Insurance is the pooling and sharing of risk in order to provide protection against a possible eventuality. In order to do this, information, including your personal data, needs to be shared between different insurance market participants. The insurance market is committed to safeguarding that information.
 

This notice is designed to help you understand how the insurance market participants process your personal data through the insurance.
 

This notice may be updated from time to time: this version is dated 8 March 2018.
 

In this notice:

we, us or our refers to the relevant insurance market participant [policyholder, insurer, broker, reinsurer];

 

you or your, refers to the individual whose personal data [may be/is being] processed by an insurance market participant (you may be the insured, beneficiary, claimant or other person involved in a claim or relevant to a policy).
 

There are other terms in bold with specific meanings. Those meanings can be found in the glossary below.

 

This notice sets out the following:

 

1 – INTRODUCTION – HOW THE INSURANCE MARKET WORKS

2 – THE DATA WE MAY COLLECT ABOUT YOU (YOUR PERSONAL DATA)

3 – WHERE WE MIGHT COLLECT YOUR PERSONAL DATA FROM

4 – IDENTITIES OF DATA CONTROLLERS AND DATA PROTECTION CONTACTS

5 – THE PURPOSES, CATEGORIES, LEGAL GROUNDS AND RECIPIENTS, OF OUR PROCESSING OF YOUR PERSONAL DATA

6 – CONSENT

7 – PROFILING

8 – RETENTION OF YOUR PERSONAL DATA

9 – INTERNATIONAL TRANSFERS

10 – YOUR RIGHTS AND CONTACT DETAILS OF THE ICO

11 – GLOSSARY OF KEY TERMS

 

 

SECTION 1 INTRODUCTION
 

How the insurance market works:


INSURANCE LIFECYCLE

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

FLOWS OF PERSONAL DATA THROUGH THE INSURANCE LIFECYCLE

 

 

SECTION 2 THE DATA WE MAY COLLECT ABOUT YOU (YOUR PERSONAL DATA)

 

In order for us to provide insurance quotes, insurance policies, and/or deal with any claims or complaints, we need to collect and process personal data about you. The types of personal data that are processed may include:

 

Types of Personal Data

Details
 

Individual details  

Name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to you
 

Identification details  

Identification numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving licence number
 

Financial information  

Bank account or payment card details, income or other financial information
 

Risk details  

Information about you which we need to collect in order to assess the risk to be insured and provide a quote. This may include data relating to your health, criminal convictions, or other special categories of personal data. For certain types of policy, this could also include telematics data.
 

Policy information

Information about the quotes you receive and policies you take out

Credit and anti-fraud data  

Credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to you
 

Previous and current claims  

Information about previous and current claims, (including other unrelated insurances),which may include data relating to your health, criminal convictions, or other special categories of personal data and in some cases, surveillance reports
 

Special categories of personal data

Certain categories of personal data which have additional protection under the GDPR. The categories are health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation

 

SECTION 3 WHERE WE MIGHT COLLECT YOUR PERSONAL DATA FROM
 

We might collect your personal data from various sources, including:
 

  • you;

  • your family members, employer or representative;

  • other insurance market participants;

  • credit reference agencies;

  • anti-fraud databases, sanctions lists, court judgements and other databases;

  • government agencies such as the DVLA and HMRC;

  • open electoral register; or

  • in the event of a claim, third parties including the other party to the claim (claimant / defendant), witnesses, experts (including medical experts), loss adjustors, solicitors, and claims handlers


Which of the above sources apply will depend on your particular circumstances.

 

 

SECTION 4 IDENTITIES OF DATA CONTROLLERS AND DATA PROTECTION CONTACTS
 

The insurance lifecycle involves the sharing of your personal data between insurance market participants, some of which you will not have direct contact with. In addition, your personal data may not have been collected directly by an insurance market participant.
 

You can find out the identity of the initial data controller of your personal data within the insurance market life-cycle in the following ways:
 

  • Where you took out the insurance policy yourself: the insurer and, if purchased through an intermediary, the intermediary will be the initial data controller and their data protection contact can advise you on the identities of other insurance market participants that they have passed your personal data to.
     

  • Where your employer or another organisation took out the policy for your benefit: you should contact your employer or the organisation that took out the policy who should provide you with details of the insurer or intermediary that they provided your personal data to and you should contact their data protection contact who can advise you on the identities of other insurance market participants that they have passed your personal data to
     

  • Where you are not a policyholder or an insured: you should contact the organisation that collected your personal data who should provide you with details of the relevant participant’s data protection contact.

 

 

SECTION 5 THE PURPOSES, CATEGORIES, LEGAL GROUNDS AND RECIPIENTS, OF OUR PROCESSING OF YOUR PERSONAL DATA

 

We set out below the purposes insurance market participants might use your personal data for:


Purposes
 

Quotation/Inception:

- 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 appropriate policy/ premium

- Payment of premium where the insured/policyholder is an individual


Policy administration:

- Client care, including communicating with you and sending you updates

- Payments to and from individuals


Claims Processing:

- Managing insurance and reinsurance claims

- Defending or prosecuting legal claims

- Investigation or prosecuting fraud


Renewals:

- Contacting the insured/policyholder to renew the insurance policy

- Evaluating the risks to be covered and matching to appropriate policy/ premium

- Payment of premium where the insured/policyholder is an individual


Other purposes outside of the insurance lifecycle but necessary for the provision of insurance throughout the insurance lifecycle period:

- Complying with our legal or regulatory obligations

- General risk modelling

- Transferring books of business, company sales & reorganisations


Please note that in addition to the disclosures we have identified against each purpose, we may also disclose personal data for those purposes to our service providers, contractors, agents and group companies that perform activities on our behalf.

 

 

SECTION 6 CONSENT

 

In order to provide insurance cover and deal with insurance claims in certain circumstances insurance market participants may need to process your special categories of personal data, such as medical and criminal convictions records, as set out against the relevant purpose.

 

Your consent to this processing may be necessary for the insurance market participant to achieve this.


You may withdraw your consent to such processing at any time. However, if you withdraw your consent this will impact our ability to provide insurance or pay claims.

 

 

SECTION 7 PROFILING AND AUTOMATIC DECISION MAKING

 

When calculating insurance premiums insurance market participants may compare your personal data against industry averages. Your personal data may also be used to create the industry averages going forwards. This is known as profiling and is used to ensure premiums reflect risk.

 

Profiling may also be used by insurance market participants to assess information you provide to understand fraud patterns.

 

Where special categories of personal data are relevant, such as medical history for life insurance or past motoring convictions for motor insurance, your special categories of personal data may also be used for profiling.

 

Insurance market participants might make some decisions based on profiling and without staff intervention (known as automatic decision making). Insurance market participants will provide details of any automated decision making they undertake without staff intervention in their information notices [and upon request] including:
 

  • where they use such automated decision making

  • the logic involved

  • the consequences of the automated decision making

  • any facility for you to have the logic explained to you and to submit further information so the decision may be reconsidered.

 

 

SECTION 8 RETENTION OF YOUR PERSONAL DATA

 

We will keep your personal data only for so long as is necessary and for the purpose for which it was originally collected. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim under this insurance, or where we are required to keep your personal data due to legal or regulatory reasons.

 

 

SECTION 9 INTERNATIONAL TRANSFERS

 

We may need to transfer your data to insurance market participants or their affiliates or sub-contractors which are located outside of the European Economic Area (EEA). Those transfers would always be made in compliance with the GDPR.
 

If you would like further details of how your personal data would be protected if transferred outside the EEA, please contact the data protection contact of the relevant participant.


SECTION 10 YOUR RIGHTS AND CONTACT DETAILS OF THE ICO

 

If you have any questions in relation to our use of your personal data, you should first contact the data protection contact of the relevant participant. Under certain conditions, you may have the right to require us to:

 

  • provide you with further details on the use we make of your personal data/special category of data;

  • provide you with a copy of the personal data that you have provided to us;

  • update any inaccuracies in the personal data we hold;

  • delete any special category of data/personal data that we no longer have a lawful ground to use;

  • where processing is based on consent, to withdraw your consent so that we stop that particular processing;

  • object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and

  • restrict how we use your personal data whilst a complaint is being investigated.


In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

 

The contact person at Safe Forsikring AS is:

Espen Stange
es@safeforsikring.as

+47 97 00 58 02


YOUR RIGHT TO COMPLAIN TO THE ICO (Information Commissioner’s Office)
 

If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights in SECTION 10, or if you think that we have breached the GDPR, then you have the right to complain to the ICO. Please see below for contact details of the ICO.

 

England:
Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate) or

01625 545 745 (national rate)

Email: casework@ico.org.uk

 

 

SECTION 11: GLOSSARY

 

Key insurance terms:

 

Beneficiary is an individual or a company that an insurance policy states may receive a payment under the insurance policy if an insured event occurs. A beneficiary does not have to be the insured/policyholder and there may be more than one beneficiary under an insurance policy

 

Claimant is either a beneficiary who is making a claim under an insurance policy or an individual or a company who is making a claim against a beneficiary where that claim is covered by the insurance policy

 

Claims processing is the process of handling a claim that is made under an insurance policy

 

Quotation is the process of providing a quote to a potential insured/policyholder for an insurance policy

Inception is when the insurance policy starts

 

Insurance is the pooling and transfer of risk in order to provide financial protection against a possible eventuality. There are many types of insurance. The expression insurance may also mean reinsurance

 

Insurance policy is a contract of insurance between the insurer and the insured/policyholder

 

Insurance market participant(s) or participants: is an intermediary, insurer or reinsurer

 

Insured/policyholder is the individual or company in whose name the insurance policy is issued. A potential

insured/policyholder may approach an intermediary to purchase an insurance policy or they may approach an insurer directly or via a price comparison website.

 

Insurers: (sometimes also called underwriters) provide insurance cover to insured/policyholders in return for premium. An insurer may also be a reinsurer.

 

Intermediaries help policyholders and insurers arrange insurance cover. They may offer advice and handle claims. Many insurance and reinsurance policies are obtained through intermediaries

 

Lloyd’s: many policies are underwritten in Lloyd's of London. Lloyd's is a specialist insurance market place. To find out more about how Lloyd's operates please visit www.Lloyds.com

 

Policy administration is the process of administering and managing an insurance policy following its inception

Premium is the amount of money to be paid by the insured/policyholder to the insurer in the insurance policy

 

Reinsurers provide insurance cover to another insurer or reinsurer. That insurance is known as reinsurance

 

Renewal is the process of the insurer under an insurance policy providing a quotation to the insured/policyholder for a new insurance policy to replace the existing one on its expiry

 

We, us or our refers to the relevant insurance market participant [link to diagram with policyholder, insurer, broker, reinsurer].

 

You or your refers to the individual whose personal data may be processed by an insurance market participant. You may be the insured, beneficiary, claimant or other person involved in a claim or relevant to an insurance policy

 

Key data protection terms:

 

GDPR: is the EU General Data Protection Regulation and the new UK Data Protection Act, which replaces the UK Data Protection Act 1998 from 25 May 2018.