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Insenture Underwriting Services Limited and the insurer of your policy are the data controllers of your personal information. You can contact Insenture Underwriting on data privacy matters at info@insentureunderwriting.com or by writing to us at: The Data Protection Officer, Insenture Underwriting Services Limited, 1st Floor 94 - 102 Highstreet, Hampton Hill, TW12 1NY.

 

Your insurer’s name and contact details will be provided on your Certificate of Insurance. Further information about how your insurer uses your details may be found on your insurer’s website. We are governed by the Data Protection legislation applicable in the United Kingdom.
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How we may collect your information
 
We may collect details about you from:

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- Information you give us via the telephone or online forms;
- Information you give to Price Comparison Websites;
- Information you give to brokers;
- Other sources such as Google Earth and social media; 
- Third parties and other sources;
- Telematics systems, dash-cams and mobile applications;
- Cookies on our websites.
 
What information we may collect about you
 
We collect details including details about your health, personal circumstances, claims history, credit history, motoring history and other relevant details. We may collect information on you from databases such as fraud databases, the electoral roll and county court judgment records.
 
How we may share your information
 
In order to provide our services to you, we may share your information with insurance companies, solicitors, regulators, business partners and suppliers. We may also have a legal obligation to provide your information, in certain circumstances, with regulators, police and other public bodies. Information you supply may be used for the purposes of insurance administration by us and third parties. These third parties may share your information with their own agents.
 
How we may use your information
 
We may use your information for a number of purposes.

 

These include: 

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- Providing you with our services; 
- Dealing with your claim;
- Carrying out checks such as fraud checks and credit checks.
 
Driving Licence Checks 
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We may also provide your (or any named third party) driving licence number (DLN) and other details to the DVLA to confirm licence status, entitlement and relevant restriction information and endorsement / conviction data. Searches may be carried out prior to your policy commencing and at any point during your insurance policy including any mid-term adjustment and renewal stage. For details relating to information held about you by the DVLA please visit www.dvla.gov.uk. The DVLA may also be used to search your (or any named third party’s) no claims discount (NCD) details against a no claims discount database to obtain information in relation to your NCD entitlement. We may pass details of your no claims discount to certain organisations to be recorded on a NCD database. 
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Motor Insurance Database 
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Your policy details will be added to the Motor Insurance Database (MID), run by the Motor Insurers’ Bureau (MIB). MID and the data stored on it, including your personal details, may be looked at and used by certain statutory and/or authorised bodies including the Police, the DVLA, the Insurance Fraud Bureau and other bodies permitted by law. 
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If you are involved in an accident (in the UK or abroad), insurers and/or the MIB may search the MID to obtain relevant information.
 
Persons pursuing a claim in respect of a road traffic accident (including citizens of other countries) may also obtain relevant information which is held on the MID. 
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It is vital that the MID holds your correct registration number. If it is incorrectly shown on the MID you are at risk of having your vehicle seized by the Police. You can check that your correct registration details are shown on the MID at www.askmid.com. 
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Fraud Prevention and Detection 
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We carry out fraud checks on our customers. We do this in order to prevent fraud and also to help us make decisions about the provision, pricing and administration of insurance. When carrying out these checks, we will search against fraud detection databases. We may pass details about you to some of these databases. Law enforcement agencies, financial service providers, fraud prevention agencies, police and other organisations may also access these databases. 
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Claims History 
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We may process data relating to your claims history for the purposes of assessing any claim you may make. 

The aim is to help us to check information provided and also to prevent fraudulent claims. When you tell us about an incident we will pass information relating to it to these databases. We may search these databases when you apply for insurance, in the event of any incident or claim, or at time of renewal. 
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Credit Searches and Accounting 
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In assessing an application for insurance or policy renewal, we may search files made available to us by credit reference agencies. They keep a record of that search. 
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Credit reference agencies share information with other organisations, enabling applications for financial products to be assessed or to assist the tracing of debtors, or to prevent fraud. 

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Telematics Devices & Mobile Applications

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​Some of our policies require our drivers to fit a telematics device and / or download mobile applications. We / the broker will explain if this is applicable on purchasing a policy with us, with the full terms of the policy detailed in your policy wording. How the data collected may be used is detailed below. 

Telematics devices collect and transmit data on location, mileage driven, driving style along with the time and impact speed if your insured vehicle is involved in an accident. Mobile applications may collect location data whilst you are driving even when it is closed or in the background.

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When you purchase a telematics policy we may collect, use, store and transfer the following personal data about you:

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- Contact and identity details including your first and last name, username or similar identifier, occupation, title, email address, postal address and telephone number;

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- Profile Data includes your username and password for the App, feedback and survey responses.

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- Installation data such an installation photo of the front of your car which may contain data such as the make of your car and your registration number;

Vehicle details and car insurance details;

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- Technical information including your IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating systems and platform and other technology on the devices you use to access the App.

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- Information obtained through monitoring your car, including details of your driving behaviour, the date and time your car is driven, durations of journeys made in your car, the locations you drive, the speed you drive, the rate you accelerate when you drive, the intensity and force with which you brake when you drive (commonly known as ‘G-Force’).

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- Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences.

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- Location data – we also use GPS technology or similar location technologies to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling your Location Data in your settings.

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Raw Trip data is anonymised and retained indefinitely and may be used by our Telematics provider and their associated partners for the purposes of improving systems, general analysis or generating new aggregate data sets. We and/or the telematics provider collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate data collected through your usage of the telematics device or applications. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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Some data will result in a report being sent alerting us to the possibility of a crash or to tampering with the device or when there is no data network connection.

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Telematics devices do not identify who is driving the vehicle, but telematics data and our assessments of driving behaviour can be linked to an individual, for example when we discuss driving feedback with you and in the event of a claim.

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Telematics data (driving data / behaviours) collected may be used in the assessment of liability in the event of a claim, verifying your declared policy details by us, and in statistical analysis by the telematics provider  to assist us in product assessment and development.

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We may choose to use the data collected to contribute towards the calculation and charging of your insurance premium. Please note that if you allow other drivers to use the car during the period of insurance their driving behaviours will have an impact on the telematics data collected and could impact your renewal premium with us.

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Third Party Links

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Our mobile applications may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you access third party websites through links on apps we encourage you to read the privacy policy of every website you visit.

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Consent to Installation of our mobile applications and other app permissions.

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Before installing mobile applications on your Apple or Android device, please indicate your consent to our processing of your personal data including device information and permissions such as, permissions to receive notifications from applications and access to your device’s network to have full network access and view network connections to enable the app and its features to work;

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Some of the permissions listed require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling such permissions in your device settings. However, please note that if one or more permissions are disabled on your device, we may not be able to offer the full extent of either of our services or you may not benefit from the full experience of both our services supplied. 

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Transfers 
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Sometimes your information may be transferred outside the European Economic Area by us, by the organisations with whom we share your information or by the servants and agents of these organisations. If we do this we will ensure that anyone to whom we pass it provides an adequate level of protection.

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Data Retention 
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We will only hold your personal data for as long as we are required in law and by our regulators. Your Rights as a Data Subject.

Under Data Protection Laws you have certain rights; these include for example, a right to understand what data we hold on you and a right to ask us to amend that data if it is incorrect. If you would like to exercise any of your rights please contact our Data Protection Officer (contact details below).

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Legal Basis

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We and your insurer are allowed to use and share your information in the ways described in this Privacy Policy:

 

- So that we can provide you with a quotation at your request and can arrange, provide and administer your policy. 

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- Where we need to process sensitive information such as health and/or criminal conviction information for insurance purposes, we do so on the permitted basis that it is in the public interest to ensure that insurance is available at reasonable cost through risk-based pricing.

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- So that we can comply with legal and regulatory obligations, such as legal obligations to share information with our Regulators and Ombudsmen, or carry out financial sanctions checks.

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- Where our use of your information is necessary for our legitimate business interests, such as marketing of our products and services (unless you ask us not to), research and statistical analysis and conducting customer surveys.

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Your Information Rights

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​You have the right to access information held about you, on written request, and if necessary to rectify any errors or omissions in that information. Please write to The Data Protection Officer, Insenture Underwriting Services Limited, 1st Floor 94 - 102 Highstreet, Hampton Hill, TW12 1NY. If we receive repeated requests from you, we reserve the right to charge a fee for this. You have the right to tell us that you no longer agree for us to tell you about our products and services which may be of interest (direct marketing). You have the following additional rights in respect of your personal information: 

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- Erasure: in certain circumstances you will have the right to ask us to erase information we hold about you. 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.

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- Restrict processing: where you do not wish your information to be erased, you may instead have the right to ask us to restrict our processing of your information. This right is only available in limited circumstances, such as where you believe the information we hold about you is inaccurate or is being processed improperly. The right would apply during the period that we are checking its accuracy or legality.

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- Portability: to receive a copy of the personal data you have provided to us, in a commonly used machine-readable format, and to transfer that personal data to another data controller. Where it is technically feasible you may also have the right to request us to transfer the data directly to another data controller.

- Object: where we are processing your information on the grounds of it being in our legitimate interests to do so, you have the right to object to that processing.

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Automated decision making and profiling: where we use automated processing to make a decision which may produce a legal or similarly significant effect on you, you may request human intervention, express your point of view and contest the decision. In order to exercise these rights, please write to the Data Protection Officer at the address given above or use the email address info@insentureunderwriting.com.