Privacy Policy

How we act

We act as the data controller in respect of your personal information and are committed to protecting your privacy.  We will process the details you have given us (this includes information provided to us via a comparison website) in line with the UK’s Data Protection laws and any other laws that apply.

If your quote originated from a comparison website you should be aware that they act as the data controller of the data that they collect on their site(s). When you click through to our website we will be the data controller of the information that we collect on our site.

Legal basis for processing

The collection of and processing of data about you and other persons connected with your insurance is necessary for the entering into and performance of a contract or contracts and this forms legal basis we have for processing information. We also have legal obligations to perform in which case processing of your information is necessary for compliance with the legal obligations to which we are subject, for example Proceeds of Crime Act 2002.

If you do not consent to processing

You are not obliged to provide us with personal information, but we cannot provide our services without it.

Your rights

You have the right to object to us using your personal information. You can do this at any time by telling us. We will consider your request and either stop using your information or explain why we are not able to. Further details about your rights and how you can contact us are provided below.

We reserve the right to amend or modify this privacy policy at any time and any changes will be published on this website.

Collecting and processing your personal information

For us to provide and administrate insurance quotes, insurance policies, and/or deal with any claims or complaints we need to collect and process information (including personal data) about you and any other individuals you may disclose. We may also process information classified as “special categories”, which includes details about health and medical conditions, and criminal convictions.

Information you provide about other people will be processed on the basis that you have provided this information with their explicit consent.

The types of personal data that we process may include but not be limited to:

 

Individual details	such as name, address, contact details, marital status, date and place of birth, nationality, employer, job title, family details
Identification details	identification numbers issued by government bodies or agencies, including your national insurance number, employers reference number, passport information, tax and driving licence information, utility bills, certificates of incorporation (for businesses)
Financial information	bank account and payment card details, income, expenditure or other financial information
Risk information	information about you or other persons named or eligible to claim benefits under a policy in order to assess the risk to be insured and provide a quote. This might include data relating to health, criminal convictions or other special categories of personal data. For certain types of policy, this could include information such as telematics data.
Policy information	Information about the quotes you receive and the policies you arrange
Credit and anti-fraud data	see the heading “Credit Searches and fraud prevention” below.
Previous and current claims	Information about previous and current claims (including unrelated insurances) which may include data about your health, criminal convictions or other special categories of personal data. This may also include surveys.
Special categories of personal data	certain categories of personal data have additional protection under data protection laws. The categories are health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or orientation. The special categories we collect relate to health and criminal convictions, however it is possible that special categories of data may be collected through our interactions with you, in which case we will ensure we meet the additional levels of protection required under the data protection laws.

 

In the event of a claim we may also collect information from third parties (such as the other party involved in the claim), witnesses, experts, loss adjusters, loss assessors, solicitors and claims handlers.

To ensure that your personal details are protected, you may be asked questions to confirm your identity before we can communicate with you.

We process personal data to provide you with our services, which include:

• Providing quotations and arranging your insurance cover
• Administering your insurance policies
• Claims processing or assisting you in your claim
• Processing renewals and adjustments
• Complying with our legal or regulatory objectives
• Debt collection
• Help improve our customer service

We will disclose your information to insurers, intermediaries, our service providers, contractors and agents and group companies that perform activities on our behalf for these and other purposes described in this policy.

To help improve customer service and for quality control and training purposes, calls may be recorded and monitored.

Credit searches and fraud prevention

We may exchange your personal data with or carry out checks with credit reference agencies, fraud prevention agencies, and other public and privately available sources of information. These checks may include electoral roll and credit information (including credit history and credit score), sanctions and details of criminal offences. Insurers may also perform these checks as well. We perform these activities to check your identity, assess credit worthiness, help prevent fraud and money laundering.

Insurance credit checks are registered as general insurance searches and may be viewed by other companies when you apply for credit or insurance. These searches should not harm your credit profile or adversely affect your credit profile.

These checks may be performed at any stage of the quote, purchase process or when your insurance is due for renewal. This may happen regardless of whether you get a quote via the internet or phone.

If you make an application for credit the premium finance provider may perform a full credit check.

You should also be aware that some insurance companies exchange information through various databases, including the Claims and Underwriting Exchange (CUE) which holds a record of incidents reported to insurers, which may or may not have given rise to a claim. This exchange of information enables insurance companies to verify the information that is provided during the quote process (including information about any third party who is named on the policy), and also helps to prevent fraudulent claims.

If you deliberately misrepresent or provide false or inaccurate information and we suspect fraud we will record this on our own data bases and may exchange it with fraud prevention agencies or other authorities, for example the Police.

Retention of your personal data

We will keep your personal data for so long as is necessary and for the purpose for which it was collected. In particular, for as long as there is any possibility that either you or we may wish to bring a legal claim or a complaint under your insurance, or where we are required to keep your personal data due to legal or regulatory reasons.

International transfers

When we pass your personal data (including special categories of personal data) to insurers, their agents, intermediaries or other service providers you should be aware that they (including their affiliates or sub-contractors) may have offices located outside the European Economic Area (EEA). Transfer of your information should be made in compliance with the applicable data protection laws to ensure your information is properly protected. Your policy documents will set out how your data is used and whether it might be transferred outside the EEA. You should also be aware that those parties and ourselves might use the services of digital storage providers because of the amount of data we collect and process. We ensure that appropriate measures are in place to ensure we only use the services of those providers who meet the standard expected in the applicable data protection laws.

On-line information

When you visit our 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 website, improve customer journeys, and for anti-fraud purposes.

Your rights

You have the right to:

• Object to us using your personal information. We will either agree to stop using it or explain why we are unable to.
• Ask for a copy of the personal information we hold about you (some exemptions apply)
• Ask us to update or correct your personal information to ensure its accuracy
• Ask us to delete your personal information if it is no longer needed for the original purpose
• Ask us to restrict the use of your personal information in certain circumstances
• Ask for a copy of your personal information so you can use it for your own purposes (data portability)

Complain

if you are concerned about how we have used or processed your information or if you feel your personal information has been mishandled. You can write to us directly at Data Access Team, Comfort Insurance, Comfort House, 8 Goresbrook Road, Dagenham RM9 6UR or you can complain directly to the Information Commissioner’s Office (ICO), details can be found here (https://ico.org.uk/concerns/handling/)