Controllers of personal information

Trinity Lane Insurance Company Limited is a joint data controller authorised and regulated by the Gibraltar Financial Services Commission (GFSC). The Financial Services and Markets Act 2000 (Gibraltar) Order 2001 allows Trinity Lane Insurance Company Limited to exercise its pass porting rights to provide services in the UK. Consequently, Trinity Lane Insurance Company Limited subscribes to the Association of British Insurers (ABI), the Motor Insurers’ Bureau (MIB) and the Financial Services Compensation Scheme (FSCS). “We”, “Us” and “Our” in this privacy policy refers to Trinity Lane Insurance Company Limited.

We have appointed Adrian Flux Insurance Services as our data protection representative. Please direct data protection queries to [email protected], or Data Protection Officer, Adrian Flux Insurance Services, East Winch Hall, East Winch, King’s Lynn, Norfolk. PE32 1HN.

We reserve the right to amend this privacy policy at any time and without notice in response to changes in data protection laws and privacy legislation.

Your rights

Under the General Data Protection Regulation (GDPR) you have the right to access or obtain copies of the personal information held about you by us.

A response to your request will be provided to you within one month of us receiving a valid request. If you wish to exercise this right against our partners you will need to write to them directly. In accordance with the GDPR, we will not charge for this information in most cases. In the majority of circumstances, this information can be requested by contacting your broker. For security reasons, you must include your full name, address and date of birth when writing to us or your broker.

You have the right to request that we correct any inaccuracies in the personal information held about you. Please contact your broker if your personal information needs updating.

You are also entitled to request the removal of your personal data from our records. To ensure your data is completely removed, the most effective way to request this is by contacting your broker. For security reasons, you must include your full name, address and date of birth when writing to us or your broker. As long as your request meets our data retention periods, then we will overwrite removing your personal and sensitive information, the remaining data will be used for statistical purposes only.

You have a right to submit a complaint to the Information Commissioner in either the UK or Gibraltar if you believe we have not complied with our obligations under the GDPR.

https://ico.org.uk/global/contact-us/

https://www.gra.gi/data-protection/data-protection-complaint-form

You have the right to have your data transmitted directly to another data controller where technically feasible.

You have the right to restrict data processing, where this does not conflict with our contractual obligations, where;

• You contest the accuracy of the personal data we hold
• The processing is unlawful and you oppose the erasure of your data
• We no longer need the data for processing, but the data is required by you for the establishment, exercise or defence of legal claims
• You have objected to the processing of your data pending the verification of whether the legitimate grounds for processing override your objection

You have the right to object to the automated processing of your data including, but not limited to, profiling. This excludes where the processing is necessary for entering into a contract, or the performance of our contractual obligations.

Uses for your data

The data you provide to us will be used by us for the following purposes:

• Quotation: Your data will be used to provide you with the best quote in relation to the insurance services you are requesting a quotation for.
• To assess your insurance risk, verify your identity, to help prevent fraud and to provide you with their best premium. We, or your broker, may obtain information from third parties at quotation and renewal and in certain circumstances where policy amendments are requested. This information includes a quotation search from a credit referencing agency. This search will appear on your credit report and will be visible to other credit providers. It will be clear that this is a quotation rather than a credit application by you to pay by monthly instalments.
• We may use scoring methods to assess this application. This information may also be used for debt tracing and the prevention of money laundering as well as the management of your account. Alternatively, we may ask you to provide physical forms of identification.

Data we collect

We collect personal data and sensitive personal data as part of providing services to you. This data will be collected by your broker and passed to us. We may also monitor or record calls, emails, SMS messages or other communications in accordance with UK and European law.

Types of data we may collect

Personal data

Examples of personal data we may collect includes:

• Name, address, date of birth and gender
• Telephone numbers and email address
• Occupation and other lifestyle information
• Claims history

Sensitive personal data

Examples of sensitive personal data we may collect includes:

• Medical history
• Criminal convictions

Call recording and monitoring

We monitor or record calls, emails, SMS messages or other communications for:

• Business purposes such as quality control and training
• Processing necessary for entering into or performance of a contract
• Prevention of unauthorised use of our telecommunication systems and websites
• Ensuring effective systems operation
• Meeting any legal obligation
• Protecting your vital interests
• Prevention or detection of crime
• The legitimate interests of the data controller

Sharing data

We do not sell your data to third party companies.

We may share your data with selected third parties for:

• Claims handling – in the event of a claim your details may be passed to Hadleigh Claims Management, on the basis of contractual requirement, who we use for claims handling.
• Fraud Prevention – We may check and/or share your details with the police, Fraud Prevention and Detection Agencies, or any authority that requests in order to combat financial crime.
• Motor Insurance Database – Information relating to your insurance policy will passed to the Motor Insurance Database (MID) managed by the Motor Insurers’ Bureau (MIB). MID and the data stored on it may be used by certain statutory and/or authorised bodies including the Police, the DVLA, the DVLNI, the Insurance Fraud Bureau and other bodies permitted by law for purposes not limited to but including:
  • Electronic Licensing o Continuous Insurance Enforcement;
  • Law enforcement (prevention, detection, apprehension and or prosecution of offenders)
  • The provision of government services and or other services aimed at reducing the level and incidence of uninsured driving.

Data Retention Policy

The maximum period of time that we will hold your data for is 10 years.

Requesting documents

Requests for documents will usually be handled by your broker.

Fraud prevention, detection and claims history

In order to prevent and detect fraud we may at any time:

Share information about you with other organisations and public bodies including the Police check and/or file your details with fraud prevention agencies and databases and, if you give us false or inaccurate information and we suspect fraud, we will record this with ourselves, these agencies and databases. We and other organisations may also search these agencies and databases to:

Help make decisions about the provision and administration of insurance, credit and related services for you and members of your household trace debtors or beneficiaries, recover debt, prevent fraud and to manage your accounts or insurance policies check your identity to prevent money laundering.

Undertake credit searches and additional fraud searches. We can supply on request further details of the databases we access or contribute to.

Third-party websites

We cannot be held responsible for the privacy policies and practices of other websites linked to our websites. We do take great care in ensuring only links to companies, organisations and individuals following the same standards and policies as us remain on our website, but we cannot guarantee this. In such instances, you are advised to check the privacy policies on external websites.

Changes to our Privacy Policy

We keep our privacy policy under review, and reserve the right to make changes to our privacy policy in accordance with UK legislation. Where applicable we will make you aware of any significant changes by email, text message or post. We recommend that you make regular checks on our privacy policy to ensure that you are aware of any changes that may have been made. This policy was last updated on 1st July 2020.