Privacy Policy

The way we use your information will be different depending on why you have provided your information to us:

• If you are unsure whether we are the data controller of any of your personal information, please contact us and we will be happy to help.
• If you are using our website, please read the ‘Website User’ section.

This Privacy Policy explains how we use the information we process about you and your rights in respect of this information.

Changes to this Privacy Policy

We reserve the right to update this Privacy Policy from time to time. Such changes may be necessary, for example, due to changes or developments in data protection laws, privacy best practice or the introduction of new technologies. You should check our website periodically to view the most up-to-date Privacy Policy. This Privacy Policy was last updated on 13/06/2019.

Definitions

In this policy, the words listed below have the following specific meanings when they appear in bold type with or without an initial capital letter:

'Data Controller(s)’ means the company who determines the purposes and means of processing personal information. Data controllers can appoint data processors who must act on behalf of the data controller.

‘Direct Marketing’/’Marketing’ means promoting and selling products and services directly to the public e.g. post, telephone, email, etc.

‘Lawful Basis’/’Lawful Bases’ means the valid legal ground(s) a company relies upon to process your information.

‘Legitimate Interest(s)’ is one of the lawful bases for processing and means the interests of the company or the interests of third parties. Legitimate interests could be commercial interests, individual interests or broader societal benefits.

‘Personal Information’ means information/data relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

‘Profiling’ means automated processing of personal information intended to evaluate, analyse, or predict an individual’s behaviour.

‘Sensitive Information’ means special category data and criminal convictions and offences information.

‘Special Category Data’ means the following types of information: race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; or sexual orientation.

‘We’, ‘us’, ‘our’ means Provident Insurance a trading name of Covea Insurance plc.
We (Covea Insurance plc) are the data controller of the personal information that you provide to us.

‘You’, ‘your’, ‘yours’ means the data subject. A data subject is a living person whose personal information is processed by a data controller or data processor.

Disclosure of other people's personal information

Please make anyone whose personal information you have provided to us aware of this Privacy Policy. You must make sure any information you supply about anyone else is accurate and that they’ve agreed to their information being supplied.

How to contact us

We have appointed a Data Protection Officer who is responsible for overseeing how we handle your information. Please contact us if you have any questions about our Privacy Policy or the information we hold about you.

Write to us at:
The Data Protection Officer
Provident Insurance
50 Kings Hill Avenue
Kings Hill
West Malling
Kent
ME19 4JX

Or email: dataprotection@providentinsurance.co.uk

How we use your information

If you have a policy with us or you are considering getting a policy with us, we collect information about you when you get a quote for insurance, when you buy or renew an insurance policy from us, when you amend or cancel your insurance policy or when you make a claim under your insurance policy.

If you are claiming under another person’s policy as a third party claimant, we collect information about you when you make a claim under the insurance policy.

If you are a witness to an event giving rise to a claim, we collect your information to help us handle the claim.

We only collect information that is relevant and necessary for us to provide the insurance product and to handle claims made under the insurance policy.

If we speak to you on the telephone, we may record calls for training and monitoring purposes to help improve our service and to detect and prevent fraud.

What type of information do we collect?

• Personal information provided by you, about you and any additional drivers, directly or through an aggregator:
  • Contact details
  • Social media username (if you contact us through social media)
  • Date of birth
  • Occupation
  • Homeowner status
  • Marital status
  • Gender
  • Driving licence details
  • Residency status
  • IP address
  • Device type that you are accessing the website from
  • Images and videos from dash camera footage
  • Your opinions and feedback if you are a member of our customer panel
• Financial information provided by you, directly or through an aggregator:
  • Payment details
  • Transactions and payments made to us for your policy
• Sensitive information provided by you, directly or through an aggregator:
  • Criminal convictions and offences
  • Health information including medical conditions
• Information about what you are insuring provided by you, directly or through an aggregator:
  • Your vehicle details including the car registration, car make and model, annual mileage, value, class of use, where the vehicle is kept etc.
• Information about your insurance history provided by you, directly or through an aggregator:
  • Recent quotes for insurance
  • Your insurance history
  • Claims details
• Information relating to fraudulent or potentially fraudulent activity provided by fraud agencies and databases:
  • History of fraud
  • Indicators of fraudulent behaviour
  • Investigations into fraud
• Your credit information provided by credit reference agencies:
  • Your credit history and score
  • Details of any unsecured loans, outstanding amounts and any defaulted payments
  • Information on the electoral register
  • Details of County Court Judgments and bankruptcy
• In addition to the information above, we also collect information from third parties, to assist us in assessing your insurance risk. Some of this information is publicly available such as census data. Where required, we also collect information regarding your vehicle from HPI Ltd and the Driver and Vehicle Licensing Agency (DVLA)

Why we use your information

The information we collect may be used by us, our employees and third party insurers and/or service providers who are acting under our instruction, for the reasons detailed below. We must always have a lawful basis for processing your information. When we process your sensitive information, we must always have an additional lawful basis.

For each reason for processing your information, we have set out our lawful bases:

Why do we use your information	Our lawful bases for processing	Our legitimate business interest, where applicable
To provide you with a quote Assessing your application for insurance and, if we can, the price and other terms we can offer	Personal Information: Entering into and the performance of a contract Legitimate interest	To price our products based on your insurance risk and to set policy acceptance parameters to determine when we want to insure certain risks.
	Sensitive Information: Substantial public interest - insurance
To administer and manage your insurance policy Administering the purchase of your policy Managing your policy Processing your insurance premiums Arranging the renewal, cancellation or lapse of your policy	Personal Information: Entering into and the performance of a contract Legitimate interest	To price our products based on your insurance risk and to set policy acceptance parameters to determine when we want to insure certain risks.
	Sensitive Information: Establish, exercise or defend our legal rights Substantial public interest - insurance
To handle claims made against an insurance policy Registering your claim Assessing your claim Processing payments for your claim Processing reinsurance recoveries	Personal Information: Entering into and the performance of a contract Legitimate interest	To undertake checks to validate and settle your claim.
	Sensitive Information: Establish, exercise or defend our legal rights Substantial public interest - insurance
To resolve any complaints you may have Register complaints Manage and resolve complaints	Personal Information: Entering into and the performance of a contract Legitimate interest	To investigate and resolve any complaints made.
	Sensitive Information: Establish, exercise or defend our legal rights Substantial public interest - insurance
To recover any debt that you owe to us Recovery of unpaid debts or reimbursement of damages under a contract	Personal Information: Entering into and the performance of a contract Legitimate interest	To recover any debt that is owed to us even if we do not hold a contractual relationship with you.
To conduct credit reference checks and to assess your application for credit Verifying your identity Making decisions about credit	Personal Information: Entering into and the performance of a contract Legitimate interest	To check the details you provide to verify your identity. To check your ability to afford the finance you are purchasing.
To prevent, detect and investigate fraud or money laundering Investigating suspicions of fraud and money laundering Prosecuting fraud	Personal Information: Legitimate interest	To prevent fraud and money laundering.
	Sensitive Information: Substantial public interest – preventing or detecting unlawful acts
For management information purposes and internal analysis of products and services Accounting and financial records, analysis and reporting Audit requirements Legal and professional advice Research into market trends and customer demographics Pricing and underwriting models and analysis System security and effective operation	Personal Information: Legitimate interest	To monitor our business performance and maintain appropriate company records. To develop, manage and improve our products and services. To build and refine our pricing models and ensure we are accurately pricing our products.
	Sensitive Information: Substantial public interest – insurance
For training purposes to improve your customer experience Assessing customer experiences Developing and improving our customer experience	Personal Information: Legitimate interest	To improve the service we provide to customers.
	Sensitive Information: Substantial public interest - insurance
To market additional products and services to you Recording your marketing preferences in connection with products and services	Personal Information: Consent	Not applicable.
For customer research to improve our products and services to you Recording your consent to be a part of our customer panel Assessing customer experiences Developing and improving our customer experience Entering you into a prize draw as a reward for providing your feedback and providing the winner with the prize	Personal Information Consent	Not applicable.

Insurance Policy Renewals

We will contact you prior to your policy expiration date with details of whether we can provide you with another insurance policy and the price of the policy.

If you have opted in, your policy will automatically renew so that you have continuity of cover. This means you need to contact us advising that you do not wish to renew otherwise the policy will automatically renew. We will always make it clear in your renewal letter if this will happen and we will always give you enough time to notify us of the lapse of your policy. You can change your opt-in/opt-out details when you reach renewal.

Customer Panel

If you have consented to join our customer panel, we will ask you for your opinion and feedback so that we can improve our products and services. When you complete one of our surveys, we enter you into a prize draw and we will contact you if you have won so that we can send you the prize.

You can opt out of the customer panel at any time by contacting us on 03300 240 123 or by clicking unsubscribe on any of the emails we have sent you.

Fraud prevention and detection

Applying for a quote and holding an insurance policy with us

If we suspect fraudulent behaviour, we may not offer you insurance or we may void your policy.

When you apply for a quote and/or take out an insurance policy with us, we will carry out checks to help us to prevent and detect fraud and money laundering. Some of the checks that we carry out are with fraud prevention agencies and databases.

We will keep a record of individuals and any associated investigations to prevent and detect future fraud or money laundering.

Making a claim

If you make a claim against one of our insurance policies, we will carry out checks to help us to prevent and detect fraud and money laundering. Some of the checks that we carry out are with fraud prevention agencies and databases.

If we suspect fraudulent behaviour, we may not be able to accept your claim. We investigate potentially fraudulent claims and where appropriate, we will use surveillance to assist our investigation. We appoint fraud investigation and surveillance suppliers to conduct these investigations on our behalf.

We will keep a record of individuals and any associated investigations to prevent and detect future fraud or money laundering.

Fraud agencies and databases

To prevent and detect fraud, we check your details against a range of databases and agencies including other insurers' databases. If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies, fraud databases and other insurers. Law enforcement agencies may access and use this information.

We access and use the information recorded by fraud prevention agencies or fraud databases to prevent fraud and money laundering. These checks are done to identify, predict, investigate and evaluate potentially fraudulent behaviour.

We use the following fraud prevention agencies and databases:

• CIFAS National Fraud Database
• CUE (Claims and Underwriting Exchange)
• IFB (Insurance Fraud Bureau)
• IFIG (Insurance Fraud Investigators Group)
• IFED (Insurance Fraud Enforcement Department)
• IFR (Insurance Fraud Register)
• NFIB (National Fraud Intelligence Bureau)
• NCA (National Crime Agency)
• OFSI (Office of Financial Sanctions Implementation)
• Lexis Nexis
• Motor Insurance Database
• MIAFTR (Motor Insurance Anti-Fraud and Theft Register)
• DVLA (Driver and Vehicle Licensing Agency)

You can get more information about the CIFAS National Fraud Database at www.cifas.org.uk/fpn.

Credit checks with credit reference agencies

We will perform credit and identity checks on you with one or more credit reference agencies (CRAs) in the following circumstances:

• When you apply for an insurance quote with us;
• Prior to renewals on all existing policyholders;
• When you apply for credit from us.

To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

• Assess your creditworthiness and whether you can afford to take the product;
• Verify the accuracy of the data you have provided to us;
• Prevent criminal activity, fraud and money laundering;
• Manage your account(s);
• Trace and recover debts; and
• Ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at www.transunion.co.uk/crain.

Automated Decisions

Some of our reasons for processing will involve automated decision making. You have a right to obtain human intervention for any of our automated decisions. If you object to an automated decision, we may not be able to offer you an insurance quotation or renewal.

Offering an insurance policy and pricing

We, directly or through a price comparison website, ask you a series of questions when you obtain a quote for insurance from us. This is so we can understand the insurance risk that we are being asked to consider and make an underwriting assessment and decision. The information you provide along with other information helps us to decide whether we can offer you a quote and the price you will need to pay for insurance.

We use lots of factors to assess whether we can provide insurance cover, the price of your policy and any other terms of your policy. These factors include, but are not limited to, your age, your vehicle details, your geographical location, claims history, the past performance of the insurance product, information about levels of crime within your postcode area, details about the type of vehicle you are insuring, credit history information, etc.

Based on this information, an automated decision will be produced on acceptability of cover, the price you will need to pay for your policy and any other terms we need to apply.

Validation lists

When we use your personal information to assess your application for insurance and when handling any claims made against the insurance policy, we will check your details against our validation lists.

Validation lists include, but are not limited to, individuals who have made multiple changes to quotes, non-disclosures, defaulted on their direct debit payments or committed potentially fraudulent activity. This is an automated check with an automated decision to decline insurance if you are on the list.

Credit checks

When we carry out credit checks, an automated score is produced by the credit reference agency. We use this to assess the terms and price on which cover may be offered, verify your identity and prevent and detect fraud.

How we share your information

In order to sell, manage and provide our products and services, prevent fraud and comply with legal and regulatory requirements, we may need to share your information with third parties, including:

• Reinsurers (A reinsurer is a specialist company that we transfer some or all of the insurance risk to (reinsuring)).
• Our auditors (for management information purposes).
• Regulators and other industry bodies (A regulator is a body that supervises specific industry or business activity).
  • Information Commissioner’s Office (ICO)
  • Financial Conduct Authority (FCA)
  • Financial Ombudsman Service (FOS)
• Credit reference agencies
• Fraud prevention agencies
• Crime prevention agencies, including the police
• Suppliers carrying out a service on our, or your behalf
  • We use computer software and technology suppliers that provide systems, software and technology so that we can offer our products and services.
  • When you have windscreen damage and we appoint you one of our approved glass repairers.
  • For some types of damage to your vehicle, we appoint you one of our approved repairers.
  • We use call centres to support some of our telephone helplines outside of normal working hours so that you can always contact us about your claim.
• Other insurers, business partners and agents
• In the event of a merger or acquisition or sale or transfer of any of our business or assets, your personal information may be disclosed to the prospective buyer or other party involved. Your information will only be used by them upon transfer to fulfil the original purpose for which it was collected, and you will be made fully aware of the details of the transfer.

These companies are data controllers of your information and you should refer to the relevant company’s Privacy Policy for how they use your information.

• Breakdown cover is provided by RAC Motoring Services and/or RAC Insurance Ltd.
• Motor Legal Protection cover is administered by Arc Legal Assistance Ltd on our behalf.
• Motor Legal Protection cover – Hebble Law are appointed as our approved solicitors to provide motor legal assistance.
• Replacement Car cover - we appoint Enterprise Rent-A-Car to supply the replacement car to you.
• When we need to recover debt, we appoint Moorcroft Debt Recovery Limited to act on our behalf.
• Where applicable, the aggregator you used to purchase the insurance policy.
• Where applicable, the social media site that you used to contact us.
• Other UK and EU Covéa and parent companies.

Motor Insurance Database

The Motor Insurers’ Bureau (MIB) is the Data Controller for the Claims Underwriting and Exchange Register (CUE) and the Motor Insurance Anti-Fraud and Theft Register (MIAFTR). For more information please visit www.mib.org.uk.

Information about your insurance policy will be added to the Motor Insurance Database (MID), managed by MIB.  MIB process personal information about you, this information may include your personal details, goods and services, financial details, education and employment details. On occasion MIB may collect special category data such as records of any personal injury claims. The police, the Driver and Vehicle Licensing Agency (DVLA), the Driver and Vehicle Agency (DVA), the Insurance Fraud Bureau and certain other authorised organisations may use the MID and the information stored on it for purposes including:

• Electronic licensing;
• Continuous insurance enforcement (to reduce the number of people driving without insurance)
• Enforcing the law (preventing, detecting, cautioning or prosecuting offenders)
• Providing government services or other services aimed at reducing the number of uninsured drivers.

MIB’s legitimate interests in providing the CUE/MIAFTR data to the industry is detecting and preventing fraud. By preventing consumers from making multiple or illegitimate claims against insurance policies it will save the insurance industry a considerable sum of money.  This in turn will reduce the cost of insurance premiums for the insurance industry, benefiting the wider consumer public.

The purpose of MIB processing your personal information is to provide access for the insurance industry to the MIAFTR database and facilitate access for the insurance industry to CUE; to enable underwriting decisions to be made by subscribers; validating claim information; verifying facts during a claim investigation; law enforcement to detect suspected cases of fraud; activities relating to the provision or administration of motor insurance policies; the provision of motor vehicle condition history checks (commonly known as "vehicle provenance checks") to trade and general public consumers; and to maintain MIB accounts and records and to promote MIB services and to support and manage MIB employees.

If you're involved in a road traffic accident (either in the United Kingdom, the European Economic Area or certain other territories), insurers and MIB may search the MID for relevant information.

People (including citizens of other countries) making an insurance claim following a road traffic accident (and their appointed representatives) may also get relevant information which is held on the MID. You can find out more about this from us, or at www.mib.org.uk

Marketing

If you have chosen to receive marketing information, we will use your preferred contact method to let you know about:

• Our products and services
• Receive our newsletters

If you would like to change your marketing preferences you can through the My Account area online, by contacting us on 03300 240 123 or by clicking unsubscribe on any of the emails we have sent you.

Renewal

If you choose to cancel your policy with us at renewal, based on the information we hold about you and subject to your consent, we will contact you with an indicative quote in advance of your next renewal date.

International Transfers

We have detailed third parties that we share your information with in the ‘How we share your information’ section. Some of these third parties may be in countries outside of the European Economic Area (EEA).

Under data protection law, when personal information is being transferred outside the EEA, we as data controller, are under an obligation to ensure that such transfers are performed in a manner that ensures that your personal information is adequately protected.

In the event that we transfer your personal information outside of the EEA, we will always put in place adequate safeguards to ensure that your personal information is protected. Adequate safeguards may include placing contractual obligations on the third party that we are transferring your information to or ensuring that the third party is certified to the EU-US Privacy Shield Framework, if we are making transfers to third parties located in the United States.

There may be some circumstances where we will be required to transfer your information outside of the EEA and we will rely on it being necessary for the performance of your insurance contract. For example, claims made abroad where we need to instruct a local supplier so that we can handle your claim.

How long we keep your information for

We only keep your information for as long as is necessary in line with the purposes for which we collected your information. We have set out our general retention periods below however in certain circumstances it will be necessary for us to keep your information for longer, for example when we are required to due to legal obligations or to defend or manage legal claims.

If you get a quote from us but do not take up the policy, we will keep your information for 13 months to support customers returning in the near future and to prevent and detect fraud. If the quote is linked to fraud, we will keep your information for up to 4 years from the expiry date of the quote.

In most cases, we will keep your information for 7 years from the expiry date of the policy or from the settlement/closure of the claim, whichever is the latter. This is applicable if you get a quote from us and you buy the policy, if you have a policy with us, if you make a claim under one of our policies (including if you are a third party claimant) or if you are a witness to an event giving rise to a claim under one of our policies. This is so that we can administer the contract of insurance and handle claims made against the policy.

There are some exceptions to this, for example, we need to keep the information where there has been or is the potential (for example a minor was present at an accident) to have claims from minors and we will hold the data for 21 years and 4 months. This is so that we can handle potential future claims and meet our legal requirements.

If we suspect, detect or investigate fraud or money laundering, information will be held on a case by case basis for up to 7 years.

Your Rights

Under data protection laws, you have the following rights:

• You can submit a request to find out about the information we hold about you.
• You can request some of your personal information to be ported (also known as “data portability”) to yourself or another company.
• You can request that we correct your personal information if it is incorrect or incomplete.
• You can request that we delete your personal information (also known as the “right to erasure” or the “right to be forgotten”).
• You can request that we stop processing your information and only store it (also known as the “right to restrict processing”).
• You can object to the processing of your personal information if we are processing under the “legitimate interest” lawful basis.
• You can object to direct marketing at any point and request to be added to a marketing suppression list to prevent receiving any direct marketing in the future.
• You can request that an automated decision is reviewed by a human.
• If we are relying on consent or explicit consent as our lawful basis, you can withdraw your consent for processing at any time.
• You can complain to the Information Commissioner's Office about our processing of your personal information www.ico.org.uk/concerns. It’s always best if you speak to us first as we always aim to resolve the issue.

In some cases, we will be unable to comply with your request as a result of our own legal or regulatory requirements but we will always respond to your request and if we cannot comply, we will explain why.

If you would like to know more about your rights, you can find out more information on the ICO’s website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights

You can exercise these rights by contacting us.

Website Users

If you submit an enquiry via the ‘Contact us’ section of our website, we will collect information about you including your name, email address, your vehicle details and details relating to your enquiry.

We will use this information only to respond to your enquiry and for no other purpose. If your enquiry relates to our motor insurance, you should read the relevant section of our Privacy Policy for more information about how we use your information.

Web Analytics & Cookies

When you use our website we automatically collect information about your browsing session such as your IP address and the type of device you are using. We also keep track of the pages you view during your visit. We use this information to improve the way our website operates and for system administration purposes.

For more information, please see our Cookie Policy.

Other websites

Our website contains links to other websites. This Privacy Policy only applies to this website and the services and products we provide; when you link to other websites you should read the separate Privacy Policies on those sites.