At Autoline, we want you to know that when you use our organisation you can trust us with your information. We are determined to do nothing that would infringe your rights or undermine your trust. This Privacy Notice describes the information we collect about you, how it is used and shared, and your rights regarding it.
1.Data Controller - We are registered with the Information Commissioner’s Office (ICO) as a Data Controller for the personal data that we hold and process. Our registered address is Unit 2, Ashtree Business Park, Rathfriland Road, Newry. Co.Down. BT34 1BY our registration number is NI20828 , and our Data Protection Lead (DPL) is Julie Gibbons. Our Data Protection Lead can be contacted at Julie[DOT]gibbons[AT]autoline[DOT]co[DOT]uk.
2.Data Collection - The vast majority of information that we hold about you is provided to us by yourself, a named policyholder or someone you have authorised to supply personal data on your behalf when seeking to use our services. We will tell you why we need the information and how we will use it. If you are providing information relating to other individuals you should ensure that those individuals are aware that we will use their details for the purposes outlined in this Privacy Notice and direct them to this Privacy Notice for information.
3.Call Recording - We record all calls and monitor them for training, regulatory compliance, quality control and verification of information purposes. Calls may be supplied to insurers and relevant third parties for the purposes of addressing complaints, managing claims and the detection/prevention of fraud.
4.Our Lawful Basis for processing your information - The General Data Protection Regulation (GDPR) requires all organisations that process personal data to have a Lawful Basis for doing so. If you are unable to provide the required information we may not be able to offer you insurance or continue with cover.
The Lawful Basis identified in the GDPR are:
- Consent of the data subject
- Performance of a contract with the data subject or to take steps to enter into a contract
- Compliance with a legal obligation
- To protect the vital interests of a data subject or another person
- Performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
- The legitimate interests of ourselves, or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.
At Autoline, our Lawful Basis is to ensure that you we can provide you with insurance cover that meets your needs by searching our panel of insurance experts and advise you on the most appropriate cover to fit your requirements as well as the following additional lawful purposes:
- Provide you with quotations for insurance products via our insurer panel;
- Provide you with appropriate insurance cover for the products you have quoted for;
- Process payments for your insurance cover;
- Liaise with other insurance companies in order to request/obtain proof of no claims bonus and verify your insurance history;
- Service your existing policies and maintain our records including the handling of claims you may have on your policy;
- Provide you with renewal terms;
- Maintain the security and integrity of our insurance products;
- Direct your enquiries to the appropriate customer service staff;
- Investigate and address your concerns;
- Investigate or address legal proceedings relating to your use of our insurance products, or as otherwise allowed by applicable law;
- Reporting possible criminal acts or threats to public security;
- Fraud prevention.
For our Telematics product (Chillidrive app), personal data is used to:
- Collect GPS location information every second during an active journey using the GPS sensor in your phone.
- Record Raw Trip Data which consists of the date and time for each one second GPS data point as well as a measurement of the GPS Horizontal Precision at that point in time.
- Raw Trip data is anonymised and retained indefinitely and may be used by our Telematics provider and their associated partners for the purposes of improving systems, general analysis or generating new aggregate data sets.
- Process Raw Trip Data with a Telematics algorithm (software program) to generate Driver Scores and text / graphical feedback.
- We may use your Raw Trip Data and Driver Scores and other policy and product interactions to inform a gamification and rewards which may result in us issuing vouchers or virtual badges or other benefits.
- Compare your acceleration events against others who have used the system and generate driver scores based on how you compare with the other reference drivers.
- Compare your speed against a database of legal speed limits throughout the journey and generates a speeding score based on how much of your driving is within the legal speed limits.
- We may use your Driver Scores, Raw Trip Data or speeding related incidents, to influence aspects of your insurance policy or influence offers from us for other insurance policies. This may include changing the deductible (excess), offering you a discount, or in extreme cases withdrawing insurance cover.
- Capture photographs of certain documents and items that may be associated with your policy or potential insurance product purchase.
- Collect a GPS location fix for each photograph taken by the app including a date and time stamp.
- Process each photograph taken on our platform and electronically read and store the text within the photographs which may include a vehicle number plate or name, DOB and address information from a photo of a driving licence.
- Automatically identify or compare faces in an uploaded photograph against other documents provided.
5.Our Legitimate Interests for processing your information - At Autoline our Legitimate Interest is to ensure you are kept fully informed and updated on your policy cover and associated insurance procedures which may be required. Additional legitimate interests include:
- Communication with you regarding other insurance products and services, promotions, studies, surveys, news, updates and events that may be of interest to you;
- Transmission within Autoline of undertakings for internal administrative purposes;
- Process promotions/competitions, including prizes, and send you information about our products and services and those of our business partners;
- Contact with you once your policy lapses to offer insurance products and services that might be of interest;
- The carrying out of data analysis and testing, market research, statistical analysis including customer profiling for the purposes of analysing usage and activity trends as well as improving our services and product offering;
- The provision of information to your insurer, financial provider or other 3rd party with an interest in your policy for the purposes of quality control, auditing, concerns, fraud prevention and claims processing;
- The undertaking of staff training.
6.Personal and Sensitive Data - When providing you with an insurance quote or discussing your insurance requirements, we will need to ask you for personal information which may consist of:
- Name, Address, Date of Birth, Email Address and Mobile Number
- Occupation, Driving History and Previous Claims Experience
- Details of the risk to be covered by the policy
- Payment details, payment history and details of any credit agreements and any debt management processes
Where it is necessary for the performance of the contract, we may require you to supply sensitive information relating to health, motoring offences and any convictions.
7.Data Transfer to Third Parties - We may share your personal data with:
- Insurance Agents and Companies (including their associated companies and agents and other bodies appointed by the insurer including surveyors, loss adjustors, engineers, vehicle repairers) for the purposes of arranging insurance cover, auditing and quality monitoring, claims handling, concerns and fraud investigations;
- Telematics suppliers for the provision of telematics-based insurance policies;
- Claims handlers, investigators and adjustors appointed to manage a claim made by you or against you;
- Our business partners and service providers (including professional advisors, IT and security providers, research providers) to assist us in carrying out business activities connected with your policy and administering your policy;
- Our subsidiaries;
- The general public when you contribute to a public forum;
- The Financial Ombudsman Service and our legal advisors in the event of a compliant/dispute or other legal matter;
- Law enforcement agencies, statutory bodies, public and government authorities, or other third parties to meet our legal obligations;
- Any other company or advisors in connection with, or during negotiations of, any merger, sale of company [assets, consolidation or restructuring, financing, refinancing, or acquisition of some or all of our business by another company;
- Any other party where we ask you and you consent to the sharing of your data;
- Credit reference agencies to verify your identity, prevent fraud or to determine the most appropriate payment option;
- Companies that carry out sanction checks, anti-money laundering and anti-fraud controls;
- Finance providers if you agree to pay via Direct Debit;
8.Data Transfer Overseas - We transfer personal data with various third-party service providers for the purposes described in this Notice. Some of these providers are based outside of the EU and may not be subject to the laws of the UK. We have taken reasonable steps to ensure your personal data is treated securely in accordance with this Privacy Notice by sharing a Data Sharing Agreement with each of our overseas providers. We have satisfied ourselves that such transferred data is protected and safeguarded as required by the General Data Protection Regulation.
9.Data Retention - We will only hold your personal data as long as we are required to in law and by our regulators.
- Validate users;
- Remember user preferences and settings;
- Determine frequency of accessing our content;
- Measure the effectiveness of advertising campaigns; and
- Analyse site visits and trends.
12.Your Rights - The General Data Protection Regulation gives you specific rights around your personal data including:
- You have the right to be informed about the information we hold about you and what we use it for and you can ask us for a copy of this
- You can ask us to correct any inaccuracies with the personal data we hold
- In some circumstances, you can ask us to stop processing your details and erase your data.
We will delete or anonymise your information at your request unless:
- There is an unresolved issue, such as claim or dispute;
- We are legally required to; or
- The Financial Conduct Authority (FCA), our regulator requires us to hold your information for a time period stipulated in our Data Retention Policy;
- There are overriding legitimate business interests, including but not limited to fraud prevention and protecting customers' safety and security.
A response to your request will be provided to you within one month of us receiving a valid request. Where we hold or process your data on the basis of your consent, you have the right to withdraw this at any time. We will occasionally update our Privacy Notice. When we make significant changes, we will notify you by email. We will also publish the updated Notice on our websites. To request access to, correction of, or a copy of your information, please contact our Data Protection Lead by emailing firstname.lastname@example.org or by writing to Julie Gibbons, Autoline Insurance Group, Unit 2 Ashtree Business Park, Rathfriland Road, Newry, Co.Down. BT34 1BY.
13.Complaints - If we do something irregular or improper with your personal data you can seek compensation for any distress you are caused or loss you have incurred. You can find out more information from the ICO’s website and this is the organisation that you can complain to if you are unhappy with how we deal with you. You can contact them by calling their helpline 0303 123 1113 or by visiting this link: https://ico.org.uk/make-a-complaint/