Business privacy notice for General Insurance

How we use personal information

This document explains how LV= collect, use and store personal information relating to potential or actual policyholders, beneficiaries under a policy, their family members, claimants and other parties involved in a claim. When we refer to individuals, this includes any living person whose personal information we receive in connection with the services and products we provide. 

Allianz insurance is a registered trademark of Liverpool Victoria Insurance Company Limited. If you have Allianz Car Insurance, please refer to the Allianz Car Insurance privacy notice here.  

For individuals who we process information about in a professional capacity when working for/as businesses who have a business relationship or transact business with us or provide us with a service (such as brokers, intermediaries, managing general agencies, suppliers and business contacts), please refer to our business to business privacy notice - www.lv.com/insurance/business-privacy-notice 

We want you to be confident about how we use personal information. As a regulated company and data controller, we take the responsibilities for the security and management of personal information seriously. That is why we invest in our systems and processes to make sure the way we collect, use, share, and store the information meets both the regulatory and our own high standards. When we talk about policy, this could include any subscriptions you have with LV=.

 

Who we are and how to contact us

When we refer to “we”, “us” and “our” in this notice it means Liverpool Victoria General Insurance Group (LVGIG), Liverpool Victoria Insurance Company Limited (LVIC) which includes Buddies Enterprises Limited (BEL) trading as ElectriX, and Highway Insurance Company Limited (HICO), who are all part of the Allianz UK Group which includes insurance companies, insurance brokers and other companies owned by the Allianz UK Group. 

Please see link for a detailed list of these companies.

More information can be found at www.lv.com/insurance/about-us 

The data controller of any personal information given to us about you or other people named on the policy, quote or claim is LVGIG. It is your responsibility to let any named person know about who we are and how this information will be processed including who underwrites your policy.
 
If you have any questions about how we process personal information, please get in touch with us by writing to: GI Customer Support, LV=, County Gates, Bournemouth, BH1 2AT or by emailing [email protected] 

You can also contact our Data Protection Officer by writing to: Data Protection Officer, 57 Ladymead, Guildford, Surrey, GU1 1DB, or via email at [email protected] 

 

Personal information rights

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.
You have the right to: 

• access the personal information we hold about you
• correct personal information you think is inaccurate or to update information you think is incomplete
• have personal information deleted in certain circumstances
• restrict us processing personal information, under certain circumstances
• receive personal information in a portable format – this only applies to information you have provided to us
• object to us processing personal information, under certain circumstances

You can also ask us to have a team member review an automated decision.If you want to find out more or to exercise these rights, please let us know by writing to: GI Customer Support, LV=, County Gates, Bournemouth, BH1 2AT or email us at [email protected] 

How we collect, use and share personal information

We only collect information that we need,and have strict controls to keep it safe. We collect personal information to provide our products and services (e.g. handling claims) to you. Without the information we collect, we wouldn’t be able to give you a quote or an insurance policy and it may affect the outcome of any claims you make. Personal information we collect will be held in digital and / or paper files. 

We collect personal information such as name, address, date of birth, occupation, criminal convictions, health, claims history, IP addresses and information about the technology you are using. We’ll also collect information which relates to the things you want to insure (for example your house or vehicles). 

Where applicable, we’ll process special category data which can include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (where used for identification purposes), data concerning health, data concerning a person’s sex life and data concerning a person’s sexual orientation.

Where applicable, we’ll collect data relating to criminal offences, including alleged offences, criminal proceedings, outcomes and sentences (previous criminal convictions, bankruptcies and other financial sanctions such as County Court Judgements)

We collect personal information, including contact details about everybody named on your policy, quote, incident or claim when you:

• provide information for the purposes of attempting or getting a quote 
• apply for a policy and when we prepare your renewal quote
• buy and/or use a product or service
• ask us a question 
• make, inform us of, or we investigate a claim or incident, including anyone associated with that incident
• make a payment
• update personal details
• change cover 
• register a complaint
• take part in market research (e.g. customer satisfaction surveys)
• update marketing preferences 

When you make a claim, we may ask you to provide information about whether you’re vulnerable or experiencing medical symptoms that could affect how or when we attend to your property or vehicle. We do this so we can keep our customers and our suppliers safe.

The personal information we collect will be used by us and third parties who process information on our behalf. This includes reinsurers and organisations who administer your policy or service your claims. We also collect personal information from other Allianz UK Group companies.

We never sell your data to anyone.

Legal grounds for processing personal information

By law, we must have a legal justification to process your personal information for the purposes described in this privacy notice. 

We collect personal information to provide our quotes, products and services to you. We do this to enter into and / or perform the insurance contract with you. This includes arranging, underwriting and managing our products and handling claims in accordance within the terms of the policy.

As a regulated financial services organisation, we’re required to comply with legal and regulatory obligations. This includes meeting responsibilities we have to our regulators, tax officials, law enforcement and any other legal responsibilities we have, such as the prevention, detection and reporting of fraud and other financial crime.

We will process personal information for our legitimate interests, when we have a business reason to do so. This includes but is not limited to:

• developing, improving, and personalising our products, pricing and services
• enhancing our customer service, experience, and relationship (e.g. customer and market research, business analysis, providing relevant product and service information)
• providing a service that keeps our customers and suppliers safe by identifying when they may be vulnerable or experiencing medical symptoms that could affect us attending a vehicle or property
• improving the relevance of our advertising and marketing campaigns and identifying advertisement audiences
• displaying personalised online advertisements on third-party websites and social media platforms
• helping to detect and prevent fraud and financial crime
• developing and improving our administration, security systems and insurance applications
• promoting responsible lending and helping to prevent over-indebtedness
• sharing it with third parties in the event of organisational change (e.g. if we bought or merged with another organisation)
• sharing personal information with other Allianz UK Group companies when you submit an insurance application and/or claims for the purposes of fraud detection and prevention and analysis of marketing data.

If we need consent to process personal information, we’ll ask for this first. This consent can be withdrawn at any time.

We will process special category personal data to protect the vital interests of the customer and which is relevant for emergency medical care when an individual is incapable of giving consent to the processing. 

By law, we only collect and use special category personal data and / or criminal offence personal data where we have an additional specific legal justification to process such information. Where we process this type of information we do so for reasons of substantial public interest, including:

• for insurance purposes of advising on, arranging, underwriting and administering an insurance contract, handling a claim under an insurance contract and complying with rights and obligations in connection with insurance contracts
• for the prevention, detection and reporting of unlawful acts such as fraud and other financial crime 
• safeguarding the economic well-being of certain individuals where we identify additional support required by customers
• keeping under review the equality of treatment of customers with additional support needs

It may also be necessary for us to process special category personal data and / or criminal offence personal data to establish, exercise or defend a legal claim including where we’re faced with legal proceedings, we bring legal proceedings ourselves or where we’re investigating legal proceedings a third party has brought against you.

Third party data

We also collect data in relation to third party claimants, witnesses or other individuals involved in road traffic accidents or incidents with our policyholders. We collect this information for the legitimate interests of our business to investigate and manage claims made under an LV= policy. If we are required to process special category personal information as part of this process, we do so for reasons of substantial public interest, specifically for insurance purposes of advising on, arranging, underwriting and administering an insurance contract, handling a claim under an insurance contract and complying with rights and obligations in connection with insurance contracts.

Bank account and payment card details

We use a secure payment processor for all card payments. When a payment is processed, we share the details of the payer, such as the cardholder name and billing address, with the processor. We also share with them contact details provided by you so your bank can authenticate the transaction and help protect you against fraud. In response, we receive a unique transaction code and an extract of your card number, which we store as a record of the transaction.

You can choose to renew your insurance automatically using these card details – just let us know when you buy your policy. You can change this at any time.

You can also choose to use these card details again, if you make any changes to the policy.

If you pay by monthly instalments, we’ll process your bank account details so we can set up a direct debit with you.

Automated decision making and profiling 

We use the personal information you provide us, information we already hold about you, information about you provided by third parties and information about the risk of insuring you to inform our business decisions (e.g. product design, pricing, customer journeys or marketing strategy). We use profiling and automated decision making to help determine the prices, policy terms, relevant products/services, when you research or ask for a quote, buy insurance, make any changes, renew or make a claim.

When you ask for a quote, we’ll use an automated underwriting engine that takes account of the information you provide on your quote. We may also validate information you provide against other records we hold about you in our systems and third-party databases, including public databases. We take account of all of the information available to us to help determine the likelihood of a claim being made, how much it might cost and we use that assessment to decide whether or not to offer insurance, the price of the policy and whether we can offer the option to pay monthly.

When you have a policy with us, we’ll use an automated underwriting engine so we can offer you a renewal quote.  We may use your information to perform analytics and make sure we’re pricing our products appropriately. If you need to make a claim under a policy, we use automated systems to help manage and settle the claim.  We take account of the information we hold about you, details of the policy and details of the claim. We may also validate the claim against third-party databases, including public databases.  We use the information to determine the cost of the claim and how to settle the claim such as repairing, replacing or providing cash settlement.

To help us prevent and detect crime, we evaluate and predict whether your conduct accessing our products or services suggests a risk of fraud. You may automatically be considered to pose a fraud or money laundering risk if our processing of your personal information:

• reveals your behaviour to be consistent with that of known fraudsters or money launderers;
• is inconsistent with your previous submissions;
• reveals that you appear to have deliberately hidden your true identity. 

This activity is essential to allow us to decide whether there’s a risk of fraud, which may result in us refusing to offer you insurance or accepting your claim.
If you’ve chosen to receive marketing information from us, profiling and automated decision making will be used to make our marketing more relevant, e.g. personalising the channels used to market to you, the marketing messages you receive and the offers you’re sent.

Where we make an automated decision that has a legal or substantially similar effect, you may request a team member to review that decision. We’ll consider your comments and assess whether the decision was made correctly.

Multiple policies at the same address

We may provide a discount if there’s more than one policy at the same address. This could result in anyone at the address who has a policy or quote with us being made aware that someone else living at the address also has insurance with us.

International transfers

In the event that we process personal information outside the UK, the processing in those locations is protected by UK and European data standards.

If the information you provide to us is transferred to countries outside the UK and the European Economic Area (EEA) by us or our suppliers, steps will be taken to make sure appropriate security measures are in place with the aim of ensuring your privacy rights continue to be protected.

Where your claim occurs abroad, we’ll also send data to the necessary service providers and agencies as required to service your claim.

The Industry Databases and Institutions we check and exchange information with

Financial crime and fraud prevention agencies

The personal information, about any customer or third party or representative, we have collected will be shared with crime and fraud prevention agencies, including their members, law enforcement and other relevant organisations. LV= and these organisations use various techniques to assess and validate claims and will use personal information to prevent financial crime and fraud and to verify your identity. If financial crime or fraud is detected, you could be refused certain services, finance or employment. Where we suspect financial crime or fraud through information obtained as a result of our investigations, we may cancel any policies you may have with us, retain any premiums paid, be unable to pay any claim or offer you the requested product or service. 

Regulatory bodies

Personal information will be used or disclosed as required to regulators, for example the Financial Conduct Authority (FCA), The Prudential Regulation Authority (PRA), Information Commissioner’s Office (ICO) and Financial Ombudsman Service (FOS), to monitor and enforce our compliance with any regulation. 

Claims and Underwriting Exchange and other databases

You must tell us about any claim or incident, even if it wasn’t your fault.  We’ll search databases such as the Claims and Underwriting Exchange (CUE), Motor Insurance Anti-Fraud and Theft Register, No Claims Discount (NCD) database and all DVLA databases when you apply for insurance, make a claim or renew your policy, to validate your no claim discount and claims history (or that of any other person or property likely to be involved in the insurance or claim). We also search and share personal information onto industry fraud databases, such as the Insurance Fraud Register.

We will share personal information such as claim or incident details including dates, costs, fault status, any impact to no claim discount (NCD) and if any personal injury has occurred. The table below details the ways we share personal information for the policyholder and/or other people named on the policy, quote or involved in any claim.