Rightpath Insurance Solutions Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our:
- and any individual/group we hold personal data about.
We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below; and “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
2. Information About Us:
Our Site is owned and operated by Rightpath Insurance Solutions Limited registered in England under company number: 6411430, Registered address: New Century House, 17-21 New Century Road, Laindon, SS15 6AG, UK.Data Protection Officer: Matthew Tomkins.
Email address: firstname.lastname@example.org.
Telephone number: 020 8667 1600.
Postal Address: PO Box 6430, Basildon SS14 0QT, UK.
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Data Do We Collect?
- Date of birth;
- Email address;
- Telephone number;
- Business name;
- Job title;
- Payment information;
- Information about your preferences and interests;
- IP address;
- Claims and insurance information;
- Health information.
Your personal data may also be obtained from the following third parties:
- Insurance broker;
- Medical assistance company;
- The agent who sold your policy;
- Third parties related to the claim (e.g. a close relative).
7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
- Assess and administer claims, including requesting your feedback on our performance;
- Your personal details are required in order for us to enter into a contract with you;
- Communicating with you. This may include responding to emails or calls from you.
- Internal record keeping and job applications;
- We may use the information to improve our products and services;
- We will also use information collected to safe-guard against fraud and money laundering. We are required to report details of some suspicious activities to the National Crime Agency (NCA);
We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to request opt-out.
Third Parties including: The Financial Conduct Authority, The Financial Ombudsman Service, The Association of British Insurers, Foreign and Commonwealth Office, UK Passport Office, Australian Health Service, Civil Aviation Authority, The NHS and the Association of British Travel Agents whose content appears on our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use the following automated system for carrying out certain kinds of decision-making AND/OR profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more or to launch an appeal into the decision, using the details in Part 15.
The following automated decision-making methods may be used for processing your personal data:
- Claim assessment decisions, including profiling based on potential fraud indicators
All automated decisions should be made in line with your policy terms and conditions and you have the right to appeal these decisions.
8. How Long Will You Keep My Personal Data?
9. How and Where Do You Store or Transfer My Personal Data?
We may share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguard is applied to such transfers:
- We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the following website: "https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en" European Commission.
- Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the following website: "https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en" European Commission.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including making sure the standard of their data protection is equivalent to ours.
10. Do You Share My Personal Data?
We may sometimes contract with third parties to supply certain products AND/OR services. These may include:
- payment processing
- policy validation
- insurer referrals
- assistance company referrals
- third party claims administrators/investigators
- your doctor
- an independent doctor working on our behalf
- any insurers or government entity we believe may also cover your loss
- cost containments facilties
- National Crime Agency
In some cases, those third parties may require access to some or all of your personal data that we hold. We do not disclose your information to anyone outside Rightpath Insurance Solutions Ltd except:
- where we have your permission; or
- where we are required or permitted to do so by law or by regulatory bodies; or
- to other companies who provide a service to us or you; or
- where it is necessary for the performance of an agreement we have with you; or
- fraud prevention purposes; or
- where we may transfer rights and obligations under this agreement.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by calling us on the number mentioned in Part 15 or on the claims form we send out to you.
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
In most cases we will not be able to assess a claim without you providing us with certain personal data.
You may access certain areas of our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged of £10.00 to cover our administrative costs in responding.
We will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. These Cookies are not integral to the functioning of our Site and your use and experience of our Site will not be impaired by refusing consent to them.
All Cookies used by and on our Site are used in accordance with current Cookie Law.
Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details: For the attention of: The Data Protection Officer
- Email address: email@example.com.
- Telephone number: 020 8667 1600.
- Postal Address: PO Box 6430, Basildon SS14 0QT, UK.