Privacy Notice

We are U K Insurance Limited ("we", "us" or "our"). We underwrite this scheme, which is introduced by Motability Operations Limited.

Information collected from you & cookies policy

The information collected directly from you may include basic personal details such as name, date of birth, contact details, financial details, and any other information relevant to the context of our relationship with you, for example vehicle information. 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 the following Cookies Notices for more information: U K Insurance - Cookies Notice and Motability Cookies Policy

Information collected from others

We can collect information about you from others. This includes information from:

• Motability Operations Limited which provides information about you to help us manage and underwrite the Motability Contract Hire Scheme and the Family Fund Mobility Support Scheme.
• Fraud prevention, law enforcement or government agencies and other data sources e.g., social media or other information-sharing platforms. Please see section 3c, below, for more details.
• HM Treasury and other authorities in relation to regulatory issues e.g., where someone is subject to a financial sanction, they will appear on HM Treasury's asset freezing list.
• Driver and Vehicle Licensing Agency (DVLA). We may ask for your Driving Licence Number (DLN) and the DLN of any named drivers as part of underwriting the insurance of your vehicle. The number is used to do an automated check with the DVLA driver database to retrieve the licence status, licence entitlement, relevant restriction information and any endorsement and conviction details.
• External sources.

Sensitive personal information

We collect information that is sensitive, such as information about health or unspent criminal convictions.

We may also collect information which due to its nature requires additional protection, such as information related to children, biometric (voice recognition and facial images) data and geo-location (which could, for example, indirectly, reveal medical or religious locations although we never use this information). We may collect your sensitive personal information for specific types of policy or applications, for example when offering you a driving application e.g., Telematics.

We may obtain this from your mobile devices for driving applications and the following people:

• The main customer will provide most of the information we collect about health such as vehicle adaptions required for hired vehicles or injuries sustained in an accident and will discuss license endorsements and driving bans, including on behalf of others named on the insurance scheme. If a driver has failed to disclose this information, it may result in a repudiation.
• Prevention or law enforcement agencies may provide details to us about criminal convictions.
• Witnesses to an accident may provide medical information to us if there is an investigation of a claim.
• We may use information about a child, for example, where the child is involved in an accident.

We collect and use this information to meet our obligations under the scheme, or where it is necessary for a legal obligation, substantial public interest (such as insurance purposes or to prevent or detect fraud), or as part of the establishment or defence of a legal claim.

We may also use your biometric data (voice recognition and facial images) to check your identity. When we do so, we will explain to you why we need it, and, where necessary, obtain your consent to use it for the relevant purpose. Biometric data may also be used to prevent or detect fraud.

We use your personal information in order to meet our obligations under the scheme. We and other companies within our group of companies use your personal information in the following ways:

A. Provide insurance services.

When we receive notification to provide insurance cover for the vehicle or product provided to you under the scheme, we use information about you:

• To determine eligibility to be covered, and any special terms that may apply to you or permitted drivers (noting that we may use automated decision making to make this assessment - see section 9 below).
• To administer the scheme.
• To send you documentation relating to the insurance benefits under the scheme.
• To provide the agreed service if you make a claim.

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:

• to help make sure our customers are being treated fairly (e.g., to assist our regulators or suppliers where we have a legal duty to do so) or to help identify if it is necessary for us to adjust our services to aid and meet the needs of vulnerable customers.
• To deal with complaints.
• To help prevent and detect crime (including, for example, the prevention or detection of fraud); and
• To comply with a legal or regulatory obligation.

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 in our legitimate interest, and ensures we are managing risk on the scheme.

E. 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. We rely on vital interest as our lawful basis to process the personal information in this way.

F. To administer our services.

To administer our services, we will share information with others (including to people or organisations that may be based overseas):

• In order to enable us to process the claim you have made or administer the insurance benefits under the scheme more cost effectively.
• We may share your contact details within U K Insurance Limited to help you with a claim you may have against another customer of U K Insurance Limited.
• To help develop our products, services, and systems to deliver you a better service and experience under the scheme in the future.

We can use your personal information in this way because it is necessary for us to fulfil our obligations under the contract.

G. To improve our services.

We may use technology to review your feedback, including any verbal or written opinion, to improve our customer experiences, including.

• Recording our calls for training and administration purposes.
• To improve our written and online communication for our customers.
• To ensure our staff provide a high level of customer services.
• Anonymising and aggregating data you have provided to improve analysis of business performance.

We may also process your personal data to better understand you as a customer and to ask you to provide feedback on the services 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 keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum to achieve this.

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

You should make sure everything you tell us is correct because your records may be checked in the following circumstances:

• When you apply for insurance, financial services, or work.
• By police and other law enforcement agencies.

In particular we share information with:

• Motability Operations Limited. We will provide them with personal information you update us about, such as your address, or permitted drivers, and claims history. This enables them to improve and provide services to you, which include keeping their records up to date, helping process applications you make and identify products that may be of interest to you.
• Motability Operations Limited third-party providers. We will provide them with information about you to enable them to provide their services to you such as roadside assistance. For further details on Motability Operations Limited third-party providers please see their privacy notice at motability.co.uk
• Fraud prevention agencies that provide databases and services, such as CIFAS, National Hunter, SIRA and ENI, to prevent or detect fraud.
• Fraud prevention agencies will process this personal information in order to assist our prevention of fraud and money laundering, and to verify your identity and may also process your personal information in order to prevent fraud and money laundering by other people.
• Fraud prevention agencies will hold your personal information for up to 1 year, or up to 6 years if you're considered to pose a fraud or money laundering risk.
• If we or a fraud prevention agency determine that you pose a fraud or money laundering risk, we may refuse to provide the services.

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.

• Law enforcement or government agencies. We and fraud prevention agencies may permit law enforcement or government agencies to access and use your personal information if they request it.
• Regulatory bodies such as the Financial Conduct Authority, Prudential Regulation Authority, or the Information Commissioner's Office to meet regulatory and legal obligations and requests for information.
• Nominees you have listed able to discuss details we hold about you, or others named on your agreement, on your behalf.
• Other insurance companies to help settle any insurance claim or to verify that the information you have provided is correct.
• Insurance industry bodies such as The Motor Insurance Database to meet our obligations under the Road Traffic Act.
• Insurance industry databases, such as the Claims and Underwriting Exchange where you make a claim so that insurers can check that your claims history is correct and the Insurance Fraud Register.
• Data verification and information: We may share information concerning your request for insurance cover with external organisations who help us to check and verify your identity, verify information you have submitted and evaluate your insurance risk, manage service interactions with you and to help prevent and detect fraud/financial crime.
• Government bodies, such as the Driver and Vehicle Licensing Agency.

We may send your personal information overseas to any part of the world to administer your insurance benefits or claims under the scheme. The protections given to your personal information in other parts of the world may 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 called Standard Contractual Clauses or International Data Transfer Agreements (IDTAs) approved by the UK Information Commissioner's Office 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, for purposes such as crime prevention and national security.

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; however, we will ensure that if such a transfer is required that it complies with the standards required by data protection legislation.

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 understand and reduce risks associated with the scheme and improving cover on the scheme.

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 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 which allows computers to make decisions about you 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. 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 analysed data that confirms that more people aged under 25 have car accidents.

This is important because:

• In providing insurance services it helps us understand any risks associated with the scheme.
• In identity verification it helps us to check that you are who you say you are and to prevent others from imitating you.

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.

The results of these automated decision-making processes are only allowed where it is necessary for entering into, or performance of a contract, as they may limit the products and services, we can offer you. If you do not agree with the result, you have the right to express your point of view and contest the decision, you can request that we perform a manual reassessment using the same information that you originally provided. If you wish to do so, please contact us.

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:
by post at U K Insurance Limited, Churchill Court, Westmoreland Road, Bromley BR1 1DP,
by email at Data.Rights.Requests@directlinegroup.co.uk
or through this form: https://www.u-k-insurance.co.uk/data-rights-request.html

You may contact us at the address above for one or more of the following reasons:

1. To ask us to correct information about you that is wrong or incomplete.
2. To ask us to delete personal information about you (the "Right to Erasure"). We are not required to erase information if we still need it for the purposes for which it was collected or processed, including to maintain records after cancellation or expiry of your policy, or where we have other legal grounds for processing your information.
3. To tell us you no longer agree to, that you object to, or that you wish to restrict us using information about you and ask us to stop.
4. A right of access, namely, to ask us to provide you with a copy of all of the personal information that we have about you.
5. A "data portability" right, namely, to obtain and reuse the information that you have provided to us for your own purposes across different services. You may ask for this information to be provided directly to you or directly to another organisation. We will provide the information in a machine- readable format so that another organisation's software can understand that information.
6. To ask us to review automated decisions made about you (as explained in section 9).

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 cover 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.

Complaints

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 and we will endeavour to resolve your concern. You can contact us:
by post at U K Insurance Limited, Churchill Court, Westmoreland Road, Bromley, BR1 1DP
or alternatively by email at DataProtection@directlinegroup.co.uk

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

If you have any concerns about the way in which Motability Operations Limited use your personal information that are unrelated to your insurance cover, please direct any queries in writing to:
Data Protection Officer, Motability Operations Limited, 22 Bishopsgate, 6th Floor, London EC2N 4BQ.