When processing your information, we must comply with six principles of good practice as follows:

• processed lawfully, fairly and in a transparent manner
• processed for specified, explicit and legitimate purposes
• adequate, relevant and limited to what is necessary
• accurate and, where necessary, kept up to date;
• kept for no longer than is necessary, and
• processed in a manner that ensures appropriate security

All information provided to us is stored on secure servers at our head office in Mold, or on secure cloud-based back up services in the United Kingdom

We will take all steps reasonably necessary to ensure your data is treated securely, including taking the following measures:

We may collect and process the following information (Personal Data)

• 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: Driver’s license number/Passport
• Financial information: Bank account number
• Criminal records data: Criminal convictions, including driving offences
• Policy information: Information about the quotes individuals receive and the policies they obtain
• Credit and anti-fraud data: Credit history, 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 health data, criminal records data, and other Special Categories of Personal Data (as described in the Insured Risk definition above)
• Current claims: Information about current claims, which may include health data, criminal records data, and other Special Categories of Personal Data (as described in the Insured Risk definition above)

We may obtain personal information by directly interacting with you, such as:

• Through the claim process via yourself directly, through your legal representatives or via instructions to handle insurance claims from our clients
• Corresponding with us by phone, email, letters or otherwise
• Meeting with you

We may obtain personal information about you from third parties or publicly available sources such as:

• The other party to the claim (claimant / defendant), witnesses, experts (including medical experts), loss adjustors, lawyers and claims handlers
• Other insurance market participants, such as Insurers, Reinsurers and other Intermediaries
• Credit reference agencies
• Anti-fraud databases and other third party databases, including sanctions lists
• Government agencies, such as vehicle registration authorities and tax authorities
• By conducting searches of publicly available databases or social media sites, such as Companies House, Facebook, Twitter, LinkedIn

We will only use ‘special category’ information if;

• We have your explicit consent.
• Where it is necessary for our or a third party’s legitimate interests, and your interests and rights do not override those interest, or
• Where we need to comply with a legal or regulatory obligation

To prevent and detect fraud we may at any time:

Share information with other organisations and public bodies including the police although we only do so in compliance with Data Protection law

Check and/or file details with fraud prevention agencies and databases and if we are given false or inaccurate information and we identify fraud, we will record this. We and other organisations may also use and search these agencies and databases from the UK and other countries to:

• Check your identity to prevent money laundering

Law enforcement agencies may access and use this information.

We and other organisations may also access and use this information to prevent fraud and money laundering, for example when:

• Checking insurance claims

We may use information about you and others to ensure compliance with financial sanctions in effect in the UK and internationally. This will include the

checking of your information against the HM Treasury list of financial sanctions targets as well as other publicly available sanctions lists. Your information and that of others may be shared with HM Treasury and other international regulators where appropriate. You may also be contacted in order to provide further details in order to ensure compliance with Financial Sanctions requirements.

We may share your personal information with the parties set out below:

• On all claims your information will be provided to the Insurer who holds the relevant policy
• Professional advisors connected to our business and the claims industry.
• Our outsourced IT services provider, Wicresoft Ltd. Together with providers of system administration services to our business
• Credit reference and fraud prevention agencies
• The information Commissioners Office, solicitors, National Crime agency the serious Fraud office and any other regulators and authorities who require reporting of processing activities in certain circumstances
• Business partners, suppliers and sub contractors to the extent we consider it reasonably necessary for us to perform claim handling
• We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions

You have legal rights in relation to the information you give us, or which we collect about you as follows:

You have a right to access the informationwe hold free of charge, together with why and how we are using your information, to whom we have disclosed that information, from where we originally obtained the information and for how long we will use your information.

You have the right to ask us to rectify any information that is inaccurate or incomplete.

You have the right to ask us to erase the information (the right to be forgotten). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.

You have the right to ask us to stop using your information where: (i) the information we hold is inaccurate; (ii) we are unlawfully using the information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use it for the purpose of legal proceedings or for protecting the rights of any other person. 

You have the right to ask us to transmit the information to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.

Where we use/store  information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which is more important than your interests, rights and freedoms. If you wish to exercise any of your legal rights, please contact our Data Protection Lead by writing to the address at the top of this policy. You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.

Questions, comments and requests regarding this policy are welcomed and should be addressed to our Data Protection Lead by writing to the address below

Phoenix Liability Services Ltd

Broncoed House

Broncoed Business Park

Wrexham Road

Mold

CH7 1HP

Alternatively you can contact the ICO direct using the link below: