Controllers of Personal Information
Our Information Commissioner’s Office reference number is Z9031728
- Under the General Data Protection Regulation (GDPR) you have the right to access or obtain copies of the personal information held about you by us.
- A response to your request will be provided to you within one month of us receiving a valid request. If you wish to exercise this right against our partners you will need to write to them directly. In accordance with the GDPR, we will not charge for this information in most cases.
- You have the right to request that we correct any inaccuracies in the personal information held about you. Please contact us on 0344 381 9990 or contact us if your personal information needs updating.
- You are also entitled to request the removal of your personal data from our records. To do so, please email [email protected], or write to the Data Protection Officer, Sterling Insurance Services, Anglia House, Hallingbury Road, Bishop’s Stortford, Hertfordshire, CM23 5LY. For security reasons, you must include your full name, address and date of birth when writing to us. As long as your request meets our data retention periods, then we will overwrite removing your personal and sensitive information, the remaining data will be used for statistical purposes only.
- You have a right to submit a complaint to the Information Commissioner if you believe we have not complied with our obligations under the GDPR. https://ico.org.uk/global/contact-us/
- Data portability – you have the right to have your data transmitted directly to another data controller where technically feasible.
- You have the right to restrict data processing, where this does not conflict with our contractual obligations, where;
- You contest the accuracy of the personal data we hold
- The processing is unlawful and you oppose the erasure of your data
- We no longer need the data for processing, but the data is required by you for the establishment, exercise or defence of legal claims
- You have objected to the processing of your data pending the verification of whether the legitimate grounds for processing override your objection
- You have the right to object to the automated processing of your data including, but not limited to, profiling. This excludes where the processing is necessary for entering into a contract, or the performance of our contractual obligations.
Uses of Your Data
The data you provide to us will be used by us (or our trusted service providers acting on our behalf) for the following purposes:
Quotation: Your data will be used to provide you with the best quote with our trusted partners in relation to the insurance services you are requesting a quotation for.
Policy administration: Your data will be used for the set up, renewal, and administration of your policy for lawful purposes.
To ensure our insurers and credit providers have the necessary facts to assess your insurance risk, verify your identity, to help prevent fraud and to provide you with their best premium and payment options, they may obtain information from third parties at quotation and renewal and in certain circumstances where policy amendments are requested. This information includes a quotation search from a credit referencing agency. This search will appear on your credit report and will be visible to other credit providers. It will be clear that this is a quotation rather than a credit application by you to pay by monthly instalments.
We may use scoring methods to assess this application. This information may also be used for debt tracing and the prevention of money laundering as well as the management of your account. Alternatively, we may ask you to provide physical forms of identification.
- Customer Services: Should you need to query, amend or cancel a policy you have taken up with us, we will use your personal data to assist you with the action or enquiry you are contacting us for.
- To contact you in any way (including mail, email, telephone, text or multimedia messages) about products and services offered by us and/or carefully selected partners unless you have previously asked us not to do so. You can opt-out of receiving such information at any time by contacting us.
- Profiling: We will pass your data to Fast Stats for profiling in order to help us tailor products that will suit your needs. To opt out of data profiling, please email [email protected]
- To show you advertising showcasing our products and services that we think will be of interest to you when you visit other sites around the internet. To help us ensure that you see the most relevant advertisements possible via non-identifiable tracking via services including Google Analytics remarketing, demographics and interest retargeting and Facebook custom audiences. To opt out of these services, you can visit https://tools.google.com/dlpage/gaoptout/ and http://www.youronlinechoices.com/uk/your-ad-choices
Data We Collect
We collect personal data and sensitive personal data as part of providing services to you. We may also monitor or record calls, emails, SMS messages or other communications in accordance with UK and European law.
Types of data we may collect
Examples of personal data we may collect includes:
- Name, address, date of birth and gender
- Telephone numbers and email address
- Occupation and other lifestyle information
- Credit/debit card details
- Claims history
Sensitive personal data
Examples of sensitive personal data we may collect includes:
- Medical history
- Criminal convictions
Call recording and monitoring
We monitor or record calls, emails, SMS messages or other communications for:
- Business purposes such as quality control and training
- Processing necessary for entering into or performance of a contract
- Prevention of unauthorised use of our telecommunication systems and websites
- Ensuring effective systems operation
- Meeting any legal obligation
- Protecting your vital interests
- Prevention or detection of crime
- The legitimate interests of the data controller
If you have a telematics device, as part of your policy you are required to fit, activate and keep charged a telematics device that will monitor your vehicle and how it is driven. The data received from your device is used, together with data collected from other 3rd party data sources, to:
- Determine an accurate renewal premium based on how the vehicle is driven.
- Calculate mileage driven against the mileage endorsed on your policy – we will contact you if this is exceeded.
- Confirm that you are operating your device in compliance with your terms
- Validate that the underwriting details given are in accordance with your Statement of Fact.
- Cancel your policy if the vehicle is not driven in accordance with the highway code
- Advise you of adverse weather events that may impact road conditions
- Send notifications and information to help you remain compliant with the terms of your policy
- Help understand the circumstances of any accident or claim, loss or theft and help determine fault
- Help prevent and detect fraud
- Perform statistical analysis to assist us in product assessment and future development
Information recorded from your telematics device, your Smartbox, will be assessed automatically to generate your driving Smartbox score. This Smartbox score will be based upon a review of your location, direction of travel, time of day, speed and overall journey. This data will be assessed against our internal models of driver behaviour to generate your Smartbox Score. You may review your journeys and see how much money you have saved on your renewal via your Smartbox app.
The telematics Smartbox does not identify who is driving the vehicle but telematics data and our assessments of driving behaviour may be linked to an individual, for example when we discuss driving feedback with the policyholder, and in the event of a claim.
Open Source Data – Information about you or other drivers that is public accessible such as the electoral roll, court judgments, insolvency registers, internet search engines, news articles and sources licensed under the Open Government
We do not sell your data to third party companies. We may share your data with selected third parties for:
- Making credit decisions – with your consent we will carry out a credit check which may be used to make insurance decisions about you. If you elect to pay your insurance by monthly instalments it will also be used to make decisions about your creditworthiness. If you are paying by monthly instalments your data will also be shared with Premium Credit Limited with your consent, who we use for finance agreements.
- Marketing – if you ask for a quote from us we may pass your data to Maze Media, on the basis of legitimate interests, who may contact you in any way (including mail, email, telephone, text or multimedia messages) about products and services offered by us and/or carefully selected partners regardless of whether you take out an insurance policy with us. You can opt out of marketing at any point by emailing your request to [email protected]
- Claims handling – in the event of a claim your details will be passed to Coplus, on the basis of contractual requirement, who we use for claims handling.
- Telematics – if you have a telematics device, we will share your data with iTelematiX Limited, on the basis of contractual requirement, who are the joint controllers of you telematics data.
- Other insurers – we will provide information relating to No Claims Bonus, claims history and motoring convictions with other insurers, brokers and intermediaries.
- Prevention of fraud, accuracy of data, and No Claims Bonus – we may share data relating to No Claims Bonus and vehicle modifications with LexisNexis for any of these purposes.
- Documents – most documents that are sent in the post are provided by Opus Trust Communications, who we use for external printing.
- Reporting – if a policy is purchased via a price comparison website or Just Kampers Insurance Service, we provide a record of the purchase and any cancellation to them.
- Card payments – we use Opayo UK to securely process card payments.
- Propensity to claim – we may share data with Machine Learning Programs, on the basis of legitimate interests, to assess the likelihood that a claim will be made. You can visit their privacy notice at https://www.mlprograms.com/privacy-notice/.
- Propensity to commit fraud – we may share data with Machine Learning Programs, including special category data, on the basis of legitimate interests and for the prevention of fraud, to assess the likelihood that fraud will be committed. You can view their privacy notice at https://www.mlprograms.com/privacy-notice/.
- Debt collection – any monies owed on your policy may be passed to a debt collection agency if payment is not made direct to us within a reasonable period of time. We will do this on the basis of legitimate interests.
- Web Chat – we use Talkative to host our web chat facility enabling us to talk you through the pages or processes and permit co-browsing to your session no other parts of your web or system are accessed. This is initiated by you and you can end at any time. We share this data on the basis of legitimate interests.
- Motor Insurance Database – Information relating to your insurance policy will passed to the Motor Insurance Database (MID) managed by the Motor Insurers’ Bureau (MIB). MID and the data stored on it may be used by certain statutory and/or authorised bodies including the Police, the DVLA, the DVLNI, the Insurance Fraud Bureau and other bodies permitted by law for purposes not limited to but including:
- Electronic Licensing
- Continuous Insurance Enforcement;
- Law enforcement (prevention, detection, apprehension and or prosecution of offenders)
- The provision of government services and or other services aimed at reducing the level and incidence of uninsured driving.
- Other Adrian Flux Insurance Group Companies – we may also use information that you have provided to other companies withing the group.
Data Retention Policy
Information submitted for a quotation may be retained by us for a period of 24 months from the date of quotation. Policyholder information will be held for a period of at least 6 years after the ending of the client/insurer relationship.
Quotation data received from aggregators is stored in a separate database on a separate server and stored for a maximum period of 90 days. Any quotation data received from aggregators that is replicated across to our call centre database for any reason is retained on that database for a period of 30 days and then deleted.
All call recordings will be retained for a period of at least 6 years. All emails and documents received will be retained for a period of at least 6 years.
Over the years we have successfully negotiated large discounts for our customers and have only been able to do this because of the quality of the business we provide to our insurer partners. It is vital that we protect these discounts, enabling us to continue offering our customers fantastic prices on great products.
This additional paperwork does generate more work for you and for us, but ultimately our customers benefit from our stringent quality control of new policies. It allows us to accurately underwrite a policy and provide correct cover and pricing, particularly should new information come to light which we were previously unaware of.
A few minutes of your time sending us the documents requested will allow us to continue offering some of the most competitive rates found anywhere in the UK insurance market.
Driving Licence Number (“MyLicence”)
The number is used to do an automatic check with the DVLA driver database, to retrieve the required information. The provided information is:
- Type of licence held
- Length of time the licence has been held for
- Entitlements to drive
- Penalty points
- Conviction dates
Fraud Prevention, Detection and Claims History
In order to prevent and detect fraud we may at any time:
- Share information about you with other organisations and public bodies including the Police check and/or file your details with fraud prevention agencies and databases and, if you give us false or inaccurate information and we suspect fraud, we will record this with ourselves, these agencies and databases. We and other organisations may also search these agencies and databases to:
- Help make decisions about the provision and administration of insurance, credit and related services for you and members of your household trace debtors or beneficiaries, recover debt, prevent fraud and to manage your accounts or insurance policies check your identity to prevent money laundering.
- Undertake credit searches and additional fraud searches. We can supply on request further details of the databases we access or contribute to.
For statistical analysis and to track how many individual unique users we have and how often they visit our websites. We collect data listing which of our pages are most frequently visited and by which types of users and from which countries.
We use third parties, such as Google Analytics, Google Adwords, DoubleClick, Microsoft Bing, Clicktale, to collect completely anonymous user information which is gathered through cookies. These help us gauge our effectiveness in meeting users’ needs, and improve our service to you.
We use session cookies to help you navigate through the site and show you useful information, such as helpful phone numbers. Session cookies also enable you to use services such as online quotes, customer contact forms, callbacks, and online policy administration.
You can turn cookies off, but if you do this you may not be able to use all of the services available on our sites. You will still be able to view the majority of the informational content on the site.
For more information about cookies and managing them, including how to turn them off, please visit http://www.aboutcookies.org/
Third Party Websites
We cannot be held responsible for the privacy policies and practices of other websites linked to our websites. We do take great care in ensuring only links to companies, organisations and individuals following the same standards and policies as us remain on our website, but we cannot guarantee this. In such instances, you are advised to check the privacy policies on external websites that are not a part of the Adrian Flux Insurance Services Group.