Ltd, an independent intermediary who are authorised
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