This privacy notice tells you what we do with information we collect about you. It’s relevant to anyone who uses our services, including policyholders, prospective policyholders, website users and beneficiaries under our policies, such as named drivers. We refer to all these individuals as "customers" or "you" in this notice.
We are U K Insurance Limited ("we", "us" or "our") and you will know us by our brand names:
Churchill, Direct Line, Privilege and Green Flag.
Information collected from you & cookies policy
Where we have collected information directly from you it will usually be obvious what this is, as you will have given it to us. This might not be the case where we have used cookies to collect information from your computer or portable electronic devices. Please see our cookies policy for more information.
Information collected from others
We can collect information about you from others. This includes information from:
Sensitive personal information
We collect information that is sensitive, such as information about children, health or geo-location (which may be sensitive personal information because, for example, it can pinpoint your location at a hospital), and information related to unspent past criminal convictions or offences. We also collect your sensitive personal information for specific types of policy or applications, for example when offering you a travel policy or a driving application e.g. Telematics. We obtain this from your mobile devices for driving applications and the following people:
We collect and use this information as part of your insurance quotation or contract with us, or where it is necessary for a legal obligation, or as part of the establishment or defence of a legal claim.
We use your personal information in order to meet our obligations in our contract of insurance with you. We and other companies within our group of companies use your personal information in the following ways:
A. Provide insurance services
When you request us to provide you with a quote for one of our insurance policies or you purchase an insurance policy from us, we use information about you:
We cannot provide the services unless we use the information about you in this way.
B. Do what we are required to do by law
As part of our duty as an insurer providing insurance services, sometimes we are required by law to use information about you:
We can use your personal information in this way because we are required to do so by law.
C. Prevent fraud occurring
Fraud has an impact on all customers as it increases costs for everyone. We use your personal information to check for signs that customers might be dishonest (e.g. if someone has behaved dishonestly in the past it may increase the risk they will do so in future).
We may use your personal information in this way because it is in our interests to detect fraud and in all our customers' interests to ensure that they are not prejudiced due to increased premiums as a result of a few customers acting dishonestly.
D. Recover debt
If you owe us money we will use your personal information to help us recover it.
We can use your personal information in this way because it is a necessary part of the contract of insurance. We need to ensure that premiums are paid so that the majority of our customers do not suffer (e.g. through increased premiums) due to the actions of a small minority of customers.
E. To inform you about and promote products (marketing)
At the time when your personal information was collected, we asked you to indicate your marketing preferences. These preferences can be revisited at any time by contacting our Data Rights Team. Please see section 10 for contact details.
We may use your personal information to offer you suggestions about products and services you might want to buy. We may use external companies to do this on our behalf.
We can use your personal information in this way because it is in our legitimate interests to provide you with the right information at the right time, so that we may look at ways of extending our relationship that we have with you. We will always ensure that we keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum to meet this legitimate interest.
Where we have a legitimate interest to do so or, where necessary you have given us your consent, we may pass your personal information to third parties including:
If you have chosen not to opt out of marketing we will send you information about our products and services by email, post, telephone or SMS unless you tell us not to. If your information has been provided to us by a third party for marketing purposes we will rely on the consent you have provided to them to conduct direct marketing.
If at any time you do not wish us to use your personal information for this purpose, you may ask us not to do so. The simplest way to do this is to follow the instructions on the communication, which is a click on the unsubscribe link on emails or a return address on the envelope. See section 10 below for full details on how to contact us.
F. Where your or another person's life may be at risk
We will use your personal information to assist where your or another person's life or health is in danger and obtaining your permission is not possible (e.g. arranging emergency medical treatment in a remote location).
G. To administer and improve our services
To administer our services we will share information with others (including to people or organisations that may be based overseas):
We may also process your personal data to better understand you as a customer, including to determine how best to retain your custom, and to ask you to provide feedback on the service we provide to you.
We can use your personal information in this way because it is in our legitimate interests to provide the services in the most efficient way. We will always ensure that we keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum to achieve this efficiency.
We may share your personal information with third parties and other companies within our group of companies for the purposes mentioned in Section 3 above. A list of our group companies can be found at https://www.u-k-insurance.co.uk/group-companies.html. Alternatively, you can contact the Data Protection Officer for a list of them. Please see section 10. You should make sure everything you tell us is correct because your records may be checked in the following circumstances:
In particular we share information with:
Fraud prevention agencies that provide databases and services, such as CIFAS, National Hunter, SIRA and ENI, to prevent or detect fraud.
A record of this risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services or financing to you. If you have any questions about this, please contact the appropriate fraud prevention agency.
Credit reference agencies are used to help us verify your identify, and to determine the price of your insurance and your payment options when you take out a quote and at renewal of your insurance policy. This leaves a "soft footprint" on your credit file which can only be seen by you and does not affect your credit score.
If you choose to pay your premium by instalments we will share this information when you first take a policy with us and at each renewal. We may exchange your personal information with credit reference agencies to reflect your credit application (as payment by instalments means that there will be a credit agreement between us). We will let you know before we do this. This will be visible to other credit providers and is known as a "hard footprint". Failure by you or anyone who pays for your policy to keep up the monthly payments due under your credit agreement will be reflected in your credit score, not theirs.
The identities of the credit reference agencies and the ways in which they use and share personal information are explained in more detail at www.experian.co.uk/crain/. Alternatively, you can call us and we will send you a copy.
Driver and Vehicle Licensing Agency (DVLA) data If you choose to provide your Driving Licence Number (DLN) as part of your application for motor insurance the data provided by the DVLA may be used alongside other information you have provided:
The data will not be used for any other purpose, or be made available to anyone else. Searches of the DVLA driver database 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. Unlike other DLN searches with the DVLA that you may have authorised, this one will not show a footprint against your driving licence.
We may send your personal information overseas to any part of the world. The protections given to your personal information in other parts of the world will often not be as strong as in the UK. Where possible, we will put in place agreements with the people we send your personal information to, to require them to treat your personal information with the same protections that we apply ourselves. Our agreements may include standard terms provided by the EU called EU Model Clauses or may require the other party to be signed up to government standards that are recognised as providing the right level of protection. But it is possible that regardless of what is set out in the agreement this would not stop a government in any part of the world from accessing your personal information, as they can often have power to overrule any agreements we make.
In some cases we might need to share information to carry out the services we have promised to carry out, for example if you require urgent assistance abroad. In such an urgent situation we may not always have the time to put in place the type of agreement we would normally want to.
We are only allowed to keep your personal information if we need it for one of the reasons we describe in section 3 above.
As a general rule, we will keep it for 6 years from the end of your relationship with us, as it is likely that we will need the information for regulatory reasons, fraud prevention, or to defend a claim. For example, should you wish to bring some form of legal action relating to your relationship with us, this would generally need to be done within 6 years from the end of that relationship. However there may be exceptions where we need to keep your personal information for longer, such as where a claim has involved a minor.
We will also retain data in an anonymous form for statistical and analytical purposes, for example, to assess risk of flood damage occurring.
If we rely on your consent to collect and process your personal information, you can ask us to stop using your personal information at any time by withdrawing that consent and we will stop using your personal information for those purposes. We may rely on your consent to tell you about products or services which may be of interest to you or to use computers to make decisions about you to improve our services or develop our products (see section 9).
At any time, you can tell us to stop using your personal information to tell you about products or services that may be of interest to you or allowing computers to make decisions about you in order to improve our services or develop our products (see section 9). To find out how to do this, see section 10.
Where you do not provide the personal information we need in order to provide the service you are asking for or to fulfil a legal requirement, we will not be able to provide the service that you are asking us to give you.
We will tell you about why we need the information when we ask for it.
We will collect information about you and put this into our computer systems. The computer systems will make certain automated decisions about you which will be based on comparing you with other people. This will have an impact in terms of the level of premium or product that we offer to you or the products or services that we decide to tell you about. We may also use automated decision making to conduct an identity verification check.
For example, if you are under 25 years of age, the computer system may determine that you are more likely to have a car accident. This is because the computer system has been told that more people aged under 25 have car accidents. Another example is that, if you are under 25, the computer system may determine that you are going to be interested in a travel policy which covers high risk activity, such as skiing. Therefore, we would proactively seek to tell you about such policies as we would consider them to be of interest to you.
This is important because:
We also use computer systems to carry out modelling. Sometimes using your personal information and sometimes using data in anonymised form. We conduct this modelling for a variety of reasons, for example, for risk assessment purposes to make decisions about you, such as your likelihood to claim. However, we may also use your personal information in that modelling to make decisions about how we improve and develop our products and services, or our pricing and underwriting, or to better understand how our prospective customers make decisions about which policy is the optimal policy (i.e. we are not making decisions directly about you).
Our Data Rights Team are responsible for responding to your requests to exercise your rights which are set out below. The Data Rights Team may be contacted at U K Insurance Limited, Churchill Court, Westmoreland Road, Bromley, BR1 1DP or alternatively by email at Data.Rights.Requests@directlinegroup.co.uk.
You may contact us at the address above for one or more of the following reasons:
Sometimes we will not be able to stop using your personal information when you ask us to (e.g. where we need to use it because the law requires us to do so or we need to retain the information for regulatory purposes).
In other cases, if we stop using your personal information, we will not be able to provide services to you, such as administering your insurance policy or servicing your claim.
We will tell you if we are unable to comply with your request, or how your request might impact you, when you contact us.
If you have any concerns about the way in which we are using your personal information, please contact our Data Protection Officer in the first instance at U K Insurance Limited, Churchill Court, Westmoreland Road, Bromley, BR1 1DP or alternatively by email at DataProtection@directlinegroup.co.uk and we will endeavour to resolve your concern. However, you do also have the right to complain about how we treat your personal information to the Information Commissioner’s Office (“ICO”). The ICO can be contacted at:
ICO website: https://ico.org.uk/global/contact-us/
ICO telephone: 0303 123 1113
ICO textphone: 01625 545860