Privacy and cookies
1 What is this notice?
We take your privacy seriously and are committed to ensuring that our website is secure for you to use. This privacy notice (Notice) sets out how we will collect, use and share your personal information and explains your data protection rights and how to contact us. If you would like to receive this Notice in an alternative format such as large print, audio or braille, please let us know.
In this Notice, references to you or your shall mean you as a website user of www.co-opinsurance.co.uk (our website) and/or a customer or prospective customer of our insurance products (Insurance Products). If you purchase one of our Insurance Products, this Notice should be read with your policy documents. If you would like further information about how your personal information is collected, used and shared for each of our Insurance Products, please follow the relevant links on each product page on our website.
2 Who are we?
We are CIS General Insurance Limited (CISGIL) trading as Co-op Insurance and Co-op Insurance Services Limited (CISL) trading as Co-op Insurance Services (both are part of the Co-op Group) and are both classed as "data controllers" of your personal information. CISGIL provides you with our Motor (including Ecoinsurance), Home and Young Driver Insurance Products and CISL promotes our Co-op branded Pet and Travel Insurance Products.
Both CISGIL and CISL's registered office address is at CIS Building, Miller Street, Manchester M60 0AL. When we use terms such as we, us and our in this Notice, we mean both CISGIL and CISL.
We have appointed a Data Protection Officer (DPO) to oversee our handling of personal information. Our DPO can be contacted by email at [email protected], by letter to Data Protection Officer, Co-op Insurance, CIS Building, Miller Street, Manchester M60 OAL.
3 Who do we collect personal information about?
We collect personal information about:
- current and prospective customers;
- current members;
- current and prospective parties covered under our Insurance Products;
- users of our website;
- third party claimants;
- witnesses to accidents or incidents; and
- experts instructed in relation to any insurance claims.
4 How do we collect personal information?
We collect your personal information from:
- you directly (this includes when you use our website);
- someone else acting on your behalf who gives us the information directly;
- other Co-op Group companies such as Food, Funeralcare and Co-op Legal Services;
- third party partners who underwrite and administer some of our Insurance Products such as Allianz Insurance plc for our Pet Insurance Product;
- publically available sources such as social media and the electoral register;
- fraud prevention and detection agencies, organisations and databases;
- government and law enforcement agencies; and
If you are applying for one of our Insurance Products jointly with somebody else, you must ensure that you have permission from the other party before:
- sharing information about them to us; and
- authorising us to search, link or record information at credit reference agencies about them.
5 What kinds of personal information do we collect?
We collect and retain your personal information when you visit our website, complete an application for an Insurance Product, renew your policy, make a claim and/or complaint and when you contact us. The personal information that we collect will depend on your relationship with us and whether, for example, you are a policyholder, covered party, website user, third party claimant or other third party.
We may collect certain information such as your name, gender, marital status, address, email address, contact telephone number, internet protocol address and bank account details. We may ask for additional information for some of our Insurance Products such as vehicle registration number for motor insurance products, as well as personal information which the data protection laws define as special categories of data, such as medical history and information that relates to criminal convictions.
6 How do we use your personal information?
We may use your personal information (and any personal information relating to joint policyholders or covered parties):
- to provide you with an Insurance Product (including providing you with a quotation for insurance, issuing and servicing your Insurance Product, sending you a renewal offer and handling any claims and/or complaints made by you) on the basis that processing is necessary to perform our contract with you;
- to run checks for identification, creditworthiness and price setting against databases such as our Co-op Group membership database which contains information about members and how they use their Co-op Group membership cards, the electoral register and other databases which contain publicly available information about County Court Judgments, bankruptcy and repossessions;
- to manage your policy on the basis that processing is necessary to provide your Insurance Product;
- to ask for your feedback, assess customer service and satisfaction and to improve overall operations;
- to communicate with you and resolve any complaints that you may have;
- to assess risk and set prices;
- to develop and test new services and products for you;
- to carry out research and analysis about our products and services, for example when we are launching a new product;
- to help set our financial reserves;
- to prevent and detect fraud and crime;
- to communicate with you, where you have consented to receive communications or by sending you information about similar Co-op Group products or services which we think may be of interest to you. We will not send you marketing communications if you have opted out to receive marketing. You will be able to opt-out of such communications at any time by contacting us using the details at section 19 of this Notice;
- to validate your information (and, in some cases, match it against information that has been collected by a third party) to check that the information we hold about you is accurate, consistent and up-to-date;
- to comply with our legal obligations;
- to make automated decisions, including profiling which helps us to develop an understanding of your activities, preferences and requirements;
- to help us improve our service and our communications to you, for example to find out when your insurance may be due for renewal so that we can contact you at the appropriate time;
- to send to you Co-op Group membership offers, where appropriate;
- to help us assess customer satisfaction and improve the service of our third party partners who we may refer you to and who will provide us with details of any complaints that you make to them about their services;
- where applicable, to fulfil Co-op Group membership requirements in relation to our Co-op Group membership scheme; and
- to decide how much risk to keep and how much risk we should pass to another insurer.
7 What is our legal basis for using your personal information?
We will only use your personal information where it is permitted by law and where:
- we need to use your personal information to perform a contract with you;
- we need to use your personal information to comply with our legal or regulatory obligations;
- you have given us consent to use your personal information (if consent is needed); and
- it is reasonable for us to do so and there is no disadvantage to you or risk to your personal information.
8 Who do we share your personal information with?
We will only share your personal information with:
- service providers who assist us to manage your Insurance Product;
- third party partners who process and store your personal information on our behalf;
- social media companies and our advertising partners;
- professional advisors;
- individuals who you nominate as referees to verify certain information;
- credit reference agencies and providers of credit services;
- crime and fraud prevention agencies and organisations;
- law enforcement, taxation and legal authorities;
- claims handling agencies;
- debt recovery agencies; and
- any member of the Co-op Group, which means Co-operative Group Limited and other companies which may be added to the Co-op Group from time to time.
We may also share your personal information with third parties in the event that:
our business or substantially all of its assets are acquired by a third party;
- we are under a duty to disclose or share your personal information to comply with our legal obligations;
- we must enforce any contract with you; or
- we must protect our rights, property or the safety of our employees, members, customers or others.
In sharing your personal information, we will ensure that your information is properly protected and used in accordance with this Notice.
9 Will we transfer your personal information outside the UK?
We may need to transfer your personal information outside the UK to countries where data protection laws may not provide the same level of protection as those in the European Economic Area. We shall ensure that any such transfers are lawful and that your personal information is kept secure.
10 What do credit reference and fraud prevention agencies do with your personal information?
If you decide to purchase our Ecoinsurance, Motor or Young Driver Insurance Product, we will contact credit reference agencies to obtain your credit score to allow us to calculate the price and the underwriting of your Motor Insurance Product. We will do this when you are asking for a new quotation and also when you are renewing an existing policy. Your credit score will only be used by us and we will obtain the information in a way that does not have a negative impact on your credit record or your future ability to obtain credit. The same credit score will be used for any changes made to your Motor Insurance Product during its term until your Motor Insurance Product's next renewal date.
If you choose to pay for any of our Insurance Products by direct debit, a credit reference agency, such as Experian, will carry out a check of your credit record to find out details of your personal credit history. This check will help us decide whether or not to offer you credit terms and will be recorded on your credit record. We may also pass to credit reference agencies information held about you and your payment record with us. Credit reference agencies share information with other organisations, enabling applications for financial products to be assessed or to assist the tracing of debtors, or to prevent fraud or other crimes. For further information about the use of your personal information by credit reference agencies, please visit www.experian.co.uk/crain.
The personal information we have collected from you will be shared with fraud prevention agencies such as CIFAS who will use it to prevent fraud and money-laundering and to verify your identity. If a fraud risk is detected, you could be refused our Insurance Products.
You have a legal right to obtain details of those credit reference and fraud prevention agencies from whom we obtain and to whom we pass information about you. You also have a right to further details explaining how the personal information held by fraud prevention agencies may be used. For further information about the use of your personal information by credit reference and fraud prevention agencies, please contact us using the details at section 19 of this Notice.
11 How long will we keep your personal information for?
As a principle, we only keep your personal information for as long as it is needed for each of the purposes we have identified above. Usually, we will retain your information for up to seven years, unless there is an exceptional business purpose in which case this time period needs to be extended. If you would like further information about our retention procedures, please contact us using the details at section 19 of this Notice.
12 What are your rights?
Data protection laws give you a number of rights as set out below. If you would like to exercise any of your rights, please contact us using the details at section 19 of this Notice.
Right to access your personal information: you may request access to a copy of your personal information. Please send all requests for access to us in writing.
Right to withdraw consent: if you have given us consent to use your personal information to send you marketing, you can withdraw your consent at any time.
Right to rectification: you may ask us to rectify any inaccurate information we hold about you. If you would like to update the personal information we hold about you, please contact us.
Right to erasure: you may ask us to delete your personal information. If you would like us to delete the personal information we hold about you, please contact us, specifying why you would like us to delete your personal information.
Right to portability: you may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable format, or ask for us to send such personal information to another data controller.
Right to restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
Right to object: you may object to our processing of your personal information pursuant to this Notice. Please contact us, providing details of your objection.
Right to make a complaint: you may make a complaint about our data processing activities by contacting us using the details at section 19 of this Notice. Alternatively, you may make a complaint to the UK supervisory authority, which is the Information Commissioner's Office, by visiting their website at www.ico.org.uk, by phoning 0303 123 1113 (local rate) / 01625 545 745 (national rate), or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Please note that in some cases:
- we may not be able to comply with your request (for example, we might not be able to delete your personal information) for reasons such as our own obligations to comply with other legal or regulatory requirements. We will always respond to any request you make and if we cannot comply with your request, we will tell you why; and
- exercising some of these rights (including the right of erasure, the right of restriction and the right to withdraw consent) will mean we are unable to continue providing you with cover under an Insurance Product and may therefore result in cancellation of your Insurance Product. You will therefore lose the right to bring any claim or receive any benefit under that Insurance Product, including in relation to any event that occurred before you exercised your right of erasure, if our ability to handle the claim has been prejudiced. Your policy documents will set out what will happen in the event that your Insurance Product is cancelled.
13 Your responsibility to provide us with accurate information
It is your responsibility to provide us with accurate and complete information as it may affect your Insurance Product with us. If you do not do so, it could result in us increasing the price of your Insurance Product, rejecting your quotation or claim, reducing any claim settlement payment and/or your Insurance Product being cancelled or made void (treated as though it never existed).
14 Do we use automated decision-making?
Sometimes we use your personal information in automated processes to make decisions about you, such as whether or not to offer insurance. We might also use automated processes to create a profile of you. We do this to help ensure decisions are made accurately, fairly and efficiently. For more information about how we use automated decision-making, please contact us using the details at section 19 of this Notice.
15 How will we keep your personal information secure?
We will treat all of your personal information in strict confidence and we will take all reasonable steps to keep your personal information secure once it has been transferred to our systems. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information. Please note that we cannot guarantee the security of any data you disclose to us online. You accept the inherent security risks of providing personal information and dealing online and will not hold us responsible for any loss or damage that you incur.
16 Links to other websites
Please note that our website may include links to other websites, not owned, associated or managed by us. Whilst we try our best to only link to reputable websites we cannot be held responsible for the security of information collected by sites not managed by us, nor can we accept responsibility or liability for them. We would recommend that you read the privacy information of the third party before using their website.
17 Use of our social media sites
For information about using our social media sites please click here.
18 Changes to this notice
We may modify this Notice from time to time, so please review it regularly. We will let you know when we make any material changes to the Notice by means of notice on our website or if appropriate, by contacting you directly. This Notice was last amended on 10 May 2018.
19 How can we be contacted?
If you have any queries relating to this Notice or our use of your personal information or wish to exercise any of your data protection rights, please contact our Data Protection Officer by email at [email protected] or by letter to Data Protection Officer, Co-op Insurance, CIS Building, Miller Street, Manchester M60 0AL. Alternatively, please call our Operations team on 03457 46 46 46. Please note that calls may be monitored or recorded.
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