Who to contact about your personal information

Premier Underwriting Ltd is the Data Controller for personal data you provide to us. You can find us on the Financial Services Register under reference number 307164.

Should you have any questions about how we use your information, or if your personal information needs updating, please write to:

Data Protection Officer
Premier Underwriting Ltd
Ocean 80
80 Holdenhurst Road
Bournemouth
Dorset
BH8 8AQ

Email address of Data Protection Officer: This email address is being protected from spambots. You need JavaScript enabled to view it.. Further details are available on the Data Protection public register maintained by the Information Commissioner’s Office (ICO).

A response to your request will be provided to you within 28 days of us receiving a valid request.

Your personal information and how it is collected

We may receive personal information about you from any of the following sources:

• you or your insurance intermediary
• a price comparison website to whom you have submitted your details for a quote
• someone you have authorised to incept a policy on your behalf
• through the process of you making a claim
• third parties such as credit reference or debt collection agencies (for example, to confirm your personal data); and
• from insurers, witnesses, third parties and solicitors (for example, details relating to an incident that is the cause of a claim)

The information we receive may consist of the following personal data:

• general identification and contact information such as your name, home address, telephone number, e-mail address and date of birth
• all other personal information that is provided when completing an application for a quote for any policy, including (where necessary) Driving Licence Number, No Claims Discount information, Vehicle Registration Mark
• information about any incident that may result in a claim

Collecting and processing this data is necessary for the performance of the contract of insurance (including the quoting, incepting and managing of the policy for its duration) which forms the lawful basis for us holding and processing your data.

The information we receive may consist of special category data:

• Special category data includes details about medical conditions

By providing special category data you acknowledge the use of such details by Premier Underwriting Ltd and its third parties for the purposes outlined in this privacy policy. Processing of this special category data may be necessary for the purposes of providing you with a quote and to incept or renew your policy and during settlement of a claim. The legal basis under which we process special category data is for reasons of substantial public interest which includes an insurance purpose which is a specific derogation that allows the insurance industry to process sensitive data and data relating to criminal convictions.

You should show this notice to anyone whose personal information you provided as part of your insurance application. You must ensure that any such information you supply relating to anyone else is accurate and that you have obtained their consent to the use of their data for the purposes set out within this privacy policy.

It is important that the information you provide to us is accurate, as incorrect information could affect the price of your policy, result in your policy being cancelled, result in your policy being declared void, or lead to a claim being rejected or not fully paid.

Your personal data will be retained for as long as is reasonably necessary for the purposes listed above or as required by the law. Premier Underwriting Ltd will retain personal information to enable us to manage your policy, respond to complaints, demonstrate compliance with Financial Conduct Authority (FCA) rules and support our ability to defend against legal claims. Information is retained as required and directed by the FCA and in line with guidance from the Association of British Insurers. For these purposes our standard period of retention is 21 years and 4 months after the expiry of your policy. This retention period is necessary in order to manage claims that may involve an unborn child and allows for them to reach the age of maturity and pursue a claim. However, your personal data contained in other types of document may be retained for shorter periods. If required, please contact us for further details of applicable retention periods. Personal data may for reasons of security and convenience be stored on remote data facilities but in an encrypted form.

How we use your personal information

Your personal information may be used by Premier Underwriting Ltd for the following purposes:

• to make decisions about whether to provide insurance
• to determine the terms and premium for an insurance policy
• to assess your financial standing
• to verify the information provided including the claims history of persons named on the policy now or in the future
• to confirm your identity
• to prevent, detect and investigate crime, including fraud and money laundering
• to administer and maintain your policies
• to assist with claims and enquiries
• to facilitate our quality and compliance monitoring
• to resolve complaints and process requests for data access or correction
• to use statistical analysis and profiling to support our pricing strategy
• in the event of a claim, we may contact you to seek feedback on our performance

In order to deliver our services to you we use third party processors (for example, for the purposes of claims handling, data transfer, statistical analysis, credit searches and fraud prevention). Such processing is conducted under contract and we ensure that appropriate data protection and information security assurances are provided. We will always seek to minimise identifiable personal data wherever possible.

In order to prevent or detect fraud we will use the details you have provided in respect of your vehicle and all named drivers to check those details with various fraud prevention agencies and anti-fraud registers, who may record a search. Searches may also be made against other insurers’ databases, the Electoral Roll and Register of Judgments, Orders and Fines. To validate your (and any persons named on the policy) driving history we may also check the available databases to confirm your licence status, entitlement and restriction information and endorsement/conviction data as well as any No Claims Discounts you are claiming. These checks include processing conducted automatically by computers and may affect pricing or our ability to quote for insurance. We may cancel your insurance policy if we believe fraudulent details have been provided.

Sharing of personal information

Information provided from all sources to Premier Underwriting Ltd may be shared with any of the following and used as detailed within this privacy policy, as required or permitted by law:

• insurers
• law enforcement agencies. We may also share your information with law enforcement agencies, other organisations and public bodies where we reasonably believe it is necessary for the prevention of fraud, crime or where required to do so under a court order
• third parties (For example, in the event of a claim we may need to disclose information with any other party involved in that claim such as third parties involved in the incident, their insurer, solicitor or representative and medical teams, the police or other investigators)
• Motor Insurance Database (MID) - Information relating to your insurance policy will be added to the MID, managed by the Motor Insurers’ Bureau (MIB). MID and the data stored on it may be used by certain statutory and/or authorised bodies including the police, the DVLA, the Driver and Vehicle Agency (DVA) Northern Ireland, the Insurance Fraud Bureau and other bodies permitted by law for purposes not limited to but including Electronic Licencing, Continuous Insurance Enforcement, anyone pursuing a claim in respect of a road traffic collision
• third party processors
• reinsurers. In the event of a very large claim we would need to share your information with our reinsurers who may be located outside of the UK or the European Economic Area (EEA). In such circumstances we ensure that the reinsurers provide the same level of data protection as required by UK data protection laws and regulation
• regulators and statutory bodies (such as the Financial Conduct Authority or the Financial Ombudsmen Service)
• any party (or their professional advisors) concerned in the event of a merger, acquisition, or any form of sale of some or all of our assets

We pass information to external companies and fraud prevention agencies, for example (but not limited to) the Claims and Underwriting Exchange and the Motor Insurance Anti-Fraud and Theft Register run by the Motor Insurers’ Bureau. The aim is to help us check information provided and also to prevent fraudulent claims. We may at any time search these registers, including when we deal with your request for insurance, at renewal, or in the event of an incident or claim. If fraud is suspected, information will be shared with insurers and fraud prevention agencies. When we pass information to external companies and fraud prevention agencies they will record this information. They may check it against similar applications made to other organisations and share your data with other organisations. Those organisations may use this information when making decisions about you.

Under the conditions of 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. When you tell us about an incident we will pass information relating to it to fraud prevention agencies. Other users of fraud prevention agencies such as law enforcement agencies may use this information in their own decision making processes.

We will use information about you and any persons named on the policy to ensure compliance with financial sanctions in effect in the UK and internationally. This will include the checking of your information against the HM Treasury list of financial sanctions targets as well as other publicly available sanction lists. Your information and that of any named person on the policy may also be shared with HM Treasury and other international regulators where appropriate. You may also be contacted to provide further details to ensure compliance with financial sanctions requirements.

Credit Searches

On our behalf, your intermediary will conduct credit reference checks at one or more credit reference agency (CRA). In all cases these checks will be carried out to confirm identity, help prevent fraud and calculate premiums. This is a soft search which is visible to you if you request a copy of your credit reference file but is not visible to other organisations. This type of credit reference check will not affect your credit rating as it is not an application for credit.

Credit reference agencies may add the details of your intermediary’s searches and information that they hold about you to their records. You can contact the CRA’s currently operating in the UK (TransUnion - formerly known as Callcredit, Equifax and Experian) to find out what information they hold about you or to request your credit reference file. Their contact details are below. The information they hold may not be the same so you may wish to contact more than one.

Your Rights

Under data protection regulation you have rights as a data subject:

• the right to ask for further details on the use we make of your personal data including special category data
• the right to ask for copies of information that you have supplied to us, to be sent either to you or a third party in a reusable format
• the right to be forgotten and to request deletion or removal of personal or special category data. There are certain exemptions to this right, for example where the information is necessary to fulfil the obligations of a contract. In accordance with this exemption, once a policy is in force we are unable to delete the information we hold as it is necessary to fulfil our obligations to administer any claim that may arise
• the right to access or obtain copies of the personal information held about you by us, or request that we correct any inaccuracies in that information
• the right to challenge automated decisions. During the preparation of a quotation, Premier Underwriting Ltd makes decisions based on automatic processing and profiling. You have the right to speak to someone who may review the automated decision, provide a more detailed explanation and assess if the automated decision was made correctly. You also have the right to challenge an automated decision made about you
• the right to object to any processing carried out on the legal ground of Legitimate Business Interests, unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
• the right to restrict how we use your personal data whilst a complaint is being investigated

To exercise any of the above rights, please contact the intermediary through which you purchased or are purchasing the policy.

If you believe we have not complied with our obligations under the relevant data protection legislation, you have the right to submit a complaint to the Information Commissioner. More details about the Information Commissioner's Office can be found at www.ico.org.uk.

Contact Information

You can contact the CRAs currently operating in the UK (TransUnion, Equifax and Experian) to find out what information they hold about you. Their details are below:

TransUnion, 0330 024 7574 or log on to www.transunion.co.uk. More information about TransUnion’s activities is available in their Privacy Notice.
Equifax, Equifax Ltd Customer Service Centre, PO Box 10036, Leicester, LE3 4FS, or call 0333 321 4043 or log on to www.equifax.co.uk.
Experian, Consumer Help Service, PO Box 8000, Nottingham, NG80 7WF, or call 0344 481 0800 or log on to www.experian.co.uk.

For details relating to information held about you on the Claims and Underwriting Exchange (CUE) and the Motor Insurance Anti-Fraud and Theft Register (MIAFTR) (both run by the MIB) please visit www.mib.org.uk.

For details relating to information held about you by the Driver and Vehicle Licensing Agency (DVLA) please visit www.gov.uk.

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