How does Islands use your information?
This policy explains how, when and why we collect your personal information during the course of providing services to you, under what circumstances we may disclose your personal information within our Group of Companies and to others, and how we keep it secure.
- We only collect personal information about you where it is completely necessary or you have consented, and we ensure that we only collect information that we need
- We will not send you marketing material unless you have given us permission to do so
- We will not sell your personal information to third parties
- We use third party suppliers to help us provide an excellent service to you. Where we share personal information with those suppliers, we have the appropriate contracts or controls in place, which will assess the security of their processing arrangements
- We will protect your personal information with an appropriate combination of technical and organisational measures
- We record and monitor our communications with you to protect you and us, for the reasons listed in Section 2
- You have rights to your information. These are detailed in Section 11
- We will endeavour not to keep your personal information for longer than we have to
- If you have a complaint, please see how to contact us in Section 13
- If you have any questions about how we process your information, please see how to contact us in Section 15
1. What information do we collect about you?
We need information about you to create your policy, service your policy and to offer our range of services. We need to collect information from you to do this and to offer you the right product for your circumstances.
This can include personal information about you and other people you may want included on a policy, information that we collect automatically, and personal information we collect from other sources. The information we collect will include:
- Name (s)
- Contact details (postal address, email address, telephone numbers)
- Date of birth
- Banking, Credit/Debit card details.
Where necessary, we may also collect the following information:
- Country of Birth/Citizenship/Nationality/Country of Residence
- Marital Status
- Information about Family/Household/Dependants
- Criminal convictions
- Health Information
- Claims history
- Vehicle ownership
- Asset ownership
- Employment status
- Financial status including CCJs and declarations of bankruptcy
- Previous claims.
Finally, depending on the type of policy, we may also require the following information:
- Motor Insurance
- Personal Insurance
- Commercial Insurance
A Motor policy requires us to collect the personal information listed and further information about you and anyone to be covered by the policy or authorised to act on your behalf.
This includes the type of license you hold and for how long you have held it, any penalty points or motoring offences, any medical conditions which must be declared to the relevant Driver and Vehicle Licensing Authority. We need this information to effectively price your premiums.
A Personal policy requires us to collect the personal information listed and additional information about you and any other people to be covered by the policy, such as information about your lifestyles and employment status, your home and any assets to be insured.
A Commercial policy requires us to collect some of the personal information listed and additional information about the Company’s directors and employees, as well as business contact details.
If your business is under your name and located at your home address, by default the information we collect will be personal to you.
2. Why we use the information about you
We collect your personal information for a number of reasons; so we can provide you with a quote, administer your policies, handle claims, protect us and you from fraud, improve the products and services we offer, and inform you of other products you may be interested in.
To process your information we rely mainly on the following legal bases:
Performance of a contract:
The use of your information is necessary to perform the contract that you, or a person covered on the policy, has with us.
We may rely on your consent to use your personal information for certain products or to assist in a claim, and also for direct marketing purposes. You may withdraw your consent at any time, please contact us using the detail provided at the end of this policy.
We may use your information for our legitimate interests, such as to provide you with the most suitable policy, website experience, emails or newsletters, or to improve and promote our products and services, along with administrative, fraud prevention and detection and legal purposes. These include:
- Acting as an insurance intermediary in arranging insurance contracts and fulfilment of those contracts including claims servicing and settlement
- The prevention and detection of fraud and financial crime
- Public safety and crime prevention
- The provision of instalment payment facilities
- Complying with international sanctions
- Combatting money laundering and terrorist financing
3. How will we use the information about you?
We use the personal information we collect for a number of reasons. These include:
- To give an appropriate assessment of the risk you’re hoping to have insured. We evaluate the risk and assess how much coverage may be available from different suppliers and assist you in deciding which policy to arrange
- To give you advice and guidance
- To service your policy and any claims you make
- Where necessary, we’ll use your information to verify your identity or those transacting on the policy
- For fraud and financial crime prevention and detection, and for legal purposes where we may need to use your information to investigate or respond to legal disputes, regulatory investigations or for compliance purposes
- We may also use your personal information to ensure we comply with legal and regulatory requirements. This includes internal audits, monitoring and assurance activities to examine and evaluate the systems and controls within Islands Insurance. Wherever possible we will minimise the amount of personal data used
- When you call us, we record calls for quality control and training purposes. How long we keep recordings depends on our retention policy (see Section 12), unless Islands Insurance has a legitimate interest to keep recordings longer (as reasonably necessary), including for fraud detection and financial crime investigation purposes. Additionally we record calls to:
- Ensure that we have correctly followed your instructions
- Resolve any queries, issues or disputes
- Help us understand how we could improve customer service
- Respond to regulatory queries
- Help our Fraud Prevention team with detection or prevention of fraud or other crimes
- Assist with staff training and improve our customer experience
- We also use your information to help us improve our products and services, our prices and our customer experience through analytics, reporting and testing
- We may use your information to contact you if we need to tell you there is an error or change in your policy
- We use credit reference agencies, to help us decide whether to offer insurance policies or services to potential customers. For more details, see Section 5.
- For general communications or product performance and industry insights and news
- Your data will be combined with publicly available information and third party market research to enable us to understand your lifestyle segmentation, demographics and purchasing habits
- We sometimes ask our customers to take part in market research. Any additional personal details that you give us as part of the market research will be used only with your consent.
- If you give us permission, we will collect information from you about your experience with Islands Insurance to use as a case study. You will be provided with a copy of this article and will have the right to confirm you are happy with any wording before it is published. This information may be circulated in one of our publications, or shared with the press. It may include:
- Names and titles
- Details about your claim.
Life Products And Services
In addition to the above, we may also use your information to share your data with third party tracing service providers, where appropriate, if we are unable to contact you, or to check if you have passed away.
4. Information that we share
We may have to share your information with other companies in the Group, or to categories of third party service providers, including insurance partners and brokers, in certain circumstances:
- Where we need to arrange an insurance policy, we will share the necessary information you have provided to us with other suppliers of insurance or specialist insurance intermediaries. If you would like to know how these other insurers process your information, please contact us.
- To enable our corporate customers to understand the volumes and types of claims made against their insurance policies, we may share information relating to your claim against such a policy with these organisations, or brokers acting on their behalf
- Where we need to service your policy and handle a claim against it, we will use third party lawyers, loss adjusters, fraud specialists, subject matter experts and repairers where appropriate
- Where required by law, we will share your information with third parties such as law enforcement agencies and regulatory or Government bodies. Failing to do so could result in fines or sanctions for Islands Insurance.
- We use other insurance companies to insure Islands Insurance as a business. Where required, we will share the necessary personal information with these insurers.
- There are some instances where we need to share your information with third parties to help us detect and prevent criminal or fraudulent activities
- Where fulfilling our contractual obligations to you requires it, we will share your information with third parties. For example, to follow up on engineering inspections or survey findings
- We may share your information with third parties where they provide parts of your policy cover to ensure your policy can be serviced and honoured. For example, where you have opted for breakdown cover, we will share your information with our breakdown partners
- We will share your information with third party IT providers who support us in hosting, transferring, processing, testing and problem resolving. This enables us to provide you the services and products you need. We may also share information with third party audit companies providing expertise and assurance over our processes and controls
- We may also share your information with third parties in relation to other activities, such as training that we carry out
- In order to deliver you policy documentation and marketing campaigns, we will share your information with third party printers, distributers, and courier services
- If you enter one of our social media competitions, or contact Islands Insurance through social media, your information will be shared with our social media management platform providers.
- We may also share your information with third party organisations who help us to research and analyse our product and service offerings, so that we can continue to provide you with the best possible service. You may opt out of this by contacting us using the details provided at the end of this policy
In addition to those listed above, Islands may need to share information with the following categories of suppliers for handling a claim:
- Motor Claims
- Commercial Claims
- Loss adjusters
- Lawyers and legal cost negotiators
- Special investigators
- Breakdown and recovery companies
- Hire Car providers
- Vehicle repairers
- Windscreen repair companies
- Salvage companies
- Rehabilitation specialists and medical professionals.
- Loss adjusters
- Lawyers and legal cost negotiators
- Special investigators
- Out of Hours and Overseas emergency claims helplines
- Breakdown and recovery companies
- Hire Car providers
- Windscreen repair companies
- Salvage companies
- Disaster restoration experts
- Rehabilitation specialists and medical professionals
5. How we use Credit Reference Agencies
A credit reference agency (CRA) is an independent organisation that assists insurance companies in deciding whether to offer insurance policies to potential customers, based on information gathered about them from public sources and from major lending companies.
Islands Insurance provides information to credit reference agencies and works with them to make decisions, for example, when:
- Checking details on applications for credit and credit-related or other facilities
- Managing credit and credit-related accounts or facilities
- Recovering debt
- Checking details on proposals and claims for all types of insurance
- Checking details of job applicants and employees
- Helping to detect and prevent crime, fraud and money laundering
- Checking your credit history
- Verifying your identity if you, or someone financially linked with you, applies for services
- Credit checks may remain on your record
- Tracing your whereabouts
- Undertaking research, statistical analysis and systems testing.
We would like to send you information about our products and services and other companies in our Group which may be of interest to you. We will collect your information for marketing purposes, if you agree, when you obtain a quote, take out a policy with us, enter into a competition or provide your personal information through the Islands Insurance website. We may also purchase your data from third-party providers.
To ensure that we keep our marketing communications relevant and useful to you, we will share your data with carefully selected third party marketing analytics organisations for customer profiling.
If you enter one of our competitions, we will collect your information in order to randomly select a winner and send out their prize.
To stop us contacting you for marketing write to us using the details provided at the end of this Policy.
7. Information Security
We work hard to keep your data safe. We use an appropriate combination of technical and organisational measures to ensure, as far as reasonably possible, the confidentiality, integrity and availability of your information at all times. If you have any security-related concerns, please contact us using the details provided at the end of this Policy.
8. Transferring your information outside of the European Economic Area (EEA)
In order to provide our services, the information you give us may be transferred to countries outside the European Economic Area (EEA). These countries may not have similar data protection laws to the UK. When we do transfer your personal data outside of the EEA, we ensure that any party with access to your information has implemented the necessary security and privacy measures to ensure that your personal data is kept secure and confidential as outlined in this policy.
9. Information we collect through your use of our websites and social media
Cookies help us understand how you use our websites, view our products and respond to our advertising, so we can tailor direct marketing and enhance our overall product and service offering to you. When you visit one of our websites, we may record your device information including IP address, hardware and software used, general location, and when and how you interact with our websites.
This information is retained and used to note your interest in our products and to improve customer experience. When you receive direct marketing from us by email, we may use technology or links to determine how you use our direct marketing, and your interest in it.
10. Detecting and preventing fraudulent or criminal activity
We value the confidentiality of your personal information. However, there are some instances where we need to share your information with third parties to assist us in detecting and preventing criminal or fraudulent activities. If you require any more information about this, you can talk to us in person at any branch, or by contacting us using the details provided at the end of this policy.
11. Access to your information and correction
You have a number of rights with regards to the personal information that we hold about you, which you will have provided as part of taking up a quote or service with us.
Right of Access
You have the right to request a copy of the information that we hold about you. We will provide you with this information within one month of receiving your request and verifying your identity. If the request is complex, we may extend the response time. We will inform you if this is the case and explain why.
Right to Rectification
We want to make sure that your personal information is accurate and up to date. You may ask us to correct, update or remove information you think is inaccurate or incomplete, and we ask that you inform us promptly of any changes to your circumstances.
Right to Erasure
You may also ask us to erase your personal information from our systems, in certain circumstances. There are some specific circumstances where the right to erasure does not apply and we are permitted to hold your data. We will explain the reason for this at the time, should this occur.
Right to Data Portability
You may also ask us to move, or ‘port’, your personal information to another organisation electronically. We will only port personal information that you have provided to us, that we have processed based on your consent or performance of a contract, or that has been processed automatically. We will port your personal information without charge and within one month, where technically feasible.
Right to Restricting Processing
You have a right to request that we restrict the processing of your personal data in certain circumstances. We will inform our third parties to whom we have disclosed your personal data that they must also restrict processing. We will inform you when the restriction on processing your personal data ends.
If you would like to exercise these rights then please write to us using the details provided at the end of this policy, outlining your specific request.
12. Retaining your data
Islands Insurance, and the information we collect about you, are subject to various regulatory and legislative requirements. In addition, we will endeavour not to keep your personal information for longer than we have to for us to fulfil our obligations to you. Where it is not possible for us to delete your data, we will ensure the appropriate security and organisational measures are put in place to protect the use of your information.
We work hard to ensure that your personal information is treated safely and securely. However, if you have a complaint, you can talk us in person at any branch, or by contacting us using the details provided at the end of this Policy. You also have the right to complain to the Office of the Information Commissioner.
15. Who to contact in relation to processing of personal information at Islands Insurance
Please contact us if you would like to discuss anything in relation to this policy or how we handle your personal information. You can reach the Data Protection Office for Islands Insurance by:
- Email at DataProtection@islands.je
- Writing to us at:
Data Protection Officer,
55 The Esplanade,
Jersey JE1 4HQ