Privacy Policy

Introduction

Here at Red Seal, we are totally committed to keeping your personal data safe. We will always treat your personal data with respect and design our products and services with your privacy in mind.

This privacy policy will help you understand how we collect, use and protect your personal data. You should also show this notice to anyone else who may be insured with us.

You acknowledge that by providing your personal data to us, you consent to its processing in the manners outlined below. When providing personal data about others, you confirm that you have the consent of these individuals to supply their personal data. We are unable to offer you any product or service that requires the processing of special category personal data, as defined in the General Data Protection Regulation (GDPR), unless you provide explicit consent for the collection and use of such data.

Data we collect

We collect personal data and special category 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 law.

Types of data we may collect

Personal Data

Examples of personal data we may collect include:

Names and titles
Physical address and address history
Contact details including telephone numbers and email address
Date of birth
Gender
Lifestyle and other information

Special category personal data

Examples of special category personal data we may collect include:

Medical history
Claims history
Criminal conviction and CCJs

We may also indirectly collect other special category personal data during the course of any fraud investigations.

Call recording and monitoring

We monitor and 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
For the legitimate interests of our data controller

Telematics

If you have a Telematics Unit, we will use the Unit to capture data include date, time, speed, location and other associated vehicle and driving related information from your vehicle. The information includes:

Date
Time
Latitude
Longitude
Speed
Duration
Distance
Acceleration
Braking
Cornering
Other associated vehicle information

Our Telematics systems normally collect information while your vehicle is being used, and transmit this to us and/or our suppliers some time later. Instances where the Telematics systems may send real-time data and alerts to us include where a collision or crash is detected, if the device’s tamper alerts are activated, or if it is at your request, for example if your vehicle has been stolen and a Theft Tracking service has been activated.

When is data collected

We will collect your personal data when:

You ask for a quote
You make enquiries through a price comparison website
You purchase our products and services or those provided by our service partners
You make customer enquiries
You register for information or other services
You register a claim
You respond to communications or surveys
We require additional information from you for validation purposes

How your data is used

Processing your quotes
Administering your policy, including claims handling
Fraud prevention and detection
Credit scoring or other automated decision-making systems
Administering debt recoveries
Verifying your identity when required
Undertaking market research, product development and statistical purposes
Keeping you informed about promotions and new developments by email, telephone, SMS, social media or post
Processing renewal of your policy
For assessment and analysis to enable us to review, develop and improve the services which we offer
We may use your information to make decisions about you using computerised technology to profile you, such as assessing which products might be most suitable for you.

Legitimate Interests

There are certain circumstances where we process your personal data for our legitimate business interests. These can be commercial or societal benefits and in order for us to process your data, we will always balance our interests against your own to ensure it is fair.

The following processes rely on legitimate interest:

Fraud detection and prevention across Red Seal
Engaging and contacting you throughout the lifecycle of your policy or claim to ensure you have a good experience as a Red Seal customer
Setting reserves for our claims
Internally auditing our processes to maintain our high standards
Use of your quote data (whether you accepted a policy or not) to refine pricing models and improve the accuracy of our premiums
Sharing data with selected third parties in order to add value to our products

Claims Underwriting Exchange (“CUE”)

As part of the quote process we exchange information with the Claims Underwriting Exchange which holds a record of incidents reported to insurers, which may or may not have given rise to a claim. We do this in order to verify the information provided about you or any individual who is named on the quotation or policy during the quote process.

Driving Licence Number (MyLicence)

We may collect your Driving Licence Number (DLN or “MyLicence”) as part of your claim application.

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
Convictions
Conviction dates
Disqualifications

The data provided by the DVLA may be used alongside other information you have provided:

To calculate a motor insurance quote
To administer the policy
For anti-fraud purposes

They will not be used for any other purpose, or be made available to anyone else. Only the motor insurance industry may use this information. If you apply for a quote with us and don’t decide to take out insurance with us, the data returned from the DVLA database will be anonymised or deleted no later than 30 days after receipt of that data.

Searches may be carried out prior to the date of the insurance policy and at any point throughout the duration of your insurance policy including at the mid-term adjustment and renewal stage.

We may also use your DLN to search your (or any person included on the proposal) ‘No Claims Bonus’ details against a No Claims Bonus database (“NCB”) to obtain information in relation to your ‘No Claims Bonus’ entitlement.

Such searches may be carried out against your (or the relevant person included on the proposal) DLN, name, date of birth, Vehicle Registration Mark (“VRM”) and or postcode. A search of the DLN against the NCB should not show a footprint against your (or another relevant person included on the proposal) driving licence

Please note that under our User Agreement with the Motor Insurance Bureau, individual agents do not have access to the data returned by a DLN search and as such will not be able to discuss issues relating to your DLN with you. In these instances, we suggest checking the information associated with your DLN is correct at www.gov.uk/view-driving-licence

For details relating to information held about you by the Driver and Vehicle Licensing Agency (“DVLA”) please visit www.dvla.gov.uk and www.mylicence.org.uk. To view your driving licence, visit www.gov.uk/view-driving-licence.

Claim process

To ensure an efficient and speedy claim process we will take instruction from you or any other person provided they are named on the policy. If you would like someone else to deal with your claim on your behalf please let us know.

If you give us data about another person, in doing so you confirm that they have given you permission to provide it to us to be able to process their personal data (including any special categories of data) and also that you have told them who we are and what we will use their data for, as set out in this policy.

Our use of your data at renewal

Your claims data is passed onto our underwriters to account for any no claims bonus.

Telematics

We and joint controller companies we partner with to administer Telematics products will use the data captured by the Telematic Unit for the purposes of:

Calculating and charging insurance premiums based upon actual vehicle usage, and compiling and generating Driving Scores.
Controlling your personal data for the purpose of providing you with services relating to the insurance policy. We will process your data in accordance with our responsibilities under the General Data Protection Regulation (GDPR).
Carrying out the installation, activation, deinstallation, disconnection, servicing, updating or testing of the Telematic Unit.
General research and analysis, mapping purposes, researching and refining techniques for analysing motor Telematics data and the supply of traffic data. In all such circumstances the data will be used anonymously and will not identify any individual, vehicle user, or the policyholder.
Enabling us, joint controller companies and any service partners, to contact you by post, electronic mail, telephone or text messaging regarding the administration of your insurance policy and the associated services.
Provision of the insurance services under the policy, including management of claims, underwriting and policy servicing. Data will be used for any underwriting or claims development or investigations that may be required, and for fraud prevention, detection and investigation purposes.
Please note that where the telematics unit indicates a severe crash has occurred, we will try to contact the policy holder and the named driver to offer assistance. If they cannot be reached, we will try to reach anyone else named on the account. If we are unable to make contact with any of those persons named on the account then we will contact the emergency services with details of the vehicle, its last known location, and the names of those individuals named on the policy.

Dealing with other people

All policies must have an Administrator.

The Administrator must be a Policyholder within the current Period of Insurance and will be our primary point of contact in relation to the administration of the policy.

The Administrator:

Will have access to all documentation, information and personal data relating to all Insured(s) on this policy
Can nominate another Policyholder to become the Administrator
Can make any change to all parts of the policy
Can cancel the whole policy in line with General Condition of your Policy

With the exception of cancellation (General Condition), it is our policy to deal with those named on your policy or any acceptable callers. The ways in which we may deal with those named on your policy or any acceptable callers include adding or removing vehicles to the policy.

An acceptable caller is:

a Policyholder
Named Driver
the spouse, partner or parent of a Policyholder
a Secretary or Personal Assistant where added by a Policyholder
any other person or organisation that provides evidence that they have authority to act on behalf of the Policyholder and passes our data protection procedure

Who has access to your data

Apart from ourselves, other companies that may have access to your data include:

Companies within Red Seal
In the event that we undergo re-organisation or are sold to a third party, in which case you agree that any personal data we hold about you may be transferred to that re-organised entity or third party.

How your Telematics Data is shared

Telematics data will only be disclosed to other parties in the following circumstances:

To the joint controller Telematic Service Providers we use to collect and transmit Telematics information. The service provider in question may vary depending on the type of Telematics product and/or device you have chosen. Further details can be found in your policy guide.
To our agents, partners and subcontractors for operational reasons, including providing the agreed services under the policy.
To parties whom we are required by law to disclose data to, such as our regulators or if we are issued with a court order.
To other parties with your permission, as outlined in the ‘Confidentiality and Disclosure of your Data’ section of this privacy statement.

Your data may also be shared with the relevant insurance and claims databases, in accordance with this Privacy Policy, as detailed above.

Confidentiality and disclosure of your data

We will endeavour to treat your personal data as private and confidential. From time to time we will employ agents and subcontractors to process your personal data on our behalf. The same duty of confidentiality and security will apply to them and all processing will be carried out under our instruction.

We would like to bring to your attention our obligations to disclose data in the following four exceptional cases permitted by law, and the other situations set out below. These are:

Where we are legally compelled to do so
Where there is a duty to the public to disclose
Where disclosure is required to protect our interest
Where disclosure is made at your request or with your consent

In the unfortunate event that you have to make a claim then we will need to disclose data with any other party involved in that claim. This may include:

Third parties involved with the claim, their insurer, solicitor or representative
Medical teams, the police or other investigators

If you make a complaint about the service we have provided, we may be obliged to forward details about your complaint, including your personal data, to the relevant ombudsman. You can be assured that they are similarly obliged to adhere to all applicable data protection legislation and keep your personal data strictly confidential.

Please note that we make a number of checks to assess your application for credit and verifying identities to prevent and detect crime and money laundering, as well as data sharing at any time for the purposes of fraud prevention. These checks may also include your DLN/MyLicence.

Using data obtained from your DLN, we may pass details of your ‘No Claims Bonus’ to certain organisations to be recorded on an NCB database. This may occur if information requires updating or correcting at any stage, and also at the renewal stage of your policy and upon or after the cancellation of your policy prior to the expiry date.

Data subject rights

You have a number of rights as a data subject. Please note that these rights do not apply in all circumstances.

Request your data

In order to access the data we hold about you, you need to make a ‘Subject Access Request’, or SAR. To make a SAR please email us at:

admin@redsealclaims.com

Please provide

Your name, address, policy/claim number and what information you would like.
Identification documents; one which shows your name and signature (e.g. a copy of your passport) and one which shows your name and address (e.g. a copy of a recent bill or bank statement or other official document). We will accept just one identification document if it shows your name, address and signature such as a copy of your driving licence. (This is to take reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you.)

Please note that if your SAR involves personal data of other people (such as named drivers on your policy) or you are making a request on behalf of another (such as a parent on behalf of their child), we will need identification from these individuals, as well as a signed letter of authority from them that they are happy for you to act on their behalf and for us to release their data to you.

Once we have received your request and identification documents, we will have one month to fulfil your request. Where for some reason this will not be possible, for instance due to large volumes of data being involved, we are permitted by law to take up to an additional two months to fulfil your request. Where any such delay is anticipated we will inform of you this as soon as possible along with details of when we expect to be able to provide you with the requested documentation.

Your other rights as a data subject, where applicable, include:

The right to be informed about our processing of your personal data
The right to have your personal data corrected if it is inaccurate, and to have incomplete personal data completed
The right to object to the processing of your personal data
The right to have your personal data erased (“right to be forgotten”)
The right to move, copy, or transfer your personal data (“data portability”)
Rights regarding automated decision making, including profiling

For more details on these rights and how to exercise them, please contact:

admin@redsealclaims.com

If you have any queries about your rights, or believe that they have not been met by Red Seal or any of the companies within the group, please contact our Data Protection Officer at:

admin@redsealclaims.com

If you have any complaints relating to the processing of your personal data, you also have the right to complain to the relevant Supervisor Authority. In the UK this is the Information Commissioner’s Office (ICO). They can be contacted at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Use of your data for fraud and money laundering prevention & detection and credit decisions

Fraud prevention

In order to prevent and detect fraud, we may at any time share information about you with members of Red Seal.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identify.

If false or inaccurate information is provided and fraud is identified, you could be refused certain services, finance, or employment and details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information.

We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

checking details on applications for credit and credit related or other facilities
managing credit and credit related accounts or facilities
recovering debt
checking details on proposals and claims for all types of Insurance
checking details of job applicants and employees

We and other organisations may access and use, from other countries, the information recorded by fraud prevention agencies.

For further details on how your information will be used by us and these fraud prevention agencies, and your data protection rights, please contact us at admin@redsealclaims.com

Credit reference

When you apply to us to open an account, at renewal, and in certain circumstances where an amendment to your agreement is requested, we make a number of checks to assess your application for credit and verifying identities to prevent and detect crime and money laundering. To obtain this information, we will check the following records about you and anyone else who may also be insured and whose personal details have been provided as part of the insurance application.

Our own records.
Credit Reference Agency (CRA) records. When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. They supply us with both public (including the electoral register), and shared credit and fraud prevention information
Fraud Prevention Agency (FPA) Records

We make searches about you at credit reference agencies who will supply us with information, including the Electoral Register and credit information. The agencies will record details of the search whether or not your application proceeds. The searches will not be seen or used by lenders to assess your ability to obtain credit. We may use scoring methods to assess this application and to verify your identity.

Credit searches and other information which is provided to us and/or the credit reference agencies, about you and those with whom you are linked financially, may be used by ourselves and other companies if you, or other members of your household, apply for other facilities including insurance and loans applications and claims. 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.

If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to breach that link.

We may also make periodic searches at CRAs and FPAs to manage your account with us.
Information on applications will be sent to and recorded by CRAs. When you borrow from us, we will give details of your account(s) and how you manage it/them to CRAs. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for six years after they are closed, whether settled by you or defaulted.

If you give us false or inaccurate information and we suspect or identify fraud, we will record it and may also pass this information to FPAs and other organisations involved in the prevention of crime and fraud.

If you borrow from us and do not make payments that you owe us, we will trace your whereabouts and recover debts.
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or to employ you, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us using the details provided below.

Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the GDPR.

How to find out more

This is a condensed guide to the use of your personal information for credit reference purposes. If you would like to read the full details of how your data may be used please contact us at admin@redsealclaims.com

You can contact the CRAs currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They will charge you a small statutory fee.

Call Credit: Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 060 0550 or log on to www.callcredit.co.uk.
Equifax: Credit File Advice Centre, PO Box 1140, Bradford, BD1 5US or call 0844 355 0550 or log on to www.equifax.co.uk.
Experian: Consumer Help Service, PO Box 8000, Nottingham, NG80 7WF or call 0844 481 8000 or log on to www.experian.co.uk.

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at:

Please contact us at admin@redsealclaims.com if you want to receive details of the relevant fraud prevention agencies.

When you make a claim

If necessary we may also have to investigate your claims and conviction history in the course of administering the claim. You can be assured that we will keep such investigations strictly confidential.

We pass information to the Claims and Underwriting Exchange Register and, in the case of motor insurance, the Motor Insurance Anti-Fraud and Theft Register, both of which are managed by the Motor Insurance Bureau (MIB). This helps insurers check information and prevent fraudulent claims. When we deal with your request for insurance we may search these registers. Under the conditions of your policy, you must tell us about any incident (such as an accident or theft) which may give rise to a claim. When you tell us about an incident we will pass information to the Registers.

Information relating to your motor insurance policy will be added 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 DVANI, 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

If you are involved in a road traffic accident (either in the UK, the EEA or certain other territories), insurers and/or the MIB may search the MID to obtain relevant information.

Persons (including their appointed representatives) pursuing a claim in respect of a road traffic accident (including citizens of other countries) may also obtain relevant information which is held on the MID.

It is vital that the MID holds your correct registration number. If it is incorrectly shown on the MID you are at risk of having your vehicle seized by the Police. You can check that your correct registration number details are shown on the MID online at www.askmid.com, or by writing to:

Motor Insurers’ Bureau
Linford Wood House
6-12 Capital Drive
Milton Keynes
MK14 6XT

Fraud prevention and detection

In order to prevent and detect fraud, insurers may at any time share information about you with members of Red Seal.

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 and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

- - checking details on applications for credit and credit related or other facilities
  - managing credit and credit related accounts or facilities
  - recovering debt
  - checking details on proposals and claims for all types of Insurance
  - checking details of job applicants and employees

MyLicence

As part of our fraud prevention and detection measures, we may undertake searches against your (or any person included on the proposal) DLN against details held by the DVLA to confirm your licence status, entitlement and restriction information and endorsement/conviction data. This helps insurers check information to prevent fraud and reduce incidences of negligent misrepresentation and non-disclosure. A search of the DLN with the DVLA should not show a footprint against your (or another relevant person included on the proposal) driving licence.

Please contact us at admin@redsealclaims.com if you want to receive details of the relevant fraud prevention agencies.

We may exchange your details such as NCB, DLN and Claims records with insurance industry databases for the purpose of validation and financial crime prevention.

We and other organisations may access and use, from other countries, the information recorded by fraud prevention agencies.

Retention of your data

Your personal data will be kept for as long as we require it in order to provide you with the agreed product(s) or service(s). It will continue to be retained after any account, policy or service has been closed or otherwise come to an end in line with our legal and regulatory requirements, and for as long as you may legally bring claims against us.

Changes to this policy

This privacy policy was last updated on 12th February 2019. We reserve the right to make changes to this policy and you will be informed of any changes when you next visit our website.

From time to time we may need to change the way we use your personal data. Where we believe you may not reasonably expect such a change we will write to you. When we do so, you will have 60 days to object to the change but if we do not hear from you within that time you consent to that change.