1. Introduction

Protector Insurance, Company Registration FC033034 is the UK establishment of Protector Forsikring ASA. As a Company, Protector takes privacy seriously. This policy sets out in broad terms how we use personal information that we collect from you. We may revise this privacy policy from time to time. Please check this notice to be updated of any changes we may make.


2. Privacy Principles

  • Personal information you provide is processed fairly, lawfully and in a transparent manner
  • Personal information you provide is collected for a specific purpose and is not processed in a way which is incompatible with the purpose which Protector Insurance collected it
  • Your personal information is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed
  • Your personal information is kept accurate and, where necessary kept up to date
  • Your personal information is kept no longer than is necessary for the purposes for which the personal information is processed
  • We will take appropriate steps to keep your personal information secure
  • Your personal information is processed in accordance with your rights
  • We will only transfer your personal information to another country or an international organisation outside the European Economic Area where we have taken the required steps to ensure that your personal information is protected. Such steps may include placing the party we are transferring information to under contractual obligations to protect it to adequate standards
  • Protector Insurance does not sell your personal information and we also do not permit the selling of customer data by any companies who provide a service to us

 

3. What is personal information?

Personal data, or personal information, means information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Basic Data:  such as your name, address, email address, telephone number(s), date of birth or age, gender and / or marital status.
  • Additional Information : such as the details of your car, your driving licence, your driving history, your home, current and previous your employment (including salary), your National Insurance Number.
  • Financial Data : such as details about your bank account where required for settlements, bank name, account name, sort code and account number
  • Insurance Policy Data : such as information about other insurance policies such as your claims history, quotation history, payment history or other claims data.
  • Third Party Information : such as information which we collect about third parties (including but not limited to Basic Data, Additional Information, Financial Data, Insurance Policy Data, Special Category Data (likely to be health records) and Criminal Convictions Data, as a result of that third party’s connection to an insurance, such as a claimant or beneficiary;
  • Special Category Data : defined as ‘sensitive’ such as marital status, health information including medical records, existing and previous medical conditions including records of benefits claimed in relation to these conditions; or
  • Criminal Convictions Data : such as disclosures about previous criminal convictions including alleged offences, criminal proceedings, outcomes and sentences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Basic Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice

4. How and when we collect this information

We may record and collect personal information about you when you contact Protector Insurance or a trusted third party (See section 8) by filling in forms, registering a claim on-line, or corresponding with us by phone, post, email or otherwise for the purpose of

  • Requesting or obtaining a quote
  • Submitting an enquiry
  • Purchasing a Protector product
  • Registering a claim and processing a claim


We may also collect information about you from a number of other sources including

  • Individuals or companies who have policies under which you are insured
  • Government agencies i.e. DWP, HMRC, MOJ Portal
  • Credit reference Agencies
  • Social Media (when fraud is suspected)
  • Medical professionals

We may also collect certain data from your use of our website or apps
We collect non-personal information via cookies and other similar technologies when you visit our website www.protectorforsikring.no. The information collected may be your device information, general location and how you interact with the website. The purpose of these cookies is to improve your online experience. No personal data is collected or stored via the use of cookies.

Please refer to our cookie policy for more specific information

5. Why do we process personal information?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  1. Where we need to perform the contract we are about to enter into or have entered into with you to provide your insurance policy cover.
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  3. Where we need to comply with a legal or regulatory obligation.
  4. Where it is necessary to:
  • advise on, arrange, underwrite or administer an insurance policy;
  • administer a claim under an insurance policy;
  • exercise a right, or comply with an obligation, arising in connection with an insurance policy, including a legal right or legal obligation,.
  • (This point (4) is what is referred to under the data protection legislation as an “Insurance Purpose”. Please see section 6 as to how we will use the insurance purpose when processing your personal data).

We may use information for number of administration purposes including:

  • Improving the customer experience by reducing the number of questions we need to ask you.
  • Understanding the risks to offer you the best service.
  • Verifying your identity when you contact us and carrying out anti-fraud checks.
  • Handling claims and complaints.
  • Customer research and statistical or analytical purposes

The circumstances in which we use your personal data, and the legal grounds we have for doing so are set out in the next section.

6. Under what legal basis do we process this information?

We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data and the specific stage of our relationship with you and depending on what personal data we are processing during that stage. Please contact us if you need more details about the specific legal ground we’re relying on to process your personal data where more than one ground has been set out in the table below.

 

Activity

 Type of Data (as described in Section 3)

Legal Basis

To provide a quote, to underwrite your policy

A) Basic Data

B) Additional data

C) Special Category Data (likely to be medical data)

D) Third Part Data

E) Criminal Convictions Data 

A) Performance of a contract with you – i.e. To provide an insurance policy, to fulfil our contract

B) It is necessary for an insurance purpose – i.e. to advise on, arrange, underwrite or administer an insurance policy

To administer and service your policy, handle and pay claims 

A) Basic Data

B) Additional Data

C) Special Category Data (likely to be medical data)


D) Third Party Data

E) Criminal Convictions Data 

 A) Performance of a contract with you – i.e.to provide an insurance policy, to fulfil our contract.

B) Necessary for our legitimate interests (to use the information to administer the policy and handle claims).

C) Where you have provided your prior written consent.

D) It is necessary for an insurance purpose – i.e. advise on, arrange, underwrite or administer an insurance policy.

 To handle and resolve complaints A) Basic Data

B) Additional Data

C) Special Category Data (likely to be medical data)


D) Third Party Data

E) Criminal Convictions Data

A) Performance of a contract with you – i.e.to provide an insurance policy, to fulfil our contract.

B) Necessary for our legitimate interests (to use the information to resolve a complaint).

C) Necessary for establishing, exercising or defending a legal claim [against us].

To prevent, detect and investigate fraud during the course of underwriting or claims handling

A) Basic Data

B) Additional Data

C) Special Category Data such as medical information relevant to your claim or our fraud suspicions

D) Criminal Convictions Data

A) Necessary for our legitimate interest (to detect and report fraudulent claims).

B) Necessary for reasons of substantial public interest – i.e. the prevention of fraud

For the purposes of arranging instalments or debt recovery or premiums A) Basic Data

B) Additional Data

C) Financial Data

A) Performance of a contract with you – i.e. To recover sums owed to us pursuant to our contract with you

B)Necessary for our legitimate interest (to recover business debts).

For insurance operational purposes, for understanding and monitoring risk profiles, analysis of financial reports, for placing reinsurance contracts, for financial and statutory reporting

A) Basic Data

B) Additional Data

C) Special Category Data such as medical data

A) Necessary for our legitimate interests (i.e. for understanding our business and our customer’s requirements) and / or

B) Necessary for the exercise of a function conferred upon us by law

For training purposes, monitoring customer services on telephone calls A) Basic Data

B) Additional Data

A) Necessary for our legitimate interests (i.e. for understanding our business and our customer’s requirements)

 

Please note, Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best product/ service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for our activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


7. Dealing with other people

It is our policy not to deal with other people on your behalf (such as your spouse or partner) unless we have your express written permission to do so. In some exceptional cases we may also deal with other people who call on your behalf, with your consent. If at any time you would prefer us to deal only with you, please let us know.


8. Who do we provide personal data to?

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 6 above:

  • When you request a quote for any type of insurance we will share information with your broker, intermediary or agent for the purposes of administration.
  • When you incept a policy with us we may pass your details to reinsurers for the purpose of placing reinsurance contracts.

The way data is shared with brokers, intermediaries and reinsurers is contractually agreed between us and the relevant third party within a data sharing agreement.

During the claims handling process your data may be shared with

  • Protector approved engineers, garages or your appointed third parties
  • Policyholders
  • Our insurance partners such as intermediaries (insurance brokers), reinsurers or other companies who act as (re)insurance distributors
  • Fraud detection agencies, and other third parties who operate and maintain fraud detection registers and/or assist with identification checks.
  • The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime. 
  • Loss adjustors or loss assessors
  • Solicitors and/or any other legal providers
  • Car Hire companies
  • Your healthcare practitioner i.e. GPs, hospitals, rehabilitation providers
  • Other Insurers if there is a claim resulting from or to another insurance company
  • Overseas assistance companies
  • Property builders or other Repairers


In some circumstances, Protector uses third party administrators (TPAs) to obtain services and fulfil obligations we have under the insurance contract such as claims handling. Your data may be shared with TPAs for the purpose of providing that service. Where we engage these suppliers for processing activities we require that they apply the same levels of protection and security to your data that we apply.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Where data is transferred outside the United Kingdom and/or European Economic Area (EEA) the third parties shall ensure that it does so in compliance with applicable Data Protection Requirements.

9. Motor Insurance Data

When you tell us about a motor incident, we work in partnership with the Motor Insurers’ Bureau (MIB) and associated not-for-profit companies who provide several services on behalf of the insurance industry. At every stage of your insurance journey, the MIB will be processing your personal information and more details about this can be found via their website: mib.org.uk. Set out below are brief details of the sorts of activity the MIB undertake:

  •  Checking your driving licence number against the DVLA driver database to obtain driving licence data (including driving conviction data) to help calculate your insurance quote and prevent fraud
  •  Checking your ‘No Claims Bonus’ entitlement and claims history
  •  Prevent, detect, and investigate fraud and other crime, including, by carrying out fraud checks
  •  Maintaining databases of:
  • Insured vehicles (Motor Insurance Policy Database or Motor Insurance Database/MID)
  • Vehicles which are stolen or not legally permitted on the road (Vehicle Salvage & Theft Data or MIAFTR)
  • Motor, personal injury, and home claims (CUE)
  • Employers’ Liability Insurance Policies (Employers’ Liability Database)
  • Managing insurance claims relating to untraced and uninsured drivers in the UK and abroad
  • Working with law enforcement to prevent uninsured vehicles being used on the roads
  • Supporting insurance claims processes

Under your policy you must tell us about any incident (such as an accident or theft) which may or may not give rise to a claim.

The transfer and processing of your data will always comply with all current data protection and compliance regulations and with our commitment to adequately protect and secure your personal information. Where data is transferred outside the European Economic Area (EEA) for any use stated in this policy the level of protection it is given will always be equal to that given within the EEA.

Your information may also be disclosed when we believe in good faith that the disclosure is required by law, required to comply with a judicial proceeding, court order or legal process or for the prevention or detection of crime including fraud.

10. Storage and Retention of Data

All data collected from you is stored in electronic format within core operating systems. Any information receive in paper format will be transferred to electronic format. We do not permit the storage of documents in any other format.

In most cases data is kept only as long as the regulations say we have to. For claims data this is usually within 10 years after the claim notification data and for data where there has not been a claim, the policy has ended and does not renew will be sooner. It will vary depending on what sort of data we are holding, why we are holding the data and what we’re obliged to do by the law or regulator.
We will only keep data to fulfil our obligations set out in this privacy policy.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

11. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

12. Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, which include a right to:

Request access to your personal data (commonly known as a "data subject access request").
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. How to contact us

Data Protection Officer
If you have questions relating to this privacy policy or our data protection practices, or you wish to make a subject access request please contact The Data Protection Officer at the following email address -

dpouk@Protectorinsurance.co.uk

 

Or by post at

The Data Protection Officer
Protector Insurance
7th floor
3 Hardman Street, Spinningfields
Manchester
M3 3HF

14. How to complain about the processing of your personal data

The Information Commissioner’s Office (ICO) is the UK’s independent public authority set up to uphold information rights.
Any person who believes that they are directly affected by the processing of personal data can ask the ICO to consider whether the processing is likely to comply with law. Visit the ICO athttps://ico.org.uk

15. How to make a complaint

We're proud of the service we provide to our brokers and clients, but we know that sometimes things can go wrong. 

Our aim is to get it right, first time every time. If we make a mistake we will learn from it and try to put it right promptly.

We will always confirm to you the receipt of your complaint within five working days and do our best to resolve the problem within four weeks.

If we cannot, we will let you know when an answer may be expected.

If we have not resolved the situation within eight weeks and you are an 'eligible' complainant you may be entitled to refer it to the Financial Ombudsman Service. 

For more information on eligibility please refer to the Financial Ombudsman Service at: http://www.financial-ombudsman.org.uk/

Should you wish to make a complaint then it should be directed to:

Customer Relations Manager

th Floor
3 Hardman Street
Spinningfields
Manchester
M3 3HF

Email:  CSM@protectorinsurance.co.uk

Telephone: 0161 274 9077

Making a complaint or referral to the Financial Ombudsman Service does not affect your legal rights.