Group Protection Insurance Privacy Policy

We obtain Personal Information directly from your employer at application stage and from you at application and claims stage if required. At claims stage, we can accept information about the claim from you, your next of kin, your legal representative or another relative. Where the policy is under trust we may receive Personal Information from appointed trustees.

We may also obtain Personal Information from third parties, including the following:

• Insurance brokers or financial advisers;
• Third parties involved in the relevant insurance policy or claim, including other insurers, legal advisers, brokers and advisers; 
• Healthcare providers and medical practitioners;
• Service providers in relation to the relevant insurance policy or claim, including medical experts and in limited circumstances, private investigators; 
• Aviva group companies who may provide information in relation to other products you hold, previous claims, policies or quotes; 
• Data brokers, e.g. Experian and LexisNexis;
• Financial crime detection agencies, databases and sanctions lists, including the Insurance Fraud Bureau;
• Government agencies and regulatory bodies, including the police, the courts, the Department for Work and Pensions (DWP), Companies House, the National Health Service (NHS) and HM Revenue & Customs (HMRC); 
• Regulators who regulate how we operate, including the Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA), Information Commissioner’s Office (ICO), and Financial Ombudsman Service (FOS);
• Third parties that help us maintain the accuracy of our data, e.g. by identifying individuals who are deceased, updating contact details for individuals who have moved;
• Third party suppliers, including auditors, legal advisers and other professional service firms, and sanctions-checking service providers;
• Publicly available sources, including the Office for National Statistics (e.g. census data) and other data made available under the Open Government Licence internet searches, news articles, online marketplaces and social media sites, apps and networks (e.g. Twitter, Facebook and Instagram);
• Third parties in connection with any acquisition of a business by us.

The Personal Information we hold and process includes:

Information provided by you or third parties, including:

• General data – includes your name, date of birth, marital status, country of residence/citizenship and your relationships to other people; 
• Contact data – includes your address, telephone number and e-mail address;
• Identification data – includes government issued identification numbers, e.g. your NHS number and other identifiers, e.g. usernames and social media identifiers;
• Appearance and behavioural data – includes your gender, age, general interests, how often and where you travel, descriptive data, e.g. your height and weight, demographic data and behavioural data, e.g. your purchase history.
• Health and lifestyle data – includes details of your Body Mass Index, whether you do or have ever smoked or used tobacco products, details regarding alcohol consumption. For further information see Sensitive Personal Information; 
• Product data – includes information about quotes, policies, schemes and claims, and any other information relevant to your product, including policy and claim histories;
• Claims data – if a claim is made under an insurance policy, this includes information about the claim collected from you, your next of kin or another relative, your legal representative or other relevant third parties;
• Fraud and sanctions related data – includes information obtained as a result of our investigations, e.g. carrying out checks of publicly available sources such as newspapers and social media sites and information obtained from checks of fraud databases and sanctions lists such as relationships/close associations with politically exposed persons;
• Employment-related data – includes your employment status, job title, salary, and employment and history;
• Financial data – includes bank account details, details of income, tax bands and liabilities, assets and liabilities e.g. information on shareholdings and loans;
• Vulnerability data – information about health, life events, resilience and capability that helps us identify if you might have additional support requirements in order that we can better meet your needs;
• Telephone recordings and online chat transcripts – information obtained during recordings of telephone calls or online chats with our representatives and call centres;
• Communication preferences and customer feedback – includes communication preferences, responses to surveys, complaints and details of your customer experience.

Information provided by third parties, including:

• Accurate contact data, e.g. where you have moved address, changed your telephone number or started using a new email address and not yet advised Aviva. This data may be used to ensure that we have a complete understanding of your product holding and to provide you with communications about your products. It will not be used for direct marketing purposes unless it was collected by the third party expressly for that purpose and always in accordance with data protection law.

Information collected from your devices, including:

• Mobile device number, device type, operating system, browser, MAC address, IP address, location and account activity obtained through our use of cookies. You can find more about our use of cookies in our Cookie Policy.

Information already held by Aviva, including:

• If you hold another Aviva policy in your own right, data relating to other Aviva policies – e.g. quote, policy and claim histories relating to other existing Aviva policies or products or those you may have applied for or held in the past, and contact details where you may have advised Aviva about a change on one product, but not another;
• Modelled data that has been developed by Aviva using data that it already holds.

Information inferred from your Personal Information, including:

• Vulnerability data – information about health, life events, resilience and capability that helps us identify if you might have additional support requirements in order that we can better meet your needs;
• Fraud and sanctions-related data – includes information obtained as a result of our investigations, e.g. carrying out checks of publicly available sources, such as newspapers and social media sites and checks of fraud databases and sanctions lists.

Children’s data:

• We collect data about children in some circumstances e.g. where they are eligible for a child’s critical illness claim or where they are beneficiaries of a policy in trust.

Sensitive Personal Information

Sometimes we will request or receive Personal Information that is sensitive and we call this “Sensitive Personal Information”. This is information relating to your health, genetic or biometric data, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership. It also covers criminal offence data, including information about criminal activity, allegations (including those unproven), investigations, proceedings and penalties. For example, to investigate a claim made under a critical illness or income protection policy, we’ll need to ask you to provide details of your health condition. We know how sensitive this data is, so protecting it is a top priority. The types of Sensitive Personal Information we hold and process where relevant includes:

• Health data – includes details of existing and previous physical or mental health conditions, health status, test results, medical diagnoses and treatment given, prescriptions and personal habits (e.g. smoking or consumption of alcohol);
• Criminal data – includes details of convictions, e.g. in relation to fraud;
• Other sensitive data – in limited circumstances we may process other Sensitive Personal Information. For example, we may process information relating to your religious beliefs where relevant to your preferences regarding medical treatment.

The main purposes for which we use Personal Information are to:

• Communicate with you and other individuals;
• Make assessments and take decisions, including whether to provide you with our products and services and on what terms; 
• Provide our products and services, including insurance administration, making changes where requested or necessary, managing renewal, claims assessment, settlement and dispute resolution and the provision of our apps and other technologies, e.g. DigiCare+ Workplace;
• Manage relationships with third parties, e.g. brokers and service providers. 
• Prevent, detect and investigate fraud and other crime, including by carrying out fraud, sanctions and anti-money laundering checks. For further information see Fraud and Other Financial Crime;
• Improve our products and services, provide staff training and maintain information security, including by recording and monitoring telephone and online calls and screen sharing sessions;
• Conduct customer insight analysis, market research and focus groups, including customer segmentation, gathering customer feedback, creating promotional materials and customer satisfaction surveys;
• Help us better understand our customers and improve our customer engagement;
• Carry out data analysis, including to ensure data accuracy and quality and for insurance risk modelling and product and pricing refinement. For further information see Profiling and Data Analysis;
• Manage complaints, including to allow us to respond to any current complaints, or challenges you or others might raise later, for internal training and monitoring purposes and to help us to improve our complaints handling processes. We may be obliged to forward details about your complaints, including your Personal Information, to the appropriate authorities, e.g. the relevant ombudsman;
• Manage feedback and queries, and handle requests to exercise data subject rights. For further information see Data Rights;
• Manage our business operations, including by carrying out internal audits, quality assurance and training, financial analysis and accounting, producing management information, and performing administrative activities in connection with the services we provide;
• Manage commercial risk, including by taking out and maintaining appropriate insurance and reinsurance;
• Comply with applicable legal, regulatory and professional obligations, including cooperating with regulatory bodies e.g. the FCA, PRA, ICO and government authorities, to comply with law enforcement and to manage legal claims;
• Identify and support customers requiring additional support, to help us better meet your needs and to comply with regulatory guidance about how we meet your needs. Sometimes you or a third party may tell us that you have additional support requirements, and in other cases we may infer this from your Personal Information and our interactions with you;
• Establish, enforce and defend our legal rights or those of third parties, including enforcing our terms and conditions, pursuing available remedies and limiting our damages; 
• Carry out activities that are in the public interest, e.g. we may need to use Personal Information to carry out anti-money laundering checks;
• Buy, sell, transfer or dispose of any part of our business; 
• Archiving, scientific or historical research or statistical purposes.

We are committed to collecting and using Personal Information in accordance with applicable data protection laws. By law, we must have a legal justification, known as a lawful basis, in order to use your Personal Information for the purposes described in this Privacy Policy. Depending upon the purpose, our lawful basis will be one of the following:

• Performance of a contract – to arrange, underwrite or manage our products, or handle claims in accordance with their terms;
• Compliance with a legal obligation – to meet responsibilities we have to our regulators, tax officials, law enforcement, or other legal responsibilities;
• Legitimate interests – to operate and improve our products and services and keep people informed about our products and services or for any other purposes we identify as appropriate to our business needs, or those business needs of a third party;
• Consent – where we have obtained appropriate consents to collect or use your Personal Information for a particular purpose.

Where we rely on legitimate interests as our lawful basis, we are required to carry out a balancing test to ensure that our interests, or those of a third party, do not override the rights and freedoms that you have as an individual. The outcome of this balancing test will determine whether we can use your Personal Information for the purposes described in this Privacy Policy. Where we rely on the lawful basis of legitimate interests, the interests being relied upon will usually be:

• To further our business and commercial activities and objectives, or those of a third party, e.g. to provide our products and services and produce management information on our performance and the performance of third parties;
• To provide cover to you under a group policy where your employer is the policyholder;
• To provide you with helpful information relating to your products and about useful tools for managing and engaging with your products. These are not marketing communications;
• To comply with our legal and regulatory obligations, guidelines, standards and codes of conduct, e.g. background checks or the prevention, detection and investigation of financial crime or fraud;
• To improve and develop our business, products and services, or those of a third party, e.g. to ensure the accuracy of customer data and to develop our pricing and risk methods and models;
• To retain policy records for a period of time in order to ensure we have appropriate records in place in respect of any future claims that may be insured by us;
• To safeguard our business, shareholders, employees and customers, or those of a third party, e.g. maintaining the security of our IT network and information, enforcing claims, including debt collection; 
• To facilitate the purchase, sale, transfer or disposal of any part of our business; and
• To analyse and assess competition in the market for our products services, e.g. by carrying out market research.

We can only collect and use Sensitive Personal Information where we have an additional, specific lawful basis to process such information. We usually rely upon one of the following lawful bases where we process Sensitive Personal Information:

• Reasons of substantial public interest:
  • insurance purposes – including advising on, arranging, underwriting and administering contracts of insurance, administering claims under a contract of insurance and exercising rights, or complying with obligations that arise in connection with contracts of insurance;
  • complying, or helping someone else comply with, a regulatory requirement relating to unlawful acts and dishonesty - including regulatory requirements to carry out money laundering checks;
  • preventing or detecting unlawful acts – including disclosures to competent authorities;
  • preventing fraud – including investigating alleged fraud;
  • safeguarding the economic well-being of certain individuals – including where we identify additional support required by our customers;
  • equality of opportunity or treatment – including where we need to keep under review the equality of treatment of customers with additional support needs.
• Necessary to establish, exercise or defend a legal claim – including where we are faced with legal proceedings, we bring legal proceedings ourselves or where we are investigating legal proceedings that a third party has brought against you;
• Information has been clearly or obviously made public by you.
  

Where we cannot rely on one of the above lawful bases to process your Sensitive Personal Information for a particular purpose, we will seek your explicit consent.

If you would like to know more about the lawful bases we rely upon, or how the lawful basis of legitimate interests applies to a particular purpose, you can contact us.

You may ask us for a copy of your Personal Information together with specified details about how we use your information. This is commonly known as a ‘subject access request’.

If you wish to make a subject access request, please fill out this form or write to us using the details in Contacting Aviva.

If your request is made electronically, we will, where possible, respond to you electronically. Otherwise, we will normally respond in writing unless you request otherwise.

We do our best to ensure that your Personal Information is accurate and kept up to date. If you believe your information is inaccurate or incomplete, then please contact us to request that we amend or update it.

You may ask us to erase your Personal Information, but this right only applies in certain circumstances, e.g. where:

• it is no longer necessary for us to use your Personal Information for the original purpose; 
• our lawful basis for using your Personal Information is consent and you withdraw your consent; or
• our lawful basis is legitimate interests and there is no overriding legitimate interest to continue using your Personal Information if you object.

This isn’t an absolute right and we have to balance your request against other factors such as legal or regulatory requirements, which may mean we cannot erase your Personal Information.

You may ask us to stop using your Personal Information in certain circumstances such as:

• where you have contacted us about the accuracy of your Personal Information and we are checking the accuracy;
• if you have objected to your Personal Information being used based on legitimate interests.

This isn’t an absolute right and we may not be able to comply with your request.

In some cases, you can ask us to transfer Personal Information that you have provided to us to another third party of your choice. This right only applies where:

• we have justified our use of your Personal Information based on your consent or the performance of a contract with you; and
• our use of your Personal Information is by electronic means.

You can object if you no longer wish to receive direct marketing from us.

You may also object where you have grounds relating to your particular situation and the lawful basis we rely on for using your Personal Information is our (or a third party's) legitimate interests. However, we may continue to use your Personal Information where there are compelling legitimate grounds to do so.

You have the right not to be subject to a decision using your Personal Information which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right does not apply if the decision is:

• necessary for the purposes of a contract between us and you;
• authorised by law (e.g. to prevent fraud); or
• based on your explicit consent.

You do however have a right to request human intervention, express your view and challenge the decision.

In some circumstances we ask for your consent to use your Personal Information. You are free to withdraw your consent at any time.

If it is the case that we need your consent to provide you with a particular product and you wish to withdraw your consent, we may no longer be able to provide our product to you. Where that is the case, we will inform you before taking any action.