Soteria Insurance Limited Privacy Notice

      1. What is this notice?

      This privacy notice (Notice) sets out how we will collect, use and share your personal information and explains your data protection rights and how to contact us. If you would like to receive this Notice in an alternative format such as large print, audio or braille, please let us know.

      In this Notice, references to you or your shall include anyone requesting an insurance quote from us or whose details are provided to us during the quotation process, policyholders and anyone named or covered by our insurance products (Insurance Products) and anyone who may benefit from or be directly involved in the Insurance Product or a claim including claimants and witnesses

      1. Who are we?

      We are Soteria Insurance Limited (SIL) (formerly known as CIS General Insurance Ltd) and are classed as a “data controller” of your personal information. SIL provides you with Co-op motor and home Insurance Products. Our registered office address is at 9th Floor, Arndale House, 122A Market Street, Manchester M4 3AG. When we use terms such as we, us and our in this Notice, we mean SIL.

      In addition:

      • SIL has appointed Markerstudy Insurance Services Limited (MISL) to handle the ongoing administration of your Insurance Product, including claims handling.
      • Affinity Insurance Solutions Ltd (AISL) has been appointed by MISL to handle certain administration functions in relation to your Insurance Product, including services in relation to any renewals of your Insurance Product.

      SIL, MISL and AISL are each separate data controllers of your personal information. This means we each have separate responsibility for your personal information. MISL and AISL will provide you with a separate privacy notice which explains how they process your personal information in connection with the administration of your Insurance Product.

      SIL will not usually collect any personal information from you directly but we may receive personal data from MISL and/or AISL in the course of managing the overall performance of our Insurance Products, monitoring the performance of MISL/AISL, and when MISL/AISL asks us to approve a claim. This Notice explains the limited circumstances in which SIL may process your personal information.

      1. Who do we process personal information about?

      We may process personal information about:

      • previous, current and prospective customers/policyholders;
      • previous, current and prospective parties covered under an insurance policy;
      • users of our website, [soteriainsurance.co.uk];
      • business partners;
      • third party claimants;
      • witnesses to accidents or incidents; and
      • experts instructed in relation to any insurance claims.
      1. How and when do we receive personal information?

      Except in the limited circumstances identified in this section, we only receive personal information from MISL and AISL. We generally only receive this information in the course of managing the overall performance of our Insurance Products, monitoring the performance of MISL/AISL, and when MISL/AISL asks us approve a claim.

      If you contact us via the contact form on our website, or using the contact details provided on our website, we will receive the personal information that you choose to provide us with, including your contact details.

      1. What kinds of personal information do we process?

      The personal information that we process will depend on the circumstances, for example, whether we are reviewing and approving a claim you have made.

      We may process certain information such as your name, gender, marital status, address, email address, contact telephone number, and details of your claim. We may process additional information in relation to some of our Insurance Products such as vehicle registration number for motor insurance products, as well as personal information which the data protection laws define as special categories of data, such as medical history and information that relates to criminal convictions for the purposes of providing you with a policy or processing claims, or for preventing, detecting and investigating fraud.

      1. How do we use your personal information?

      We will only use your personal information where it is permitted by law. We have set out below alongside each purpose the legal basis that we rely on. We may use your personal information (and any personal information relating to joint policyholders or covered parties):

      • to provide you with an Insurance Product (including having oversight of and approving any claims made by you) on the basis that processing is necessary to perform our contract with you;
      • to manage the overall performance of our Insurance Products and to monitor the performance of MISL/AISL on the basis that processing is necessary for our legitimate interests in understanding the performance of our Insurance Products and checking that claims handling is being handled appropriately;
      • where it is necessary for us to comply with any legal or regulatory obligation to which we are subject;
      • to manage your policy on the basis that processing is necessary to provide your Insurance Product;
      • to assess risk, set prices, decide how much risk to keep and how much risk we should pass to another insurer on the basis that processing is necessary for our legitimate interests in setting prices that are appropriate to the risk level;
      • to help set our financial reserves on the basis that processing is necessary for our legitimate interests in maintaining sufficient and appropriate financial reserves and running our business in a proper manner;
      • to prevent and detect fraud and crime on the basis that processing is necessary for us to comply with any legal or regulatory obligation to which we are subject and our legitimate interests in complying with such obligations and preventing and detecting fraud and crime;

      Where we process any special category data for the purposes of providing you with a policy or processing claims, or for preventing, detecting and investigating fraud, our legal bases are that the processing is necessary for an insurance purpose, preventing or detecting unlawful acts or fraud, complying with or assisting another to comply with a regulatory requirement relating to unlawful acts or dishonesty, and/or the establishment, exercise or defence of legal claims.

      1. Who do we share your personal information with?

      We may share your personal information with:

      • MISL;
      • AISL;
      • service providers and professional advisors who assist us to manage your Insurance Product;
      • crime and fraud prevention agencies and organisations;
      • law enforcement, taxation and legal authorities;
      • reinsurers,

      for the purposes outlined in section 6.

      We may also share your personal information with third parties in the event that:

      • our business or substantially all of its assets are acquired by a third party;
      • we are under a duty to disclose or share your personal information to comply with our legal obligations;
      • we must enforce any contract with you; or
      • we must protect our rights, property or the safety of our employees, customers or others.
      1. Will we transfer your personal information outside the UK?

      We may need to transfer your personal information outside the UK to countries where data protection laws may not provide the same level of protection as those in the European Economic Area. We shall ensure that any such transfers are lawful and that your personal information is kept secure.

      1. How long will we keep your personal information for?

      As a principle, we only keep your personal information for as long as it is needed for each of the purposes we have identified above. Usually, we will retain your information for up to seven years, unless there is an exceptional business purpose in which case this time period may be extended.

      1. What are your rights?

      Data protection laws give you a number of rights as set out below. If you would like to exercise any of your rights, please contact us using the details at section 12 of this Notice.

      Right to access your personal information: you may request access to a copy of your personal information. Please send all requests for access to us in writing.

      Right to withdraw consent: if you have given us consent to use your personal information for a particular purpose, you can withdraw your consent at any time.

      Right to rectification: you may ask us to rectify any inaccurate information we hold about you. If you would like to update the personal information we hold about you, please contact us.

      Right to erasure: you may ask us to delete your personal information. If you would like us to delete the personal information we hold about you, please contact us, specifying why you would like us to delete your personal information.

      Right to portability: you may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable format, or ask for us to send such personal information to another data controller.

      Right to restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.

      Right to object: you may object to our processing of your personal information pursuant to this Notice. Please contact us, providing details of your objection.

      Right to make a complaint: you may make a complaint about our data processing activities by contacting us using the details at section 12 of this Notice. Alternatively, you may make a complaint to a supervisory authority for data protection matters. The UK supervisory authority is the Information Commissioner's Office and you can make a complaint by visiting their website at www.ico.org.uk, by phoning 0303 123 1113 (local rate) / 01625 545 745 (national rate), or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

      Please note that in some cases:

      • we may not be able to comply with your request (for example, we might not be able to delete your personal information) for reasons such as our own obligations to comply with other legal or regulatory requirements. We will always respond to any request you make and if we cannot comply with your request, we will tell you why; and
      • exercising some of these rights (including the right of erasure, the right of restriction and the right to withdraw consent) will mean we are unable to continue providing you with cover under an Insurance Product and may therefore result in cancellation of your Insurance Product. You will therefore lose the right to bring any claim or receive any benefit under that Insurance Product, including in relation to any event that occurred before you exercised your right of erasure, if our ability to handle the claim has been prejudiced. Your policy documents will set out what will happen in the event that your Insurance Product is cancelled.
      1. Your responsibility to provide us with accurate information

      It is your responsibility to provide MISL/AISL with accurate and complete information as it may affect your Insurance Product with us. If you do not do so, it could result in the price of your Insurance Product being increased, your quotation or claim being rejected, a claim settlement payment being reduced and/or your Insurance Product being cancelled or made void (treated as though it never existed).

      1. How to contact us

      If you have any queries relating to this Notice or our use of your personal information or wish to exercise any of your data protection rights, please contact MISL on dataprotection@markerstudy.com. MISL will then pass on your query or request to us as appropriate. [Please note that calls may be monitored or recorded for training and development and maintenance of records.]