At Freeway UK Insurance Services Limited we are of the trust you place in us when you buy your insurance through us, and our responsibility to protect your information. The UK’s updated Data Protection Act 2018 which was initially the UK’s enactment of the EU General Data Protection Regelation (GDPR). The UK retained provisions of the EU’s General Data Protection Regulation (UK GDPR (retained by virtue of the European Union Withdrawal Act 2018) and regulations based on wider EU legislation such as the Privacy and Electronic Communications Regulations (EC Directive) 2003 (PECR).
The Privacy Policy is designed to help you understand how we collect and use your information.
We may collect information from you about other people, for example, family members who may drive your vehicle. If you give us information about another person, it is your responsibility to ensure and confirm that:
- You have told the individual who we are and how we use personal information, as set out in this Privacy Policy; and
- You have permission from the individual to provide that personal information to us and for us to use it, as set out in this Privacy Notice.
As a ‘data controller’ under the act, Freeway UK Insurance Services Limited must comply with its requirements. This Privacy Policy is designed to help you understand how we collect and use your information.
Further information on the Data Protection Act and your rights, please visit the website for the Information Commissioner’s Office – www.ico.org.uk.
1 – Who we are and how to contact us
For any questions or concerns relating to this Privacy Policy or our data protection practices, or to make a Subject Access Request or any other request regarding the information we hold, please contact us at:
Freeway UK Insurance Services Limited
Unit 4 Abbots Park
Monksway
Preston Brook
Cheshire
WA7 3GH
Telephone : 01928 520520
Email : compliance.mailbox@freewayinsurance.co.uk
2 – What information we process and how we use it
We only collect, use and store your information where we have a lawful basis and legitimate business reasons to do so.
Why we need and how we use your personal information collected from you and how this is shared
We may collect, use, store and share personal information directly from you in order to fulfill requests for quotes, products and services as part of insurance broking, claims handling and risk management business. It may also be used to verify your identity, to administer payments and to enable us to carry out anti-money laundering and other financial crime checks where required. If you pay by installments your information may also be used to arrange credit.
In purchasing our products and services you should understand that you are forming a contract with us. Ig you contact us for a quote or request details on the services we provide, we may consider ourselves as having a legitimate business interest to provide you with further information about our services.
Nature of personal information: Personal data is any information that may identify a living individual. We collect personal information such as name, contact details, date of birth, gender, marital status, financial details, employment details and other personal details depending on the nature of the insurance and other services we offer.
Personal data may contain information which is known as special categories of personal data. This may be information relating to and individuals’ health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to sexual orientation, and may also contain data relation to criminal convictions and offences, all of which we will collect, use and store as necessary in relation to arranging insurances. Where we are legally required to, we comply with specific data processing requirements.
This information may be shared with insurers, insurance product providers and our third-party services providers. Where necessary, we shall obtain your consent to the processing of such information.
We only share your information if we are satisfied that our partners or suppliers have sufficient measures in place to protect your information in the same way that we do.
We may also disclose personal information to new owners of our business in the event that we are subject to a merger or acquisition. Disclosure may also be made to enable company audits, regulatory inspections or to investigate a complaint, suspicion of fraud or a security threat.
We never share your information outside our organisation for marketing purposes.
You understand that we may disclose the information you provide to relevant other parties for the purposes described in this Notice.
Fraud Prevention Agencies
We may also share your personal information with fraud prevention agencies such as the Claims and Underwriting Exchange Register and Motor Insurance Anti-Fraud and Theft Register. We may pass information relating to your insurance policy and any incident to the operators of these registers, their agents and suppliers.
MyLicence & Driver and Vehicle Licensing Agency (DVLA)
We require your Driving Licence Number (“DLN2”) to provide this to the DVLA to confirm your licence status, entitlement and restriction information and endorsement/conviction data.
This notice explains how we may use the details you provide us with. You should show this to anyone covered or proposed to be covered under your policy / prospective policy.
By continuing with your application, you confirm you have gained the consent of any named drivers for their data to be used as set out below.’ ‘I/We understand that you will, and I/we authorise you to use the data in accordance with this Data Protection Notice and carry out searches with and pass the data that I have provided to you to suppliers, insurers and third parties for the purposes set out in this Data Protection Notice.’
For Insurance underwriting purposes i.e. to examine the potential risk in relation to your (and/or a third party’s) prospective policy so that we can:
Provide your (or any person included on the proposal) Driving Licence Number (“DLN”) to the DVLA to confirm your (or the relevant person included on the proposal) licence status, entitlement and relevant restriction information and endorsement/conviction data.
Searches may be carried out prior to the date of the insurance policy and at any point throughout the duration of your insurance policy including at the mid-term adjustment and renewal stage. A search of the DLN with the DVLA should not show a footprint against your (or another relevant person included on the proposal) driving licence.
Searches may be carried out at point of quote or point of sale and if an insurance policy is incepted during the term of your policy and renewal stage
Undertaking searches against your (or any person included on the proposal) DLN against details held by the DVLA to confirm your licence status, entitlement and restriction information and endorsement/conviction data. This helps insurers check information to prevent fraud and reduce incidences of negligent misrepresentation and non-disclosure. A search of the DLN with the DVLA should not show a footprint against your (or another relevant person included on the proposal) driving licence.
Your personal data will not be used for marketing. It will only be shared within organisations
involved with the administration of your insurance policy or as otherwise set out in this Data
Protection Notice.
If we are unable to confirm your licence information with the DVLA, we will complete a check using the GOV.uk website, https://www.viewdrivingrecord.service.gov.uk/lang/en/driving-record/validate. We will obtain your consent before you provide your driving licence number, national insurance number (optional) and/or a DVLA check code, this information may be passed to the DVLA, the HMRC (His Majesty’s’ Revenue and Customs) and DWP (Department for Work and Pensions) in order to confirm your identity, your (or any named drivers) licence status, entitlement, relevant restrictions and endorsement/conviction data. Undertaking searches using this information will help us to prevent fraud and check the information is correct on your policy.
For details relating to information held about you by the Driver and Vehicle Licensing Agency (DVLA) please visit www.dvla.gov.uk.
Motor Insurers’ Bureau
We work in partnership with the Motor Insurers’ Bureau (MIB) and associated not-for-profit companies who provide several services on behalf of the insurance industry. At every stage of your insurance journey, the MIB will be processing your personal information and more details about this can be found via their website: mib.org.uk. Set out below are brief details of the sorts of activity the MIB undertake:
- Checking your driving licence number against the DVLA driver database to obtain driving licence data (including driving conviction data) to help calculate your insurance quote and prevent fraud
- Checking your ‘No Claims Bonus’ entitlement and claims history
- Prevent, detect and investigate fraud and other crime, including, by carrying out fraud checks
- Maintaining databases of:
- Insured vehicles (Motor Insurance Policy Database or Motor Insurance Database/MID)
- Vehicles which are stolen or not legally permitted on the road (Vehicle Salvage & Theft Data or MIAFTR)
- Motor, personal injury and home claims (CUE)
- Employers’ Liability Insurance Policies (Employers’ Liability Database)
- Managing insurance claims relating to untraced and uninsured drivers in the UK and abroad
- Working with law enforcement to prevent uninsured vehicles being used on the roads
- Supporting insurance claims processes
Cookies
Cookies are used to collate anonymous aggregated information that is used to manage and plan enhancements to our services and evaluate the effectiveness of our advertising and promotions on third party websites, for example tracking whether these advertisements are clicked on by users. If you do not wish for your data to be collected in this way, please refer to our Cookies Policy for instructions on how to turn this off. https://www.freewayinsurance.co.uk/cookie-policy/
IP Addresses
We collect IP addresses to monitor who is accessing our website as well as to detect and prevent fraudulent activity. This might not be the case where we have used cookies or IP addresses to collect information from your computer or portable electronic devices. Please refer to our Cookies Policy for more information. https://www.freewayinsurance.co.uk/cookie-policy/
Automated Decision Making
We and/or other parties may use your information for purposes such as statistical and trend research and analysis which may include computerised processes which profile you. Automatic profiling helps us and insurers understand, predict and forecast customer preferences and to improve the products and services we offer to assess which products might be the most suitable for you.
We also use computer systems to carry out modelling, sometimes using your personal information and sometimes using data in anonymised form. We conduct this modelling for a variety of reasons, for example, for risk assessment purposes to make decisions about you, such as your likelihood to claim. However, we may also use your personal information in that modelling to make decisions about how we improve our pricing and underwriting or to better understand how our prospective customers make decisions about which policy is the optimal policy (i.e. we are not making decisions directly about you).
Voice Recognition
Voice recognition is also known as biometric data, is an option provided to Freeway customers. The purpose of voice recognition is an added security measure and also to help reduce call times for customers. You will provide a recording of a specific phrase, which will be linked to your file and telephone number. When you next call from the number you will be asked to repeat the phrase to verify you. Freeway acknowledges that voice or biometric data, where used for identification purposes is considered special category personal data. If you provide consent for biometric recording, you can leave ‘your voice as your password’, removing the requirement to answer security questions on every call. This information is held securely in line with Data Protection regulation.
Calls
We may monitor calls, emails, text messages and other communications with you. When you contact us we may keep a record of the correspondence and any information provided to us during that or any subsequent communications.
Information Collected from Other Sources
We also obtain information about you from the Claims and Underwriting Exchange Register, Fraud Prevention Agencies, DVLA and similar third parties in addition to Price Comparison Websites. Some personal information may be provided to us by third parties such as insurance companies, other insurance intermediaries and motor vehicle licencing authorities. In some cases you will have previously submitted your personal information to them and given them approval to pass this information on for certain purposes. This can include information about you, your driving history (including criminal convictions and offences), details of accidents, information relating to the licences held with UK licencing authorities.
Such information will only be obtained from reputable sources which operate in accordance with the General Data Protection Regulation [EU 2016/679]and the Data Protection Act 2018 [Chapter 12].
What the Information is Used for
We have identified four the lawful bases which we use to collect and process data.
Contract – The information is needed to manage your account, product or service e.g. we will need to hold your information according to our retention policy, respond to claims or fraud prevention.
Legal Obligation – We are required by law to process your information e.g. to verify your identity.
Legitimate Interest – We are allowed to use your information where on balance the benefits of us doing so are legitimate and not outweighed by your interests or legal rights e.g. we have an interest in knowing what our customer do and don’t like so we can offer better products and services to analyse information we hold to ensure we are providing the right products you need.
Consent – In some cases we may obtain your consent to use information in a particular way or where the law requires consent to be obtained, e.g. if you consent to us providing you with information about our products and services, we will do so for as long as we can legally hold your data. We will never sell or share your data with any company who may wish to market their products and/or services.
Explanations of the purposes of how these lawful bases will be used and which is applicable to that purpose.
To check your identity and eligibility (Contract & Legal Obligation)
The law requires us to verify the identity of our new customer and to re-verify the identity of our existing customers from time to time. This is so we know who out customers are and to make it more difficult for criminals to use false or impersonated identities for criminal purposes such has hiding the proceeds of crime or committing fraud.
To verify your identity, we will check the information you provide to us with publicly available information and relevant databases such as the Claims and Underwriting Exchange Register.
We will also check that you meet the criteria to receive the product or service we are offering.
If you provide consent for biometric recording, you are able to leave ‘your voice as your password’, removing the requirement to answer security questions on every call.
To do what we are required to do by law (Legal Obligation)
As part of our duty as a broker providing insurance services, sometimes we are required by law to use information about you:
- To help make sure our customers are being treated fairly (e.g. to assist our regulators where we have a legal duty to do so)
- To deal with complaints
- To help prevent and detect crime (including for example the prevention of or detection of fraud)
- To comply with a legal or regulatory request
To manage your policy (Contract & Legal Obligation)
We will use your information to manage your policy you have with us in line with terms of the arrangement and the rules of our regulators. Examples of this are:
- To decide what the risk might be in selling you the policy, to quote for, and provide you with a premium for that policy and any special terms that may apply to that policy (noting that we may use automated decision making to make this assessment)
- To administer your policy
- To contact you about the policy (e.g. for billing or renewal purposes)
- To provide the agreed service if you make a claim (e.g. sending someone to assist you in the roadside breakdown situation or to provide you with medical assistance if you are injured or unwell when overseas)
To prevent financial crime and fraud (Legal Obligation & Legitimate Interest)
Fraud has an impact on all customers as it increases costs for everyone. We use your personal information to check for signs that customers might be dishonest (e.g. if someone has behaved dishonestly in the past it may increase the risk they will do so in future).
We may use your personal information in this way because it is in our interests to detect fraud and in all out customers’ interests to ensure that they are not prejudiced due to increased premiums as a result of a few customers acting dishonestly.
If we, or a fraud prevention agency determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or we may stop providing the existing services to you.
To recover debt (Contract)
If you owe us money, we will use your personal information to help us recover it.
We can use your personal information in this way because it is a necessary part of the contact of insurance. We need to ensure that premiums are paid so that the majority of our customers do not suffer (e.g. through increased premiums) due to the actions of a small minority of customers. We may instruct a debt collection agent or solicitor to act for us in recovering the debt, including by bringing legal proceedings in the courts and we will provide relevant information to help recover any money that is owed to us.
To identify other products that you may find useful (Consent)
If you obtained a quotation from us after 25th May 2018 you have been asked about marketing preferences. If you chose to receive marketing communications, a description of the type of marketing you will receive is detailed below. If your policy with us started before this date you will not be marketed to, however if you would like to ‘opt-in’ to receive marketing communications, please contact a member of our Customer Care department on 01928 520 520.
To manage and organise our business (Legal Obligation & Legitimate Interest)
We may use the information we hold to:
- Analyse how well our marketing is working
- Train our team
- Analyse trends or behaviours we can
- Assess the profitability (or other indicators) of a particular product, or service to inform out future commercial strategy
- Report to and communicate with our regulators, auditors and governmental
- In order to enable us to process your claim or administer your insurance policy most cost effectively
- To help develop our products, services and systems to deliver you a better service and claims experience in the future
3 – Marketing
Regarding our marketing activity we will ask for your consent to use your information in this way. We will confirm with you what forms of communication you would like to receive marketing information in and will only communicate marketing with you in the ways you have agreed.
We may use your personal information to offer you suggestions about products and services you might want to buy. We will send you information about our products and services by email, post, telephone or SMS unless you tell us not to, and only in the format which you have agreed to receive such communications. If we intend to use your data for such purposes, or if we intend to disclose your information to any third party for such purposes we will only do so with your consent. Your consent will be obtained specifically at the appropriate time.
Withdrawal of Consent
Where you have provided specific consent to the use of your personal data, you may remove your consent to receive marketing communications at any time.
If you decide you no longer wish to receive these marketing communications at any point, this withdrawal can be activated by contacting the office. You can send an email to compliance.mailbox@freewayinsurance.co.uk or you can call 01928 520 520.
4 – Transfer of Personal Data Outside of the UK
Certain personal information held on our Information Technology systems may be transferred across geographical borders in accordance with applicable law.
By providing us with information, you consent to the collection, international transfer, storage, and processing of your information. These transfers are governed by European Union (EU) standard contractual clauses or equivalent data transfer agreements to protect the security and confidentiality of personal information.
We will only share your data with firms who meet the requirements for data protection and security under the General Data Protection Regulation.
5 – How Long we Will Keep Information About You
We will keep your information for as long as it is required to enable us to provide quotations, administer your insurances, offer renewal and respond to any claims or complaints (which may arise after the period of insurance has expired).
We will retain information for a minimum of seven years after our relationship has ended, or following the settlement of any claim, whichever is longer. We may keep your information longer for legitimate business reasons, for example claims settlement purposes. This is to comply with our legal and regulatory obligations to keep a record of our relationship, to resolve disputes, or where may be needed for future legal proceedings.
We will also retain data in an anonymous form for statistical and analytical purposes after this date.
If you require further information relating to the timescales in which we hold your information. Please contact The Chief Quality Officer using the details at the bottom of this page.
6 – Your Rights Under the General Data Protection Regulations (GDPR)
The right to be informed – For us to provide you with information about our data processing activities, including through Privacy Notices such as this.
The right of access – The right of access to personal information we hold about you. To request a copy of this information you must make a subject access request in writing to us.
The right to rectification – You may ask us to correct any inaccurate or incomplete data within one month.
The right to erasure and restrict processing – You have the right to ask us to erase and to prevent the processing of data except where we have a legal obligation to process your personal information. You should bear in mind that by exercising this right you may hinder or prevent our ability to provide products and services.
The right for data portability – On your request we will provide you with your personal data in a structured format.
The right to object – You have a particular rights in relation to automated decision making and profiling to reduce the risk that a potentially damaging decision is taken without human intervention. You can object to your personal data being used for profiling, direct marketing or research purposes.
The right to withdraw consent – This right allows you to withdraw any consent you may have provided to The Firm relating to any processing of data.
If you want to invoke any of these rights or withdraw any consent please write, email or call us using the information provided at the beginning of this Privacy Notice.
7 – How to Complain
If you wish to make a complaint about how we hold or use your data, you should first contact us so we can understand your issue and try to resolve it. You can contact The Chief Quality Officer using the details below, or you can contact our Customer Care department on 01928 520 520.
The Chief Quality Officer
Freeway UK Insurance Services Limited
Unit 4 Abbots Park
Monks way
Preston Brook
Cheshire
WA7 3GH
Email : compliance.mailbox@freewayinsurance.co.uk
Should you wish not to raise your complaint with us, or if you already have but are unhappy with the response you have received, you can contact the ICO directly and their details are listed below:
Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113 / 01625 545 745
Fax: 01625 524 510