Data Protection – Allianz plc Fair Processing Notice

This privacy statement/notice tells you how we use your information and confirms that your Data Controller is Allianz plc (“we”, “us”, “our”), Allianz House, Elmpark, Merrion Road, Dublin 4 D04 Y6Y6, Ireland. Email: info@allianz.ie. Our branch trading address is Allianz plc, 3 Cromac Quay, The Gasworks, Ormeau Road, Belfast, BT7 2JD, Email: info@allianz-ni.co.uk. Our Data Protection Officer is contactable at: DataProtectionOfficer@allianz.ie or please write to The Data Protection Officer, Allianz plc, Allianz House, Elmpark, Merrion Road, Dublin 4, D04 Y6Y6, Ireland.

  • 1. What Personal Information We Collect

    Type of Information                      

    The type of information we collect and use will differ depending on the type of product or service you have with us but includes (please note that this is not an exhaustive list):

    Name, address, date of birth, policy numbers, contact details, marital status, national insurance number (or any other relevant tax identification numbers) (if required by legislation), occupation, employment details, gender, insurance requirements including details about your home or vehicle, years of residency in the UK, driving licence details, marketing preferences and renewal dates of policies with other insurers, claims history, bank and payment card details, records of payments and arrears, VAT and other relevant tax numbers, CCTV footage, membership status of any relevant bodies, penalty point information and Road Traffic offences, telematics data, dashboard camera video footage, credit score and on-board vehicle diagnostics information. Further details of information we collect can be found under specific headings in this Data Protection Statement.

    Other People’s data:

    As well as collecting your personal data, we may also use personal information about other people, for example, family members you wish to insure on a policy, dependents (where relevant for suitability purposes), insured persons (where different from the applicant/policyholder) family health history of insured persons, limited personal information about trustees/beneficiaries (where policies are under trust), executors, nominated representatives and attorneys (under power of attorney).

    Sensitive information

    We may ask for health information or details of past or pending offences, unspent criminal convictions or other sensitive information about the person who is being insured, their family members or any other persons associated with the insurance policy. We recognise the sensitivity of collecting this information, so we will only ask for it to arrange, manage or administer an insurance contract, handle claims, or prevent fraud. Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals.

    Given the fact that data relating to health and criminal convictions is particularly sensitive information, we only collect and use such data as follows:

    Purpose: Criminal conviction data is collected and used for the purposes of obtaining/providing quotes and handling any complaints you may have.

    Basis: Performance of a contract under which we provide insurance services and assisting in the administration of a contract (the insurance policy); Consent (where another person provides your criminal conviction data to us so that we can provide them with a quote); and to take steps at your request before entering into a policy (e.g. obtaining/providing a quote)

    Purpose: Health data is used for the purposes of obtaining/providing quotes, providing and/or submitting a proposal for insurance and providing insurance services to assist in the administration of a policy including any complaints you may have.

    Basis: Data Protection law permits us to use health data where we need to and where it is proportionate for the purposes of a policy of insuranc

    We may also need to use your health and/or criminal data for the purposes of establishing, exercising or defending legal rights, including in connection with claims or proceedings and where authorised by law.

    You do not have to provide us with any personal information, however, should you be unable to provide us with the required personal data, we will be unable to provide you with a quote, insurance or process a claim that you make.

  • 2. How we collect your personal information

    We may collect personal information about you from:

    • you;
    • your named driver (if you are purchasing or renewing a motor policy);
    • joint policyholder;
    • our intermediaries;
    • your broker (or other representative);
    • insured persons (where different from the applicant/policy owner);
    • when you visit one of the Allianz Group websites (where you are purchasing or renewing a policy) or through cookies and other similar technologies when you visit our website or download and use one of our apps;
    • when you visit a website aggregator;
    • insurance industry databases and other commercial databases;
    • third parties involved in a claim (including a claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
    • communicating with us via social media platforms;
    • requesting any information from us;
    • other people who live with you in an insured property (if you are purchasing or renewing a home insurance policy);
    • your agents, attorneys (under powers of attorney), nominated representatives and other third parties relevant to you and/or the policy, including your legal advisers;
    • publicly available information including social media websites and online content, newspaper articles, TV, radio and other media content, court judgements;
    • telephone calls, which we may record or monitor for regulatory, training and quality assurance purposes;
    • other records within Allianz if you have or have had other insurance policies with or sought a quote from us or another Allianz company or third party claims;
    • the Insurance Fraud Bureau who operate a confidential phone line (cheat line for individuals who report suspect fraud);
    • and credit referencing agencies (including but not limited to County Court Judgments and details from the electoral register).

    Where you provide personal data relating to any person under the age of 16 years (“child”), Allianz will seek to verify that you are the parent/guardian of such a child. This is to ensure that you can authorise the processing of personal data relating to that child in order for Allianz to provide the insurance, deal with a complaint or claims.

  • 3. How we use your personal information
    PurposeLegal Basis
    To obtain/provide a quote, for underwriting and pricing an insurance policy including making a decision as to whether we can provide you with cover and at what price; and to investigate, validate, arrange, handle, manage or administer a claim which you or another person makes in relation to your insurance policy.Legitimate interest in managing our business; for the performance of a contract under which we provide insurance; and in order to take steps at your request prior to entering into a contract of insurance.
    To provide you with insurance cover, administer and process your insurance policy, including dealing with any queries or changes, payments, renewals and processing a cancellation of your policy; make payments to you or receive payments from you; provide you with services such as breakdown assistance; and processing of any complaints; and maintain and store records on our computer systems.For the performance of a contract under which we provide insurance.
    To verify your identity.For the performance of a contract under which we provide insurance.
    To carry out financial sanctions checks and prevention of financial crime.For the performance of a contract  under which we provide insurance; in order to take steps at your request prior to entering into a contract of insurance; to comply with legal obligations; and public interest.
    To comply with laws and regulations provide repository policy information in respect of new and renewed employer’s liability insurance policies.To comply with legal obligations.
    For marketing purposes, customer satisfaction surveys, and data analytics including profiling, to develop and enhance the customer relationship and journey as part of our business strategy; for management information purposes including portfolio assessment, risk assessment, performance reporting and management reporting; for a proposed portfolio transfer, reorganisation, transfer, disposal or other transaction relating to our business; Managing our business effectively (e.g. with third party service suppliers); for audit purposes and managing our legal affairs including exercising our legal rights and defending claims; to maintain arrangements we have with reinsurers; to manage our IT security and network; to carry out statistical analysis and reporting to help improve services and products; staff training in how to perform their duties and provide a better service to you; monitor recorded customer calls to assess our staff’s customer service; provide online services; and to enhance our applications and product offerings.Legitimate interest in managing our business; to better understand our customers; improve product and/or service enhancement; and monitor and assess business performance.
    To detect and prevent fraud.For our legitimate interest in managing our business; for the performance of a contract under which we provide insurance; and to comply with our legal obligations.


    If you are purchasing a policy, we also use certain information and consult certain databases as follows:


    Information Used: logging of any new claims notifications and any claim settlement for damage and injury.

    Purpose: to confirm your personal data and verify claims information and/or for prevent and detecting crime and fraud through the Claims and Underwriting Exchange Database.

    Processing is necessary: to comply with legal obligations.

    Information Used: Driving Licence Number.

    Purpose: to validate your driving licence number with the relevant authority; to validate the number of penalty points disclosed by you.

    Processing is necessary: in order to takes steps at your request prior to entering into the policy or for the performance of your policy.

    Information Used: vehicle registration number.

    Purpose: If you have a motor insurance policy, your details will be added to the Motor Insurance Database managed by the Motor Insurers’ Bureau ("MIB"). MID data may be used by the DVA for the purpose of Electronic Vehicle Licensing and by the Police Service for Northern Ireland (PSNI) for the purposes of establishing whether a driver's use of the vehicle is likely to be covered by a motor insurance policy and/or for preventing and detecting crime. If you are involved in an accident (in the UK or abroad), other UK insurers and the MIB may search the MID to obtain relevant policy 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.

    Processing is necessary: to comply with legal obligations.

  • 4. How we share your personal information with others

    We may share your personal information with: the Allianz Group, our agents, third parties who provide services to us (engineers, repairers, motor assessors, loss adjustors, expert appraisers, expert witnesses etc.), your intermediary and other insurers (either directly or via those acting for the insurer such as loss adjusters or investigators); providers of essential services (e.g. telecommunications, postal/courier providers, IT service providers, software providers, payment processor); other third parties involved in administering your contract; regulatory bodies and law enforcement bodies, including an Garda Siochana and PSNI (for example, where we are required to do so to comply with a relevant legal or regulatory obligations); reinsurers who provide reinsurance to Allianz (reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations; they will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies); witnesses to any accidents/incidents to which you are involved; any party you have given us permission to speak to (e.g. your representative, a relative or a friend); any party named under your insurance policy; industry and trade bodies; and claimants and their legal or medical representatives.

    The personal information you provide may be used by us and shared with other insurers as well as certain statutory and other authorised bodies for anti-fraud purposes: other insurance companies to confirm information provided (including where you are purchasing a motor insurance policy, for the purposes of validating any No Claims Discount) and to safeguard against non-disclosure and help prevent fraudulent claims; public bodies and the PSNI and other law enforcement agencies; the Motor Insurance Anti Fraud and Theft Register (MIAFTR) and the Insurance Fraud Bureau, Claims and Underwriting Exchange Register (CUE) which are run by the MIB, to prevent and detect fraud;; the Motor Insurers’ Bureau (MIB) to assist in preventing or detecting theft and fraud and to pay claims; private investigators, tracing debtors or beneficiaries, recovering debt, managing your accounts and/or insurance policies; vehicle history check suppliers/ databases to protect our customers, inform our acceptance criteria and assist in claims investigations; and other fraud prevention, ID verification databases available in the insurance industry and publicly available information to detect or prevent possible criminal activity or fraud. If you have a motor policy, your personal details will be added to the Motor Insurance Database (MID) managed by the MIB, MID data may be used by the DVA for the purpose of Electronic Vehicle Licensing and by the PSNI for the purpose of establishing whether a driver’s use of the vehicle is likely to be covered by a motor insurance policy and/or for preventing and detecting crime. If you are involved in an accident (in the UK or abroad), other UK insurers and the MIB may search the MID to obtain relevant policy 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 MID. You can find out more on www.mib.org.uk.

    We will use your personal information to detect and prevent fraudulent practices and fight financial crime to meet our regulatory responsibilities. If you purchase a product from our website or other Allianz sales channel, we will also ask you for payment details. We need this information so we can process the payment associated with any product purchased. We collect information to help us improve our products and services and let people know about products and services that we believe will be of interest to them. This may be through a range of channels including via email, online advertising or social media. We will always do this in accordance with marketing preferences provided.

    Where we obtain data from the above sources, the categories we obtain will be personal data or claims information relating to insurance profiling, claims handling and fraud prevention. We may need your consent for the processing of certain data and in these cases, we will inform you of such processing and the reason for this at the time consent is captured.

    Protecting Information Outside the European Economic Area

    Your personal data may be transferred to and/or accessed from a country outside the European Economic Area (“EEA”). We will always take steps to ensure that any transfer of information outside the EEA is carefully managed to protect your privacy rights. Such transfer/access within the Allianz Group will be covered on the basis of the Allianz Group binding corporate rules (BCRs) known as the Allianz Privacy Standard (APS) which contractually obliges each member to ensure that your personal information receives an adequate and consistent level of protection wherever it is transferred within the Group. Where we transfer your data to a non-Allianz Group member or other companies providing us with a service, we will obtain contractual commitments and assurances from them to protect your personal information. Theses assurances are well recognised certification schemes like Standard Contractual Clauses. We will only transfer your personal information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. Any requests for information we receive from law enforcement or regulators will be carefully validated before personal information is disclosed.

    Representation

    If you provide information about someone else, such as an additional insured, we will endeavour to provide this Data Protection Statement to them. Where it is not possible to do so, you must make them aware of this Data Protection Statement and the terms of the insurance (including changes to the terms or processing activities) and encourage them to read this Data Protection Statement to find out more.

    Online Information

    When you visit the www.allianzni.co.uk website, we may record information about your computer or mobile device, including hardware and software used, general location, when and how you interact with our websites. This information is used to note your interest in our websites and improve customer journeys.

    Your rights in relation to your personal information

    You have the right to request a copy of your personal data, and to have incorrect personal data about you corrected. You also have the right to withdraw your consent for the processing of your personal data, have your personal data erased, or the processing restricted. Please note that withdrawing consent and requests for restriction/erasure may affect our ability to provide you with a contract of insurance. Some of the above rights are subject to limitations in order for us to comply with a number of legal and regulatory obligations. You have the right to data portability for insurance purposes (contact dataprotectionofficer@allianz.ie).

    You also have the right to lodge a complaint with the Data Protection Commissioner. For further information, please see the section “Contacting Us” below. 

    Up to date information

    In order for us to keep your information accurate and up to date, please contact Allianz or your insurance intermediary (where applicable) if any of your details change. For contact details, please see “Contacting Us” below.

  • 4A. How Long we Keep your Information

    We will keep your personal data only for as long as it is required for your insurance contract, to handle claims and to comply with our legal and regulatory obligations as documented in our Records Management Policy. For the majority of policy data, this is seven years after the end of that transaction. If you do not accept a quote or complete an application for an insurance policy, your data will be kept for fifteen months and processed in line with this Statement. When a potential claim or actual claim is taken out on a policy, we hold details around this claim until a full and final settlement has been agreed. In most cases this should be seven years after the final settlement date or where a child was involved the later date of seven years after the child has turned eighteen or the settlement date. In certain cases, we are obliged to hold onto records for longer periods and we do so in line with our legal responsibilities. For more information on our data retention policies please refer to the “Contacting Us” section below.

  • 4B. Automated Decision Making

    As part of the provision of your insurance contract, including at quotation stage, Allianz may use automated decision-making. This means that we may use an automated underwriting model which uses your personal data to evaluate, analyse or predict the performance of your contract of insurance. Premiums are calculated according to the risk of loss, with the risk ascertained on the basis of profiling by way of a pricing tool and system. This avoids unfair discrimination. Certain motor policies also use Telematics (Allianz Safe Driver App) where driving behaviour is used to measure driving performance and to determine the nature and level of the risk associated with your insurance policy. In these cases, suitable safeguards are in place and you have the right to human intervention to express your interests and contest automated decisions. If you are making a claim, we may use profiling and other forms of automated processing to assess if your claim may be fraudulent and we may use your sensitive information, to carry out this assessment. For example, we may use your unspent motoring convictions for motoring insurance. We use automated decision making as it is necessary for entering into, or performance of your insurance policy between you as the data subject and Allianz as data controller, and other uses such as those authorised by law.

    In the event that profiling determines you have a high risk profile, we may not be able to offer you an insurance policy. If you wish to review an automated decision with Allianz, please contact us on dataprotectionofficer@allianz.ie.

  • 4C. Direct Marketing

    If your chosen preference is to receive marketing, we may contact you by email, SMS, phone or post with helpful information on products, services, special offers and competitions. If you no longer wish your information to be used for marketing purposes please write to us at Allianz plc, 3 Cromac Quay, The Gasworks, Ormeau Road, Belfast, BT7 2JD, or e-mail us at info@allianz-ni.co.uk.

  • 5. Contacting Us / How to Make a Complaint

    If you have any questions about how we use personal information, or if you want to exercise your rights stated above, please contact our Data Protection Officer  by either emailing, DataProtectionOfficer@allianz.ie or please write to:

    The Data Protection Officer, Allianz plc,
    Allianz House,
    Elmpark, Merrion Road,
    Dublin 4, D04 Y6Y6,
    Ireland

    If you have a complaint or concern about how we use your personal information, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have the right to lodge a complaint with the Office of the Data Protection Commissioner at any time. The details of the Data Protection Commission are as follows:

    Data Protection Commission
    Canal House, Station Road,
    Portarlington, County Laois.

    Telephone: +353 (0)761 104 800 or +353 (0)57 868 4800

    Lo Call Number: 1890 252 231

    Email: info@dataprotection.ie

    Fax: +353 57 868 4757


  • We may amend this Statement from time to time, in whole or in part, at our discretion. The latest version of this document will always be available at www.allianzni.co.uk and will take effect on the date that it is updated.
  • Please review this Data Protection Statement periodically to ensure you remain informed.

Date Last Updated: 2019-06-27 1:00 PM

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