This privacy notice is issued by Ignite, trading as Mission Underwriting UK Ltd (“we”; “us” and “our”) and relates to our use of personal data (referred to as “data”) concerning living persons.
Do we process personal data?
We may process data from the following categories of persons (collectively “Insurance Contacts”):
- Insured persons, insurance applicants and policyholders (“Insureds”);
- Beneficiaries and other persons named in the insurance policy (“Beneficiaries”);
- Persons filing a claim under an insurance policy (“Claimants”);
- Persons who serve as a witness in light of an insurance claim (“Witness”);
- And any other person who has had dealings with the Insured in respect of the Insured’s financial interest in their insurance policy.
Additionally, we may process data from the following categories of persons other than Insurance Contacts:
- Individuals working for one of our business partners (“Business Contacts”);
- Individuals who otherwise interact with us online or offline, for instance by visiting our offices or filing a general request for information via our website (“General Contacts”); and
- Individuals who use and visit our website (“Website Visitors”).
In each case, we respect your privacy rights and your rights as a data subject. We will manage and protect your data accordingly, whilst it is in our hands, in accordance with all applicable data protection legislation and in accordance with this privacy notice.
Who is the Data Controller?
We are registered with the Information Commissioner’s Office in the UK, as a data controller, under the registration number of Z8883427. We can be contacted at the following address:
Mission UK Underwriters Ltd
One Fleet Place
Who is the Data Protection Officer?
For enquiries relating to how your data is processed, you can contact us at the following address:
How will we use your data?
We will use data in the normal course of business to:
- Administer insurance policies.
- Underwrite insurance policies (including aggregating data with other similar data for actuarial purposes).
- Handle claims on insurance policies for Claimants.
- Deal with any complaints that you may have.
- Verify your identity.
- Confirm with third parties that you have received insurance cover.
- Where we have a legal basis to do so; help us to identify and market products that may be of interest to you.
- Detect and prevent financial crime.
We may use your data, in the course of our business, for the prevention and detection of fraud. Where we suspect fraud, this may entail:
- Sharing your data with public bodies including the Police.
- Undertaking fraud searches.
- Checking your data against fraud prevention databases.
What is the purpose of data processing?
For persons who are Insurance Contacts; we require to process your data in order to arrange and administer a contract of insurance between the Insured and Accelerant Insurance Europe SA (“the Insurer”).
The legal basis for processing your data are as follows:
- Processing data is necessary for the arrangement of the insurance contract between the Insured and the Insurer; and the insurer’s performance of the insurance contract which you will be party to.
- Processing your data is necessary for our compliance with certain legal obligations (such as the detection and prevention of financial crime).
- Processing your data is necessary in pursuit of our and the Insurer’s legitimate interests in arranging the Insured’s insurance contract.
How Did We Receive Your Data?
- If you are an Insured; we will have received your data from an insurance broker arranging insurance either on your behalf or on behalf of an Insurer.
- On occasion, we may also receive/collect your personal data directly from you, such as when you are a Website Visitor or where you are otherwise in direct contact with us. We may also receive your personal data from the following sources:
- Persons and companies you are affiliated with or related to including your family members, employer or representative;
- Credit reference agencies;
- Reinsurance companies and other third-party insurance companies with whom you have, had, are applying for, or have filed a claim under an insurance policy;
- Anti-fraud databases (such as Claims and Underwriting Exchange (CUE) and Motor Insurance Anti-Fraud Theft Register (MIAFTR) databases), sanctions lists, court judgements and other public databases;
- Government agencies (such as the Driver and Vehicle Licensing Agency and HM Revenue and Customs);
- Open electoral registers and other publicly available registers such as company registers; Supervisory, regulatory and other public authorities;
- In the event of a claim, third parties including the other party to the claim (claimant/defendant), witnesses, experts (including medical experts), loss adjustors, external counsel, and claims handlers;
- Service providers such as organisations operating our website; and
- Other public and non-public sources including information that is publicly available online.
What Types of Data Do We Process?
The data we hold may include:
- Contact details
- Professional details (occupation; trade, business or profession)
- Financial details
- Identification details
- Special categories of personal data (where permitted under applicable law).
Will we use Automatic Decision Making or Profiling?
We use a variety of technologies in calculating risk and insurance premiums and to compare insurance risks against industry averages and patterns. This is considered profiling and/or automated decision-making and is necessary to enter into a contract with you – to confirm that the premium amount reflects and adequately matches the associated risk – and/or authorised under applicable law. As a result of these profiling activities, you may be offered a different insurance policy and/or premium, or even be refused insurance.
Profiling may also be used by brokers acting on our behalf to assess information relating to you, to identify and have a good understanding of fraud patterns. Where special categories of personal data are relevant, such as medical history or past criminal convictions for certain types of insurance, such special categories of personal data may also be used for profiling. However in this case we ask for your prior explicit consent unless we can rely on a basis in applicable law to process this data for profiling purposes.
Will Third Parties Receive Your Data? What Are Their Interests?
We share your personal data with other entities within our Group. Employees only have access to and process data where such access and processing is necessary for such employees to perform the tasks and responsibilities allocated to them; with suitable organisational and technical measures being put in place to safeguard this.
We also share your personal data with the following categories of third parties:
- Our service providers (e.g. IT vendors supporting our information security and technology, external counsel and other legal advisors, consultants, auditors, website and data hosting providers, marketing agencies, accountants, etc.);
- Governmental authorities including our supervisory regulatory authorities and law enforcement agencies;
- Business Contacts;
- Contractors, brokers or financial institutions; and
- Other third parties (i) upon your request; (ii) to protect and defend our rights and properties; (iii) to detect and/or prevent fraud or money laundering (including Claims and Underwriting Exchange (CUE) and Motor Insurance anti-fraud theft registers; (iv) in the event of a sale, merger or reorganisation of our assets or other restructuring; and/or (v) where we are, or believe in good faith that we are, under a legal obligation to share your data.
How Long Will We Keep Your Data?
Your data will be retained only for as long as is necessary for us to effectively administer your policy of insurance. This means that your data will be retained until claims under your policy are barred; or as long as is necessary to defend against legal claims; or for as long as is required by law; whichever period is the longest.
What Are Your Rights to the Data?
As a data subject, you have rights with respect to the processing of your personal data under our control as follows:
You may ask us what personal data we process and request copies of such personal data. This is limited to personal data only and does not include commercial data such as underwriting data.
You may ask us to rectify or update personal data that is inaccurate or incomplete.
You may ask us to delete your personal data in certain instances (for example, where the data is no longer necessary for the purpose which it was originally collected or processed; or there is no longer a legitimate interest for us to process the data).
Restriction of processing
Under certain circumstance (such as when you question the accuracy of the personal data we hold on you or the lawfulness of its processing) you may request us to stop processing such data until your request is resolved.
In certain cases, you may ask us to send an electronic copy of your personal data directly to you or to another organisation
You may object to any processing of your personal data, including profiling, based on the ground of legitimate interest.
In circumstances where processing of your data is based on consent; of your personal data is based on your consent – you may at any time withdraw your consent however this will not affect any processing we did before withdrawal (this right only applies where consent was the basis of processing your data in the first instance);
Each of the rights set out above are subject to applicable privacy legislation and is not absolute.
In order to exercise the above listed rights, please contact our Data Protection Officer.
Can a Complaint Be Made?
If you have any complaints about how we process your data; please contact the Data Protection Officer, at the address provided above.
In the event that we are unable to resolve your complaint: You have the right to make a complaint to the Information Commissioner’s Office if you believe that your information has been mishandled by us. The Information Commissioner’s Office can be contacted as follows:
Information Commissioner’s Office
Tel: 0303 123 1113