First Underwriting Ltd is the data controller and processor in respect of your personal data. This means that we decide how your personal data is processed and for what purposes, and process your personal data.
We comply with our obligations under the GDPR by keeping personal data up to date, by storing and destroying it securely, by not collecting or retaining excessive amounts of data, by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
Use of Personal Information
We use personal information for the following purposes:-
- To assess your request for insurance, provide a quotation and administer your policy;
- To undertake the performance of a contract of insurance to which you are a party;
- To administer your claims and third party claims;
- To prevent fraud and financial crime;
- Statistical analysis and management information;
- Audits, system integrity checking and risk management;
- To send marketing information about our products and services if we have received specific consent.
There is no obligation to provide us with personal information, but if you do not, we may not be able to provide products or services or administer claims.
Profiling and Automated Decision Making
We may use automated decision making, which includes profiling in our assessment of insurance risks and for the administration of policies. This is used to help us decide whether to offer insurance, determine prices and validate claims.
Collection of Personal Information
We collect the following types of personal information to allow us to complete the activities described under ‘use of personal information’ above:-
- Individual details such as name, address, phone numbers, age, gender, marital status, dependents, employment status and job title;
- Financial details such as bank account or credit card information;
- Identification details such as driver licence number, passport number or national insurance number;
- Tracking, telematics, camera or video records if it is relevant to the insurance policy or the claim;
- Background insurance checks including previous policy information and claims history;
- Special categories of data including health, disability, motoring convictions and criminal convictions.
Where we collect Personal Information From
We may collect information about you from the following sources:-
- You or your family members;
- Your representatives;
- Information you have made public (such as via social media);
- Credit reference or fraud prevention agencies; this includes Call Credit, who’s privacy notice can be found at https://www.callcredit.co.uk/legal-information/bureau-privacy-notice
- Emergency services, law enforcement agencies, medical and legal practices;
- Insurance industry registers and databases used to detect and prevent insurance fraud, for example, the Motor Insurance Database (MID), the Motor Insurers Anti-Fraud and Theft Register (MIAFTR) and the Claims and Underwriting Exchange (CUE)
- In the event of a claim, insurance investigators, claims service providers, claimants or witnesses;
- Other service providers or provider services for our products.
Sharing of Personal Information
We may need to share your personal information with other recipients which could include:-
- Approved service providers or suppliers or other group companies that provide support services;
- Fraud prevention or credit reference agencies or other agencies that carry out work on our behalf such as the Motor Insurers Database (MID) or the Insurance Fraud Bureau (IFB);
- Other insurers, reinsurers, underwriters, regulators, law enforcement, Ombudsman Services or the Claims and Underwriting Exchange (CUE);
- Purchasers of the whole or part of our business.
Retention of Personal Information
We keep personal information only for as long as is necessary to administer the policy or manage our business or as required for legal or regulatory purposes.
Use and Sharing of Special Categories of Personal Information
Special categories of personal information under Data Protection Legislation include medical history, disabilities, motoring or criminal convictions. We may need to collect and process this information for the purposes of evaluating the risk and/or administering your policy or a claim. You or any person covered under this policy must provide explicit verbal or written confirmation to such information being processed by us.
We will only share this information in accordance with appropriate laws and regulations or where it is essential to administer the policy or when dealing with a claim. First Underwriting Ltd is authorised and regulated by the Financial Conduct Authority. All policies are underwritten on behalf of Accredited Insurance (Europe) Ltd
You have the right regarding any personal information that we hold to:-
- Restrict or object to us processing it and we will agree to either stop processing or explain why we are not able to;
- Access the personal information we hold about you subject to certain restrictions;
- Ask us to update any data that is incomplete or correct any inaccurate information;
- Ask us to delete the information from our records if it is no longer needed for the original purpose;
- Ask us for an electronic copy so it can be used for your own purposes;
- Ask us to stop processing the information if the processing is based solely on individual consent;
- Find out about any automated decisions we make that affect your insurance premiums.
If you wish to exercise any of your rights or to complain if you feel that your personal information has been mishandled, you can contact us in the first instance as follows:-
You also have the right to complain directly to the Information Commissioners Office (ICO) whose details can be found at www.ico.org.uk
If you have any questions about how we use personal information, you can contact our Data Protection Officers as follows:-