Privacy Policy

Introduction

Castle Insurance Services (NE) are committed to ensuring your privacy and personal information is protected. The document that referred you to this notice (for example, your insurance policy) shall set out details of the company that is processing your personal information; it is the data controller of your personal information and is responsible for complying with data protection laws. For the purposes of this privacy policy, references to "we" or "us" shall refer to Castle Insurance Services (NE) Ltd This privacy policy should be brought to the attention of any party who is included in your policy, where they have given you consent to act on their behalf. By providing your personal information or the personal information of someone incuded in your policy, you acknowledge that we may use it only in the ways set out in this privacy policy. We may provide you with further notices highlighting certain uses we wish to make of your personal information. From time to time, we may need to make changes to this privacy policy, for example, as a result of government leglislation, new technoligies, or other developments in data protection laws or privacy generally. You should check our website periodically to view the most up to date privacy policy.



Privacy Principles

When we collect and use your personal information, we ensure we look after it properly and use it in accordance with our privacy principles set out below, keep it safe and will never sell it.

  • Personal information you provide is processed fairly, lawfully and in a transparent manner
  • Personal information you provide is collected for a specific purpose and is not processed in * a way which is incompatible with the purpose which we collected it
  • Your personal information is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed
  • Your personal information is kept accurate and, where necessary kept up to date
  • Your personal information is kept no longer than is necessary for the purposes for which the personal information is processed
  • We will take appropriate steps to keep your personal information secure
  • Your personal information is processed in accordance with your rights
  • We will only transfer your personal information to another country or an international organisation outside the European Economic Area where we have taken the required steps to ensure that your personal information is protected. Such steps may include placing the party we are transferring information to under contractual obligations to protect it to adequate standards
  • Castle Insurance Services (NE) Ltd do not sell your personal information and we also do not permit the selling of customer data by any companies who provide a service to us



How do we collect your personal information?

Whilst there are a number of ways in which we collect your personal information, the two main ways we might collect personal information about you are from things you tell us yourself, and from things we ask other people or organisations to share with us. Things you tell us could include conversations we have on the phone, what you’ve written on an application form or if you post something on one of our forums. We might also collect information about you from other people and organisations, such as medical professionals and credit agencies, or by checking databases, such as the electoral register. Please see below for a list of ways we collect your personal information: We collect personal information directly from you:

  • via enquiry, registration and claim forms;
  • via feedback forms and forums;
  • when you purchase any of our products or services;
  • when you fill out a survey;
  • through quotes and application forms;
  • via cookies. You can find out more about this in our cookies policy;
  • via our telephone calls with you, which may be recorded;
  • when you provide your details to us either online or offline;
We also collect your personal information from a number of different sources including:
  • directly from an individual who has a policy with us under which you are insured, for example you are a named driver on your partner’s motor insurance policy;
  • from credit reference agencies who will supply us with information, including information from the Electoral Register and credit information. Please note that the agencies may record details of the search whether or not your application proceeds;
  • from social media where fraud is suspected; and
  • via third parties including:
  • your family members where you may be incapacitated or unable to provide information relevant to your policy;
  • aggregators;
  • third parties who assist us in checking that we are permitted to make claims payments; and
  • third parties such as companies who provide consumer classification for marketing purposes e.g. market segmentation data



What personal information do we collect?

We might collect personal information, such as your contact details, information about your bank or credit cards. The information we collect depends on which product or service you’re interested in for example if you are interested in obtaining car or travel insurance, we’ll collect information about the car you drive or where you’re planning to travel to and for medical insurance, we may ask you about you or your families' medical history. Please note, in certain circumstances we may request and/or receive "sensitive" personal information about you. For example, we may need access to health records for the purposes of providing you with a policy or processing claims, or details of any court or HMRC judgments for the purposes of preventing, detecting and investigating fraud. Please see below for a more detailed list of personal information we collect. The information that we collect will depend on our relationship with you. Where other people are named on your policy, we may ask you to provide the information below in relation to those people too, if this is relevant to your insurance. Where Castle Insurance Services (NE) Ltd is the data controller of your personal information we may collect the following about you: Personal information

  • contact details such as name, email address, postal address and telephone number
  • details of any other persons included on the policy where they are named on your policy and the relationship to you as policyholder
  • identification information such as your date of birth, national insurance number, passport and driving licence
  • financial information such as bank details, credit card details and information obtained as a result of our credit checks
  • information relevant to your insurance policy such as details about your vehicle, property, previous policies or claims, recent damage, information about your travel plans, destination, planned activities and dates of travel
  • information relevant to your claim or your involvement in the matter giving rise to a claim
  • information about the nature of your business and commercial assets
  • information obtained through our use of cookies. You can find out more about this in our cookies policy
  • details of bankruptcies and other financial sanctions such as HMRC investigations
  • your marketing preferences
Sensitive personal information
  • details of your current or former physical or mental health
  • details concerning sexual life or sexual orientation, for example marital status
  • details regarding criminal offences, including alleged offences, criminal proceedings, outcomes and sentences (previous criminal convictions, bankruptcies and other financial sanctions such as County Court Judgements)



How do we use your personal information?

We mainly use your personal information to provide you with an insurance policy or benefits and to provide you with the right services based on your situation. So, if you have a problem, we make sure the right network of providers and specialists are in place and we can also update you quickly on the progress and cost of your claim and keep you safe from fraud. However, there are a number of other reasons why we use your personal information; Please see below for a more detailed list of how we use your personal information. We may process your personal information for a number of different purposes and these are set out in more detail in the below sub-section. Under data protection laws we need a reason to use and process your personal information and this is called a legal ground. We have set out below the main reasons why we process your personal information and the applicable circumstances when we will do so. When the personal information we process about you is classed as sensitive personal information (now known as ‘Special Categories’) (such as details about your health, sexual orientation or criminal offences) we must have an additional legal ground for such processing, or where appropriate, we apply a specific exemption for Insurance purposes.

  • Processing is necessary in order for us to provide your insurance policy and services, such as assessing your application and setting you up as a policyholder, administering and managing your insurance policy, providing all related services, providing a quote, handling and paying claims and communicating with you. In these circumstances, if you do not provide such information, we will be unable to offer you a policy or process your claim.
  • Where we have a legal or regulatory obligation to use such personal information, for example, when our regulators, the Prudential Regulatory Authority, (PRA), the Financial Conduct Authority (FCA) and our data protection regulator, the Information Commissioner's Office (ICO) wish us to maintain certain records of any dealings with you.
  • Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claims or where we want to pursue any legal claims ourselves.
  • Where we need to use your personal information for reasons of substantial public interest, such as investigating fraudulent claims and carrying out fraud, credit and anti-money laundering checks.
  • Where we have a specific legal exemption to process sensitive personal data for insurance purposes. This exemption applies where we need to process your information as an essential part of the insurance cover, for example health data.
  • Where you have provided your consent to our use of your personal information. We will usually only ask for your consent in relation to processing your sensitive personal information (such as health data) or when providing marketing information to you (including information about other products and services). This will be made clear when you provide your personal information. If we ask for your consent we will explain why it is necessary. Without your consent in some circumstances, we may not be able to provide you with cover under the policy or handle claims or you may not be able to benefit from some of our services. Where you provide sensitive personal information about a third party (such as a named driver) we will ask you to confirm that the third party has provided his or her consent for you to act of their behalf.
  • Where we have appropriate legitimate business need to use your personal information such as maintaining our business records, developing and improving our products and services, all whilst ensuring that such business need does not interfere with your rights and freedoms and does not cause you any harm.
  • Where we need to use your sensitive personal information such as health data because it is necessary for your vital interests, this being a life or death matter.
You will find details of the legal grounds we rely on for each use of your personal information here



Who do we share your personal information with?

We might share your personal information with other third parties. For further details of disclosures, please see below. We won’t share any of your personal information other than for the purposes described in this Privacy Policy. If we share anything, it’ll be kept strictly confidential and will only be used for reasons that we’ve described. Disclosures to third parties We also disclose your information to the third parties listed below for the purposes described in this Privacy Policy. This might include:

  • Your relatives or, guardians (on your behalf where you are incapacitated or unable) or other people or organisations associated with you such as your insurer or your lawyer
  • Where you have named an alternative contact (such as a relative) to speak with us on your behalf. Once you have told us your alternative contact, this person will be able to discuss all aspects of your policy (including claims and cancellation) with us and make changes on your behalf.
  • Your Road Relay Agent, such as the AA or Greenflag
  • A recommended garage or panel beater or your designated garage or panel beater
  • Our insurance partners such as brokers, other insurers, reinsurers or other companies who act as insurance distributors
  • Other third parties who assist in the administration of insurance policies such as another Insurance Company if there has been an accident which requires a claim to or from that Insurance Company
  • We may share the personal information of any persons named on the policy with third parties to obtain information which may be used by your insurer to inform its risk selection, pricing and underwriting decisions
  • Fraud detection agencies and other third parties who operate and maintain fraud detection registers
  • The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime
  • Motor Insurers' Information Centre and the DVLA
  • Passing information to a third party for the purpose of validating your No Claims Discount (NCD) entitlement and this may be made available to other insurers
  • Also to other companies or insurers for the purpose of validating your NCD entitlement
  • Our third party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document management providers and tax advisers
  • Other suppliers, providers of goods and services associated with this insurance and/or to enable us to deal with any claims you make
  • Financial organisations and advisers
  • Central Government
  • The Financial Ombudsman Service and regulatory authorities such as the Financial Conduct Authority and the Information Commissioner’s Office
  • Overseas assistance companies
  • Loss Adjusters
  • Car Hire Companies
  • House Builders or other House Repairers
  • Emergency Assistance Companies
  • Your healthcare practitioner
  • Debt collection agencies
  • Credit reference agencies
  • Selected third parties in connection with the sale, transfer or disposal of our business
We also disclose your information to the third parties listed below for the purposes described in this Privacy Policy. This might include: Disclosure of your personal information to a third party will only be made where the third party has agreed to keep your information strictly confidential and shall only be used for the specific purpose for which we provide it to them. We may also disclose your personal information to other third parties where:
  • we are required or permitted to do so by law or by regulatory bodies such as where there is a court order, statutory obligation or Prudential Regulatory Authority / Financial Conduct Authority or Information Commissioners Office request; or
  • we believe that such disclosure is necessary in order to assist in the prevention or detection of any criminal action (including fraud) or is otherwise in the overriding public interest.
Some of the recipients set out above may be in countries outside of the EEA. Where we make a transfer of your personal information outside of the EEA we will take the required steps to ensure that your personal information is protected. Such steps may include placing the party we are transferring personal information to under contractual obligations to protect it to adequate standards. Occasionally there may also be some circumstances where we are required to transfer your personal information outside of the EEA and we shall rely on the basis of processing it for being necessary for the performance of your contract; for example, where you have a travel insurance policy and we need to contact you when you are on holiday.



How long do we keep records for?

In most cases, we only keep your information for as long as the regulations say we have to. This is usually between three and ten years after our relationship with you ends but it will vary depending on what data we hold, why we hold it and what we’re obliged to do by the regulator or the law. We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in order to comply with our legal and regulatory obligations. The time period we retain your personal information for will differ depending on the nature of the personal information and what we do with it. How long we keep personal information is primarily determined by our regulatory obligations. We typically keep quote information for 3 years, and policy and claims records for up to 10 years from the end of our relationship with you. In some cases, such as if there is a dispute or a legal action we may be required to keep personal information for longer. Long-term insurance products such as liability insurance is kept for an extended period and data held in relation to a health policies is kept for 13 years.



Your rights

You can ask us to do various things with your personal information. For example, at any time you can ask us for a copy of your personal information, ask us to correct mistakes, change the way we use your information, or even delete it. We’ll either do what you’ve asked, or explain why we can’t - usually because of a legal or regulatory issue. For further details about your rights please see below You have the following rights in relation to our use of your personal information. The right to access your personal information You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing, unless otherwise requested, or where you have made the request by electronic means, in which case the information will be provided to you by electronic means where possible. The right to rectification We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us by using the details shown in your documentation and you can ask us to update or amend it. The right to erasure: In certain circumstances, you have the right to ask us to erase your personal information, for example where the personal information we collected is no longer necessary for the original purpose or where you withdraw your consent. However, this will need to be balanced against other factors, for example according to the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request. Right to restriction of processing: In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to process your personal information. Right to data portability: In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice. Once transferred, the other party will be responsible for looking after your personal information. Right to object to direct marketing: You can ask us to stop sending you marketing messages at any time. Please see the Marketing section for more information. Right not to be subject to automated-decision making: Some of our decisions are made automatically by inputting your personal information into a system or computer and the decision is calculated using certain automatic processes rather than our employees making those decisions. We make automated decisions in the following situations: Deciding your premium We use the personal information that you and others provide to us about you your family, property, where you live your policy claims history, and other non-personal information such as garage repair costs or hospital costs to determine your premium and eligibility. The price also depends on what options you have chosen to purchase. For example, if you live in London you will pay more than if you live in Lancashire because healthcare costs, on average, are higher in London than Lancashire. We also use information about how long you have been a customer, how many claims you have made and how much you pay in premiums to determine what terms you are offered at renewal. Fraud prevention Castle Insurance Services (NE) Ltd uses automated anti-fraud filters that check against lists of people known to have undertaken fraudulent transactions and will reject those applicants on the basis they are likely to defraud the company. Assessing your application We may use scoring methods to assess your application, to verify your identity and determine finance charges, for example; When you buy a healthcare policy, you will either do so on a personal policy or under a group scheme. We may collect information directly from you, from/via your or your partner, your parents or employer. Depending on the type of scheme we may collect health information at the start, as well as personal information such as your date of birth and address. Depending on the type of scheme/policy, Insurers may use the personal and sensitive information in order to assess the price and determine any exclusions we need to apply. Examples of information used by our systems to do this include: your age, your postcode your lifestyle (e.g. do you smoke cigarettes) and your medical history. If you do not consent to us processing sensitive information in this way, we may be unable to assess your application or offer you cover, alternatively we may only be able to offer you styles of policy that do not require us to have that information at the start. Castle Insurance Services (NE) Ltd uses individual credit information about you provided to us by third parties in order to assess your suitability for insurance and the price we offer to you. The information used to assess your insurance risk includes: verification of your residence at address via bills and electoral roll, historic payment behaviour on financial products, prior insolvency and any prior county court judgements. If we are unable to validate your residence at the insured address or consider your historic payment behaviour with creditors to be significantly adverse we will decline to offer you a price for your insurance risk. You have a right not to be subject to automated decision-making in the circumstances described above and where automated decision-making used in the assessment of your application or fraud prevention, you can contact us to request that any declined decision is reconsidered. If you want to opt out of automatic decision-making, let us know, although in some circumstances it may mean we can’t offer you a quote or policy as some automated decisions are necessary to provide your insurance policy. The right to withdraw consent: For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. Please note in some cases we may not be able to process your insurance if you withdraw your consent. The right to lodge a complaint You have a right to complain to the ICO at any time if you object to the way in which we use your personal information. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/ You can make any of the requests set out above using the contact details provided to you in your policy documentation. Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make and if we can't comply with your request, we will tell you why. In some circumstances exercising some of these rights will mean we are unable to continue providing you with cover under your insurance policy and may therefore result in the cancellation of the policy. You will therefore lose the right to bring any claim or receive any benefit under the policy, including in relation to any event that occurred before you exercised your right, if our ability to handle the claim has been prejudiced. Your policy terms and conditions set out what will happen in the event your policy is cancelled.



Marketing

You’re in control of how we use your information for marketing. We will only contact you if you’ve agreed it’s okay. Then, we might use your information to tell you about products and services that could interest you. But we don’t use your personal information for our online ad campaigns – you’ll need to check your browser or social media settings to avoid seeing these. We may inform you of other products and services that may be of interest to you or members of your family, but we will only do this where you have provided your consent. You can always change your mind by contacting us using the details shown in your documentation and telling us you no longer wish to be contacted. We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you wish to unsubscribe from emails sent by us, you may do so at any time by following the unsubscribe instructions that appear in all emails. Otherwise you can always contact us using the details set out in your documentation to update your contact preferences. In such circumstances, we will continue to send you service related (non-marketing) communications where necessary. Very occasionally we may also share your details with our selected business partners, but we will specifically tell you about this when we obtain your marketing preferences. We would like to keep you informed, from time to time about relevant products and services. We may do this by mail, email, telephone or other electronic methods such as text message. From time to time we may run specific marketing campaigns through social media and digital advertising that you may see which are based on general demographics and interests. Individual personal information is not used for these campaigns. If you do not want to see any campaigns then you will need to adjust your preferences within social media settings and your cookie browser settings. Please note that we may retain any data provided to us on our websites for a limited period, even if you do not complete your quote. The information may be used to enquire as to why you did not complete your quote or for us to better understand your needs but only if you have agreed for us to contact you.



Contact

If you wish to contact the Data Controller the details are below: Castle Insurance Services (NE) Ltd, for Household, Motor, Travel Insurance and Business Insurance Products: The Data Controller: Castle Insurance Services (NE) Ltd 15 Marshall Terrace, Gilesgate, Durham DH1 2HX email: paul@castleinsuranceservices.co.uk