3.1 Data Protection Principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. used lawfully, fairly and in a transparent way.
2. collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. relevant to the purposes we have told you about and limited only to those purposes.
4. accurate and kept up to date.
5. kept only as long as necessary for the purposes we have told you about.
6. kept securely.

3.2 Information and data

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We will collect, store, and use the following categories of personal information about you (or that of any other persons insured):

• Personal contact details such as title, name, addresses (including proof of addresses), telephone numbers, email addresses, date and place of birth, gender, marital status and dependants and family details
• Next of kin and emergency contact information
• Details about your existing lifestyle and insurance arrangements including information from publicly available sources such as the electoral roll, British Geological Survey, information about previous and current insurance claims and telematics data
• Employment details including job titles, the start date, location of employment or workplace, work history, working hours, training records and professional memberships, salary, pension and benefits information
• Nationality and identification numbers issued by government bodies or agencies or other publicly available information including national insurance number, passport number, tax identification number, driving licence number and vehicle registration details
• Bank account details, or payment card details, income or other financial information such as payroll records and tax status information
• Credit and anti-fraud data including credit history, credit score and sanction list searches
• Information about your use of our information and communications systems, including IP address

We may also collect, store and use the following “special categories” of more sensitive personal data which we need to collect in order to assess the risk to be insured and provide an insurance quote

• Information about your political opinions or whether you are a politically exposed person
• Information about your health, including any medical condition, health and sickness records
• Information about criminal convictions and offences

3.3 How information is collected

We collect your personal data from various sources including, yourself, your family members, employer or representative; third party insurance intermediaries; insurers; reinsurers; credit reference agencies; anti-fraud databases, sanctions lists, court judgements and other databases; government agencies; or in the event of a claim, third parties including the other party to the claim, witnesses, experts (including medical experts), loss adjustors, solicitors, and claims handlers.

3.4 How we use your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we have entered into with you.
• Where we need to comply with a legal obligation.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal data in the following situations, which are likely to be rare:

• Where we need to protect your interests (or someone else’s interests).
• Where it is needed in the public interest or for official purposes.

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal data to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal data are listed below.

• Providing a quote or processing your application to purchase an insurance policy, its fulfilment or other related service
• Managing and administering products and services that we supply including underwriting, reinsurance, claims handling and providing legal advice and services
• Notifying you about changes to our service
• Claims handling or procuring this from any appointed service provider and business partner
• Administering the contract we have entered into with you, including for debt recoveries
• Investigating and resolving any complaints you have about our services or those provided by our appointed service providers and business partners.
• Helping us to monitor and manage products operational and governance services, including to develop new and innovative products and services
• Providing you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
• Business management and planning, including accounting and auditing
• Education, training and development requirements
• Dealing with legal disputes involving you
• To prevent or detect fraud and check your identity to prevent money laundering
• To monitor, or procuring this from any appointed service provider, your use of our information and communication systems to ensure compliance with our IT business control policies
• To ensure, or procure this from any appointed service provider, network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.

We will use your particularly sensitive personal information in the following ways:

• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
• We envisage that we will hold information about criminal convictions. We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.

We do not need your consent if we use special categories of your personal data in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive special category data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

3.4.1 If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

3.4.2 Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3.5 Automated Decision Making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

• Where we have notified you of the decision and given you 21 days to request a reconsideration.
• Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
• In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

We may use automated tools with decision making to assess applications for insurance such as price rating rules, flood, theft and subsidence area checks and credit checks. Our business partners may do this for claims handling processes. When calculating insurance premiums, we may compare personal data against industry averages or use this to create the industry averages going forwards. These automated decisions will produce a result on whether we are able to offer insurance, the appropriate price for policies or whether we can accept claims. If the individual objects to an automated decision, we may not be able to offer the insurance quotation or renewal.

If we make an automated decision on the basis of any particularly sensitive special category personal data, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

3.6 Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the Group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal data outside the EU. If we do, you can expect a similar degree of protection in respect of your personal data.

3.6.1 Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

3.6.2 Which third-party service providers process my personal data?

“Third parties” includes third-party service providers and business partners (including contractors and designated agents) and other entities within the Group. The following activities are carried out by third-party service providers: insurance and reinsurance underwriting and administration, claims handling services, IT services, management and storage of data and data analytical services, organisations and public bodies including the Police, fraud prevention agencies and databases, conduct of market research and services to more effectively communicate with you. We can supply on request further details of these third parties we access or contribute to and how this information may be used. If you require further details contact dpo@egmgu.co.uk.

3.6.3 How secure is my information with third-party service providers and other entities in the Group?

All our third-party service providers and other entities in the Group are required under written agreements to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

3.7 Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

3.8 Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal data in accordance with applicable laws and regulations.

3.9 Rights of Access, Correction, Erasure and Restriction

Under certain circumstances, by law you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to another party.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact dpo@egmgu.co.uk in writing.

3.9.1 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

3.9.2 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

3.10 Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact dpo@egmgu.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

3.11 Data Protection Officer

We have appointed a data protection officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact the dpo@egmgu.co.uk.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

3.12 Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

If you have any questions about this privacy notice, please contact dpo@egmgu.co.uk.