Privacy notice
Privacy Notice
We Underwriting & General Insurance Services Ltd (also referred to as ‘UGIS’, “we”, “us”, or “our”) are a registered company in England (Company no 04013173). Our registered address is 321 Chase Road Southgate, London N14
This Notice 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 Notice describes how we collect, use, share, retain and safeguard personal data.
This Notice sets out your individual rights; We explain these later in the Notice 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, address, date of birth, 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.
In order for us to arrange and administer insurance for you we will collect and process personal data about you. We will also collect your personal data where you request information about our services, customer events, promotions and campaigns.
We may also need to collect personal data relating to others in order to arrange 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.
You may provide us with personal data when completing online quote or contact forms, when you contact us via the telephone, when writing to us directly or where we provide you with paper-based forms for completion or we complete a form in conjunction with you.
We will collect your personal data when you visit our Website, where we will collect your unique online electronic identifier; this is commonly known as an IP address.
We will also collect electronic personal data when you first visit our Website where we will place a small text file that is commonly known as a cookie on your computer. Cookies are used to identify visitors and to simplify accessibility, and to monitor visitor behaviour when viewing Website content, navigating our Website and when using features. For more information please see our Cookie Policy.
We may record your communications with us when contacting our customer care, complaints and other customer focused functions. We also collect personal data through the use of telemetric or similar location tracking services, where you have agreed to the use of this particular service.
Where we collect data directly from you, we are considered to be the controller of that data i.e. we are the data controller. Where we use third parties to process your data, these parties are known as processors of your personal data. Where there are other parties involved in underwriting or administering your insurance they may also process your data in which circumstance we will be a joint data controller of your personal data.
Legal Basis for processing your Personal Information
We are required to have a lawful basis (as defined in the legislation) in order to process your personal data and the relevant bases which we use are shown below:-
Purpose of Processing
Providing quotations; arranging and administering insurance policies .
Provision of Information on products and services (Marketing)
To notify you of changes in our service
To detect and prevent fraud, money laundering and any other financial crimes.
To meet general legal or regulatory obligations
Statistical analysis
Lawful Basis
Necessary for the performance of an insurance contract
Our legitimate interests of your explicit consent
Our legal and Regulatory obligations
Our legitimate interests – to refine and enhance the products and pricing which we can offer.
Disclosure of Personal Information
We will share your personal data within our firm, group of companies, business, including affiliates, subsidiaries and with business partners. 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:
- Insurers;
- Underwriters;
- Premium finance providers;
- Credit reference agencies;
- Debt recovery agencies;
- Claims handling companies;
- Loss adjusters;
- Insurance brokers;
- Reinsurers;
We may share your personal information with third parties only in the ways that are described in this Privacy Statement:
We may provide your information to insurers, intermediaries and third-party service providers that we use for the purposes of arranging and administering your insurance policy on your/our behalf;
We may provide your information to our service providers who perform functions on our behalf such as IT services, finance providers, claims handling and other support services. Usually, our service providers sign a standard service and / or confidentiality agreement in such cases;
We may share your data with any parent company, subsidiaries, joint ventures, other entities under a common control or third-party acquirers. We would direct these other entities will honor this Privacy Statement;
We may allow a potential acquirer or merger partner to review our databases, although we would restrict their use and disclosure of this data during the diligence phase and direct them to treat the data confidentially; as required by law enforcement, regulatory bodies, government officials, or other third parties pursuant to a court order, or other legal process or requirement applicable to our Company; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our agreements or Company policies; and other third parties with your consent or direction to do so.
Please note that these third parties may be in other countries outside of the UK and the European Union where the laws on processing personal information may differ. We will only do so where we are satisfied that sufficient levels of protection are in place as required by applicable data protection laws.
Data Controller
A “data controller” means the individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data.
A “data processor” means the individual or organisation which processes personal data on behalf of the controller.
As a provider of insurance services, we will process the following categories of data:
- Personal data such as an individual’s name, address, date of birth, gender, contact details and details of historic claims
- Special categories of personal data such as health and details on historic claims resulting in injury (physical and physiological)
- Data relating to criminal convictions and offences such as details of driving offences or insurance fraud
If you object to the collection, sharing and use of your personal data we may be unable to provide you with our products and services.
For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the named territory where the processing of personal data takes place.
If you require more information about our insurance processes or further details on how we collect personal data and with whom we share data with, please contact our ‘data privacy by e-mailing info@ugis.co.uk
Why do we need your personal data?
We do not sell personal information to third parties.
We will use your personal data for the performance of our contract with you, to quote for and provide you with insurance products and services, to process claims and renewals, to administer your policy and our business, to respond to any requests from you about services we provide and to process complaints. We will also use your personal data to manage your account, perform statistical analysis on the data we collect, for financial planning and business forecasting purposes and to develop new and market existing products and services.
We will use the special category and criminal conviction data we collect about you for the performance of our contract with you which is deemed to be necessary for reasons of substantial public interest. This allows us to quote for and provide you with insurance products and services, to process claims and renewals and to administer your policy.
In purchasing our products and services you should understand that you are forming a contract with us. If you contact us for a quote or request details on the services we provide, we consider ourselves as having a legitimate business interest to provide you with further information about our services.
In some situations we may request your consent to market our products and services to you, to share your data or to transfer your data outside the European Economic Area. Where We require consent, your rights and what you are consenting to will be clearly communicated to you. Where you provide consent, you can withdraw this at any time by contacting our data protection officer.
Retention
We will retain your personal data at the end of any contractual agreement for a period of 6 years unless insurance cover involved Liability Cover, in which case we would retain the personal data for 12 years.
We will retain special category and criminal conviction data for a period of 6 years.
Where you have submitted a claim, we will retain your data for a period of 6 years if it is a non-injury claim; where an individual has been injured (physical and physiological), we will retain your data for 12 years.
Where you have requested a quote, we will retain your personal data for 2 years, where you have contacted us for details of our services and products we will retain your personal data for 2 years.
Where you make a complaint we will retain the data for 6 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.
Automatic Decision Making & profiling
You should be aware that we use automated decision making (services/tools and techniques) to check for customer suitability to our products, for example we might perform a credit search to check an individual’s solvency and credit rating. We also analyse data to identify products and services that customers may be interested in; this is commonly known as profiling. You have the right to object to the use of profiling activities and the use of automated decision making (services/tools and techniques).
Please contact our data protection officer if you object to the use of, or you have any questions relating to the use of, your data, the retention of your personal data or the use of profiling and automated decision making services/tools and techniques. You can opt out of receiving marketing services by e-mailing info@ugis.co.uk requesting to opt out.
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:
- The right to be informed about the personal data being processed;
- The right of access to your personal data;
- The right to object to the processing of your personal data;
- The right to restrict the processing of your personal data;
- The right to rectification of your personal data;
- The right to erasure of your personal data;
- The right to data portability (to receive an electronic copy of your personal data);
- Rights relating to automated decision making including profiling.
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 protection officer by e-mailing info@ugis.co.uk or by writing to Solar House 282 Chase Road, London N14 6HA.
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 firm, group of companies, business, including affiliates, subsidiaries and authorised third parties.
To comply with our legal obligations and to ensure data privacy and protection has appropriate focus within our organisation we have a Data Protection Officer who reports to our senior management team. The Data Protection Officer’s contact details are as follows: 0208 920 7820.
If you are dissatisfied with any aspect of the way in which we process your personal data please contact data protection officer. 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 which is https://ico.org.uk/concerns/, by live chat or by calling their helpline on 0303 123 1113.
If you have any questions regarding this Notice, the use of your data or your Individual Rights please contact our data protection officer at Solar House, 282 Chase Road, London N14 6HA or by e-mailing info@ugis.co.uk or by telephoning 0208 920 7820.