Privacy Policy
Avon Insurance understands that the information you trust us with is important to you, and we are committed to protecting and respecting your privacy.
This policy explains how, when and why we collect your personal information during the course of providing services to you, under what circumstances we may disclose your personal information within our Group of companies and to others, and how we keep it secure.
Summary
- We only collect personal information about you where it is completely necessary or you have consented, and we ensure that we only collect information that we need
- We will not send you marketing material
- We will not sell your personal information to third parties
- We use third party suppliers to help us provide an excellent service to you. Where we share personal information with those suppliers, we have the appropriate contracts and controls in place which will assess the security of their processing arrangements
- We will protect your personal information with an appropriate combination of technical and organisational measures
- We record and monitor our communications with you to protect you and us for the reasons listed in Section 3
- You have rights to your information. These are detailed in Section 9
- We will endeavour to keep your personal information only for as long as we have to
- If you have a complaint, please see how to contact us in Section 11
- If you have any questions about how we process your information, please see how to contact us in Section 13
1. What information do we collect about you?
We need information about you to manage and service your policy, or to offer our range of services. We need to collect information from you to do this and to offer you the right product for your circumstances.
This can include personal information about you and other people you may want included on a policy, and information that we collect automatically, and personal information we collect from other sources.
The information we collect will include:
- Name(s)
- Contact details (postal address, email address, telephone numbers)
- Date of birth
- Banking, credit/debit card details
Where it is necessary, we may also collect information on the following:
- Country of birth/citizenship/nationality/country of residence
- Sex
- Marital status
- Information about family/household/dependents
- Criminal convictions
- Health information
- Medical history
- Claims history
- Asset ownership
- Employment status
- Financial status including CCJs and declarations of bankruptcy
- Previous Claims
- Additional needs data (information about significant life and health events)
2. Why we use the information about you
We collect your personal information for a number of reasons: so we can provide you with a quote, administer your policies, handle claims, protect us and you from fraud, to improve the products and services we offer, and finally to contact you about your policy where necessary.
To process your information, we rely mainly on the following legal bases:
Performance of a contract: The use of your information is necessary to perform the contract that you, or a person covered on the policy, has with us.
Legitimate interests: We may use your information for our legitimate interests, such as to provide you with the most suitable policy, website experience, emails or newsletters, or to improve and promote our products and services, along with administrative, fraud prevention and detection and legal purposes.
Consent: We may rely on your consent to use your personal information for certain products or to assist in a claim. You may withdraw your consent at any time by contacting us. Please contact us using the details end of this Policy
3. How will we use the information about you?
We use the personal information we collect for a number of reasons, these include:
- To service your policy and any claims you make
- Where necessary, we’ll use your information to verify your identity, or those transacting on the policy
- For fraud and financial crime prevention and detection, and for legal purposes where we may need to use your information to investigate or respond to legal disputes, regulatory investigations or for compliance purposes
- To identify your additional needs (e.g. A change in health, disability adjustments or certain significant life events) which allow us to adapt our services to your needs
- We may also use your personal information to ensure we comply with legal and regulatory requirements. This includes internal audits, monitoring and assurance activities to examine and evaluate the systems and controls within Avon Insurance
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When you call us, we record calls for quality control and training purposes. How long we keep recordings depends on our retention policy (see Section 9), unless Avon Insurance has a legitimate interest to keep recordings longer (as reasonably necessary), including for fraud detection and financial crime investigation purposes. Additionally, we record calls to:
- Ensure that we have correctly followed your instructions
- Resolve any queries, issues or disputes
- Help us understand how we could improve customer service
- Respond to regulatory queries
- Help our fraud prevention teams with detection or prevention of fraud or other crimes
- Assist with staff training and improve our customer experience
- We also use your information to help us improve our products and services, our prices and our customer experience through analytics, reporting and testing
- We may use your information to contact you if we need to tell you that there is an error or a change in your policy and for general communications, including product performance and industry insights and news
- We may use your information to share your data with third party tracing service providers, where appropriate, if we are unable to contact you, or to check if you have passed away.
4. Information that we share
We may have to share your information with other companies under the NFU Mutual Group or to categories of third- party service providers, including insurance partners and brokers, in certain circumstances:
- We may share your information with third parties where they provide parts of your policy cover to ensure your policy can be serviced and honoured
- Where we need to share the risk with other insurers or reinsurers, we will share the necessary data you have given us with our carefully selected partners
- Where we need to service your policy and handle a claim against it, we will use the requisite third party lawyers, investigators, fraud agencies and databases and subject matter experts where appropriate. Where fraud is detected, this may affect your ability to obtain products, services or employment. For more information, please contact us using the information in section 13.
- Where fulfilling our contractual obligations to you requires it, we will share your information with third parties including lawyers, medical professionals, HM Coroner/Procurator Fiscal.
- Where required by law, we will share your information with third parties such as law enforcement agencies and regulatory or Government bodies. Failing to do so could result in fines or sanctions for Avon Insurance
- We use other insurance companies to insure Avon Insurance as a business. Where required, we will share the necessary personal information with these insurers
- There are some instances where we need to share your information with third parties to help us detect and prevent criminal or fraudulent activities
- We will share your information with third party IT providers who support us in hosting, transferring, processing, testing and problem resolving. This enables us to provide the services and products you need
- We may also share information with third party audit companies providing expertise and assurance over our processes and controls
- We may also share your information with third parties in relation to other activities that we carry out, such as training
- In order to deliver your policy documentation and mailing campaigns, we will also share your information with third party printers, distributers and courier services
- We may also occasionally share your information with third party suppliers to assist us in bulk mailing campaigns, for example, if we are required to inform our customers about changes to the Insurance Premium Tax
- We may share your data with third party tracing service providers, where appropriate, if we are unable to contact you, or to check if you have passed away.
5. Marketing
We will never send you any marketing material or share your information for marketing purposes with anyone.
6. Information Security
We work hard to keep your data safe. We use an appropriate combination of technical and organisational measures to ensure, as far as reasonably possible, the confidentiality, integrity and availability of your information at all times. If you have a security-related concern, please contact us using the details provided at the end of this Policy.
7. Transferring your information outside of the European Economic Area (EEA)
In order to provide our services, the information you give us may be transferred to countries outside the European Economic Area (EEA). These countries may not have similar data protection laws to the UK. When we do transfer your personal data outside of the EEA, we ensure that any party with access to your information has implemented the necessary security and privacy measures to ensure that your personal data is kept secure and confidential as outlined in this Policy.
8. Information we collect through your use of our Websites
We do not collect information through the use of non-essential cookies or similar technologies.
9. Your individual rights
You have a number of rights regarding the personal information that we hold about you:
Right of Access – You have the right to request a copy of the information that we hold about you. We will provide you with this information within one month of receiving your request and verifying your identity. If the request is complex, we may extend the response time. We will inform you if this is the case and explain why.
Right to Rectification – We want to make sure that your personal information is accurate and up to date. You may ask us to correct, update or remove information you think is inaccurate or incomplete, and we ask that you inform us promptly of any changes to your circumstances.
Right to Erasure – You may also ask us to erase your personal information from our systems, in certain circumstances. There are some specific circumstances where the right to erasure does not apply and we are permitted to hold your data. We will explain the reason for this at the time, should this occur.
Right to Data Portability – You may also ask us to move, or ‘port’, your personal information to another organisation electronically. We will only port personal information you have provided to us, that we have processed based on your consent or performance of a contract, or that has been processed automatically. We will port your personal information without charge and within one month, where technically feasible.
Right to Restricting processing – You have a right to request that we restrict the processing of your personal data in certain circumstances. We will inform our third parties to whom we have disclosed your personal data that they must also restrict processing. We will inform you when the restriction on processing your personal data ends.
Right to Object – Where we are relying on legitimate interests, you have the Right to Object to the processing of your personal data.
10. Retaining your data
Avon Insurance and the information we collect about you, are subject to various regulatory and legislative requirements. In addition, we will endeavour not to keep your personal information for longer than we have to for us to fulfil our obligations to you. Where it is not possible for us to delete your data, we will ensure the appropriate security and organisational measures are put in place to protect the use of your information.
11. Complaints
We work hard to ensure that your personal information is treated safely and securely. However, if you have a complaint, write to us using the details provided at the end of this Policy. You also have the right to complain to the Information Commissioner’s Office.
12. Changes to our Privacy Notice
We review our Privacy Policy regularly and will place any updates on our website and in relevant policy communications.
13. Who to contact in relation to processing of personal information at Avon Insurance
Avon Insurance controls the processing of personal data on its systems. If you would like to discuss anything in relation to this Policy or how we handle your personal information, you can reach the Data Protection Officer for Avon Insurance by writing to:
Data Protection Officer,
NFU Mutual
Tiddington Road
Stratford-upon-Avon
CV37 7BJ
You can also talk to one of the team.
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