The purpose of this notice is to give you more information regarding the processing, collection and sharing of your personal data. Lifesure Group Limited (Lifesure) understands the importance of maintaining your privacy, keeping your personal information secure, and complying with data protection laws. At different times in the course of its business, Lifesure acts as a data controller and also as a data processor of any personal information that it holds about you. This means that Lifesure is responsible for complying with data protection laws while this data is under its control. You should read this notice in conjunction with the standard terms of business for the sale of insurance policies which is available on our website.
Lifesure is a general insurance intermediary (a “broker”) who underwrites insurance policies as an agent of insurers. Lifesure offers a range of insurance products which cover personal insurance as well as commercial operations. Various levels of personal information will be required to perform this task.
If you require more information, our Data Protection Officer is Paul Reid. Please contact them as follows:
Data Protection Officer
Lifesure Group Limited, 3 Fenice Court, Phoenix Park, Eaton Socon, Saint Neots, PE19 8EW
How Lifesure uses and shares personal information
Information, including your personal data, must be shared between different parties. This includes intermediaries, insurers, reinsurers, Lloyd’s of London, claims handlers, and loss adjusters (‘insurance market participants’). Sharing of data is only undertaken where necessary to fulfil the requirements of the insurance contracts, or when required by law. Lifesure will never re-sell data. There is no obligation to provide Lifesure with personal information. However, if you refuse to provide it Lifesure may be unable to offer you its products and services.
Lifesure has a lawful basis for processing your information. The lawful basis, when this is relied upon, is outlined below:
|Performance of a contract with you||Processing is necessary for the performance of a contract or to take steps, at your request, prior to entering into a contract. This could include issuing quotations; processing claims; and issuing renewals.|
|Compliance with a legal obligation||Lifesure has a legal obligation to process your data. For example, in relation to sanctions and anti-fraud data.|
|For Lifesure’s legitimate interests||For example, to aid debt recovery; assist in the claims process; to ensure policies are structured correctly; risk modelling and aggregation data; preventing fraud; as well as the general administration of the insurance contract such as contacting you about the renewal of your policy. We may also send information about products and services that we have identified may be of potential value to you as they compliment products and services you already purchase.|
Each communication will be sent with an option to allow you change your preferences at any time.
|Explicit consent||Consent may be used when special categories of personal data and details of criminal offences are collected. Individuals may withdraw their consent to such processing at any time by contacting our Data Protection Officer using the contact details at the start of this privacy notice. By withdrawing consent, you may prevent Lifesure from continuing to provide the services that are the subject of the original contract and insurers may no longer be able to offer the cover or respond in the event of a claim.|
Your personal data is required at various stages of the insurance lifecycle as detailed below:
How the data is used
|Setting you up as a client, including possible fraud, sanctions, credit and anti-money laundering checks; evaluating the risks to be covered and matching to the appropriate policy and premium.|
|Policy administration||Client care, including communicating with you and sending you updates; payment of premium; and when arranging surveys.|
|Claims handling||Managing claims; defending or prosecuting legal claims; investigation or prosecuting fraud.|
|Renewals||Contacting you to renew the insurance policy; evaluating the risks to be covered and matching to appropriate policies; payment of premium.|
|Other||Complying with Lifesure’s legal or regulatory obligations; general risk modelling; transferring books of business, company sales & reorganisations.|
The above is a summary of the uses of your information. Detailed guidance can be obtained from the London Insurance Market Core Uses Information Notice accessible here which includes details on how this information is shared between market participants. It is recommended that you review this notice.
Timing of collection
Personal information may be collected at the time of the initial quotation, during the administration of the policy, during site surveys, and in the event of a claim.
Personal information that Lifesure may collect
Lifesure may collect data in relation to policy holders; directors and controllers of commercial policy holders, employee data from commercial insureds, claimants, including third party claimants who are not party to the original insurance contract, and potential policyholders.
Depending on the policy provided Lifesure may require:
|Individual details||Name, address (and proof of address), other contact details (e.g. email and telephone details), gender, marital status, family details, date and place of birth, employer, job title and employment history, relationship to the policyholder, insured, beneficiary or claimant.|
|Identification details||Identification numbers issued by government bodies or agencies, for example social security or national insurance number, passport number, tax identification number, and driver’s licence number.|
|Financial information||Payment card number, bank account number and account details, income and other financial information.|
|Insured risk||Information about the insured risk, which may contain personal data.|
|Health data||Current or former physical or mental medical conditions, health status, injury or disability information, medical procedures performed, relevant personal habits (e.g. smoking or consumption of alcohol), prescription information, medical history.|
|Criminal records data||Criminal convictions, including driving offences.|
|Other special categories of personal data||Racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning an individual’s sex life or sexual orientation.|
|Policy information||Information about the quotes individuals receive and the policies they obtain.|
|Credit and anti-fraud data||Credit history and credit score, information about fraud convictions, allegations of crimes and sanctions details received from various anti-fraud and sanctions databases, or regulators or law enforcement agencies.|
|Previous claims||Information about previous claims, which may include photographs, video, health data, criminal records data and other special categories of personal data.|
|Current claims||Information about current claims, which may include photographs, video, health data, criminal records data and other special categories of personal data.|
|Marketing preference data||This may be based on Lifesure’s legitimate interests or consent. This may include, but not be limited to, telephone number (landline and mobile), email address, postal address. You can object or withdraw consent by contacting us.|
|Website and communication usage||Details of your visits to Lifesure’s websites and information collected through cookies and other tracking technologies. This includes but is not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access. Full details of our cookies policy is available here.|
How Lifesure obtain your personal data
Most of your personal information is provided by you. Lifesure may also collect your personal information from 3rd party sources, for example credit reference agencies, sanctions search tools, due diligence providers, claims handlers, publicly available information, social media (where you have interacted with Lifesure accounts), survey companies who have visited your business, law enforcement, and other insurance market participants.
Lifesure may send marketing communications to persons who have expressed an interest in purchasing its products, or to existing customers whom it believes would benefit from other Lifesure products. Lifesure will obtain consent for all marketing activity when it falls outside of our legitimate interests (see below). Marketing will only be sent according to the preferences you have given us. Typically, you will be able to consent to receive marketing by SMS text message, by post, by telephone or by email. We will let you know if other options become available. Each marketing communication will be sent with an option to update your marketing preferences to allow you to change your preferences at any time. We do not sell the information we have about you to outside organisations.
Protection of data
Lifesure has in place physical, electronic, and procedural safeguards appropriate to the sensitivity of the information. This is to prevent unauthorised access or unlawful processing of personal data and to protect against accidental loss or destruction of, or damage to personal data. These protections will vary depending on the sensitivity, format, location, amount, distribution and storage of the personal data and may include encrypted communications, encrypted file storage, firewalls, access controls, and separation of duties. Lifesure restricts access to personal data to personnel and third parties that require access to such information for legitimate, relevant business purposes.
Retention periods for data
Lifesure will keep your personal data only for so long as is necessary and for the purpose for which it was originally collected, to manage its business, or as required by law. If there is any possibility that either you or Lifesure may wish to bring a legal claim under the insurance contract, or where required to keep your personal data for legal or regulatory reasons, then the data will be retained to meet those needs. Generally, the limitation period for the commencement of a claim is 6 years and data will be retained to cover this period. When personal data is no longer needed, Lifesure will either anonymise the data or securely destroy it.
Under the General Data Protection Regulation (GDPR) you have several rights in respect of your personal data. Your rights will always be balanced against Lifesure’s lawful basis for processing and to safeguard the public interest. If you wish to exercise any of these rights, please contact Lifesure using the contact details in the ‘About Us’ section. Lifesure will respond to requests within 30 days.
|Correction||You can request correction of the personal information that Lifesure hold about you. This enables you to have any incomplete or inaccurate information corrected.|
|Erasure||You can request erasure of your personal information. This enables you to ask Lifesure to delete or remove personal information where there is no good reason for Lifesure continuing to process it. You also have the right to ask Lifesure to delete or remove your personal information where you have exercised your right to object to processing.|
|Objection||You can object to processing of your personal information where Lifesure is relying on a legitimate interest, unless its reasons for undertaking that processing outweigh any impact on your interests, rights and freedoms.|
|Restriction||You can request the restriction of processing of your personal information. This enables you to ask Lifesure to suspend the processing of personal information about you. For example, if you want Lifesure to establish its accuracy or the reason for processing it.|
|Transfer||You can request the transfer of your personal information to another party in certain formats, if practicable.|
|Access||You can request details of information that Lifesure holds about you. Please provide any identifying information, the scope of the request, and your contact details. To protect your data, Lifesure will need to verify your identity before releasing the personal information.|
|Consent||If processing is based on consent you are able to withdraw this consent. However, please note that in some instances, this may restrict your insurance policy with us. We will notify you if this is the case.|
|Complaints||In the first instance you should contact Lifesure to discuss any complaints by contacting the Complaints Manager, details are available here. However you have the right to lodge a complaint to the Information Commissioners’ Office if you believe that Lifesure has not complied with the requirements of the GDPR in respect of your personal data. More details can be found here or by calling 0303 123 1113.|
Updated May 2018