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Private Clients Privacy Policy

Last updated: 05 Aug 2022

1. Introduction

This Privacy Policy explains how we use Personal Information which we collect about individuals in relation to our private client insurance policies.

We take the security of your Personal Information very seriously. We use a combination of technical, organisational and physical security measures to protect your Personal Information in line with our obligations under data protection law. Our employees receive training to help us comply with data protection law and safeguard your privacy.

This Privacy Policy is issued on behalf of the Aviva group companies in the United Kingdom and Ireland. When we mention "Aviva", "we", "us" or "our", what we mean is the relevant company in the Aviva group that processes your Personal Information.

The Aviva group company that underwrites your insurance policy will be the main company responsible for your Personal Information, known as the controller. Risks situated in the United Kingdom or another non-EEA country (not including the Principality of Monaco) are underwritten by Aviva Insurance Limited. Risks situated in the EEA and the Principality of Monaco are underwritten by Aviva Insurance Ireland Designated Activity Company.

We may share your Personal Information with other companies in the Aviva group. Each Aviva group company that processes your Personal Information is responsible for looking after it in accordance with this Privacy Policy. For information about Aviva please visit the Aviva website.

A third party company (or companies) may underwrite aspects of your insurance policy and will also be acting as controller(s) of your Personal Information. Please check the documentation that we provide to you for details of the other company(ies). If you want to know more about the controller(s) of your Personal Information, please contact us using the details below.

We have separate privacy policies for our different types of products, so if you have a number of Aviva products you may need to review more than one privacy policy. We may also supplement this Privacy Policy with additional privacy notices tailored to our specific relationships with you where this is useful to provide you with a full picture of how we collect and use your Personal Information. This Privacy Policy supplements – but doesn’t override – them.

Most of the Personal Information we collect relates to the individual who is taking out a policy (or other individuals, where it’s taken out jointly or otherwise for the benefit of others). We may also ask for Personal Information about other individuals if we need it. For example, if you ask us to provide insurance for someone other than you, such as family members or employees. If you provide us with Personal Information about someone else, we’ll assume that you have their permission, where required. We’ll process their Personal Information according to this Privacy Policy so please encourage them to read it if they want to find out more.

2. Personal Information We Collect and How it is Used

Sources of Personal Information

We may obtain Personal Information directly from you, including from applications and claims forms you complete, communications between us, your participation in market research, your use of our apps and websites, as well as details from the devices you use to interact with our apps and websites. We also obtain Personal Information about you from insurance brokers, financial advisers or our business partners where you have purchased a product through one of those intermediaries. 

Where you are a joint policyholder, named driver, additional traveller or otherwise a beneficiary under a policy, we will also obtain Personal Information from the named policyholder or the intermediary the policyholder purchased the product through. 

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

  • Aviva group companies who may provide information in relation to other products you hold, previous claims, policies or quotes; 
  • Third party insurers where they underwrite your insurance policy or aspects of your insurance policy;
  • Third parties who provide you with services relating to your product or claim, e.g. roadside assistance providers and travel assistance providers;
  • Third parties who provide us, or a third party insurer relevant to your product or claim, with services, e.g. loss adjusters, claims handlers (e.g. CEGA Group Services Limited), legal advisers, assistance providers, experts (including medical experts) and, in limited circumstances, private investigators; 
  • Third parties involved in your product or claim, e.g. other insurers, brokers, assistance providers, advisers, claimants, defendants and witnesses to an incident;
  • Healthcare providers and medical practitioners; 
  • Credit reference agencies; 
  • Financial crime, fraud or uninsured detection agencies, databases and sanctions lists, including the Motor Insurers' Bureau (MIB) who are the data controller for the Motor Insurance Database (MID), National Sira (a syndicated fraud prevention database operated by Synectics Solutions Limited), the Claims and Underwriting Exchange (CUE), Motor Insurance Anti-Fraud Theft Register, MyLicence, Whiplash Reforms Programme, Employers' Liability Tracing Office (ELTO) and Insurance Fraud Bureau (IFB);
  • Government agencies and regulatory bodies including the police, the courts, the Driver and Vehicle Licensing Agency (DVLA), Driver and Vehicle Agency Northern Ireland (DVA), Driver and Vehicle Standards Agency (DVSA), the Department for Work and Pensions (DWP), Companies House, the National Health Service 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), the Financial Ombudsman Service (FOS) and the Central Bank of Ireland (CBI) and any other applicable regulators in your country of domicile;
  • If you are a service provider, such as a medical expert or solicitor, regulators who regulate how you operate, including the General Medical Council and the Solicitors Regulation Authority;
  • Insurance industry bodies, including the Association of British Insurers and the MIB;
  • Debt advisors, including where breathing space is requested on outstanding debts; 
  • Third parties who help us maintain the accuracy of our data, e.g. by identifying individuals who are deceased, updating contact details for individuals who have moved and payment card providers who provide us with updated payment card details;
  • Other third party service providers, including actuaries, auditors, legal advisers and other professional service firms and sanctions checking service providers;
  • Data suppliers, e.g. LexisNexis, TransUnion and Barbour ABI; 
  • Publicly available sources including HM Land Registry, 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. LinkedIn, Twitter, Facebook and Instagram); and
  • Third parties in connection with any acquisition of a business by us.

Types of Personal Information collected

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, e.g. family members on a joint insurance policy, people employed by you;
  • Contact data – includes your address, telephone number and e-mail address;
  • Identification data – includes government issued identification numbers, e.g. your national insurance number, passport number, driving licence number (in relation to motor insurance), NHS numbers and other identifiers, e.g. usernames and social media identifiers;
  • Appearance and behavioural data – includes your gender, age, general interests, descriptive data (e.g. your height), images, demographic data and behavioural data (e.g. how often and where you travel);
  • Product data – includes information about quotes, policies, schemes and claims, and any other information relevant to your product, including renewal dates, policy and claim histories. For home insurance, this can also include planning applications, property valuations, surveys and the value of your home contents. For travel cover, this can also include details of your travel arrangements;
  • Occupiers (in relation to home insurance) – data regarding other occupiers of your property, e.g. family members or lodgers;
  • 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, e.g. witnesses;
  • 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;
  • Education and employment-related data – includes your education, vocational and professional qualifications, employment status, job title, salary and employment and educational history;
  • Vehicle and driving-related data (in relation to motor insurance) – includes driving licence entitlement and restrictions or endorsements, driving convictions, vehicle details including registration number and MOT details, vehicle ID number, digital location ID and dash cam footage;
  • Financial data – includes credit and payment card numbers, bank account details, payment information, whether you provide a continuous payment authority, tax information, details of income, assets and, in relation to home insurance, mortgages;
  • Credit assessment data – includes information received from credit agencies, e.g. details of bankruptcy orders, voluntary arrangements and county court judgments. For further information see Credit Reference Agencies;
  • 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;
  • Authentication data – includes account log-in information, passwords and memorable data for accessing your Aviva accounts;
  • Telephone recordings and online chat transcripts – information obtained during recordings of telephone calls or online chats with our representatives and call centres;
  • Customer feedback – includes responses to surveys, complaints and details of your customer experience.

Information provided by third parties, including:

  • Data about your vehicle, e.g. details about your MOT, your vehicle's mileage and information about the features of your vehicle, e.g. engine capacity (in relation to motor insurance);
  • Data about your property, e.g. whether it has a flat roof, whether it is listed, energy performance information and information about planning applications (in relation to home insurance);
  • 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. 
  • Data about the area you live in, e.g:
    • crime-related data;
    • census data;
    • house prices;
    • your council tax band;
    • subsidence data;
    • average garden size;
    • geographical area information and distance to various features, such as the coast, fire stations;
    • modelled data which predicts characteristics about people in your area such as socio-economic groups as well as likely habits; and 
    • flooding and weather-related data.

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:

  • Data relating to other Aviva policies or previous Aviva interactions – 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. For example, we use claims data to identify customers who are likely to claim more than others.

Information inferred from your Personal Information, including:

  • Appearance and behavioural data – includes your general interests, descriptive data and behavioural data, e.g.to allow us to make certain predictions and assumptions about your attitude to risk;
  • 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:
    • Motor insurance:
      • where a child is insured on an adult's policy;
      • where a child takes out a policy with us, e.g. car insurance for under 18s;
      • where a child is a claimant;
    • Home insurance:
      • where there are children living in the property;
    • Travel cover:
      • where a child is insured on a policy;
      • where a child is a claimant.

Sensitive Personal Information

Sometimes we will request or receive Personal Information that is sensitive and we call this “Sensitive Personal Information”. This can be 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 bodily injury claim, we’ll need to ask you to provide details of the injury;
  • we may hold information about any health condition or disability that has required an adaptation to your home (in relation to home insurance).

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 include:

  • Health data – includes details of existing and previous physical or mental health conditions, health status, test results, medical diagnoses and treatment, e.g. personal injuries sustained as a result of a motor accident or public liability claim under home insurance;
  • Criminal data – includes driving licence endorsements, fixed penalties or pending prosecutions for any motoring offences for any of the persons insured, or to be insured, and in relation to detecting and preventing fraud;
  • Other sensitive data – in limited circumstances we may process other Sensitive Personal Information, e.g. information relating to your religious beliefs where relevant to your preferences regarding medical treatment.

Uses of Personal Information

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 pay your claim or pursue any losses against you or a third party, provide you with our products and services and on what terms. For further information, see Automated Decision Making;
  • Process payments when you purchase a product or service and any refunds;
  • Provide our products and services, including insurance administration, taking payment, 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. MyAviva;
  • Manage relationships with third parties, e.g. insurance 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 calls;
  • Conduct customer analysis, market research and focus groups, including customer segmentation, campaign planning, creating promotional materials, gathering customer feedback and customer satisfaction surveys;
  • Help us better understand our customers and improve our customer engagement, including noting your interest in our website, understanding your customer journey, and use of profiled data (which is not actual information about you but predictions about you, e.g. assumptions about your interests based on the preferred leisure pursuits of households in your area). This allows us to make correlations about our customers to improve and promote our products and to suggest other products, services and information which may be relevant or of interest to customers;
  • 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 the section on Data Rights below;
  • 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 ICO, FCA, PRA and CBI, MIB 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.

Lawful Bases for uses of Personal Information

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 help us better understand our customers and improve our customer engagement, including by carrying out analysis and profiling, e.g. by making certain predictions and assumptions about your interests;
  • To comply with our legal and regulatory obligations, guidelines, standards and codes of conduct, e.g. background checks and 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 your policy record 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 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 and services, e.g. by carrying out market research.

Our lawful bases for the use of Personal Information:

Purpose Lawful Basis for Personal Information Processing
Communicate with you and others including complaints handling Performance of a contract
Compliance with a legal obligation
Legitimate interests
Identifying individuals requiring additional support Compliance with a legal obligation
Legitimate interests
Evaluating your application or renewal to provide a quote Performance of a contract
Legitimate interests
Provision and administration of a policy including taking payment Performance of a contract
Compliance with a legal obligation
Legitimate interests
Managing third party relationships e.g. brokers Performance of a contract
Legitimate interests
Claims assessment and management of claims Performance of a contract
Compliance with a legal obligation
Legitimate interests
Financial or other crime, fraud and credit checks Performance of a contract
Compliance with a legal obligation
Legitimate interests
Compliance with legal or regulatory obligations Compliance with a legal obligation
Establish, enforce or defend legal rights Compliance with a legal obligation
Legitimate interests
Improving quality, training and security Legitimate interests
Managing our business operations e.g. accounts, financial analysis, internal audit Compliance with a legal obligation
Legitimate interests
Data analysis (including modelling)  Legitimate interests
Applying for or claiming on our insurance Legitimate interests
Buy, sell, transfer or dispose of our business  Compliance with a legal obligation
Legitimate interests
Archiving, research or statistical purposes Legitimate interests

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 below lawful bases where we process Sensitive Personal Information. The applicable lawful basis may depend on your country of domicile.

  • You have given Aviva explicit consent to process your Sensitive Personal Information;
  • Reasons of substantial public interest (UK domiciled customers only):
    • 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 for a contract of insurance (UK, Ireland and Spain domiciled customers only) – may include 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;
  • 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;
  • Necessary to protect your vital interests or those of another individual;
  • Information has been clearly or obviously made public by you; and
  • Processing of criminal data as authorised by applicable law.

Our lawful bases for the use of Sensitive Personal Information:

Purpose Lawful Basis for Sensitive Personal Information Processing
Communicating with you and others including complaints handling Explicit consent
Necessary for insurance purposes
Legal claims
Necessary for safeguarding economic well-being of certain individuals
Identifying customers requiring additional support Necessary for safeguarding economic well-being of certain individuals
Necessary for the equality of opportunity or treatment
Explicit consent
Evaluating your application or renewal or to provide a quote Explicit consent
Necessary for insurance purposes
Legal claims
Providing and administrating a policy, including taking payment Explicit consent
Necessary for insurance purposes
Managing third party relationships, e.g. brokers Explicit consent
Necessary for insurance purposes
Claims assessment and management of claims Explicit consent
Necessary for insurance purposes
Legal claims
Vital interests
Identifying or investigating financial or other crime and fraud Necessary for insurance purposes
Legal claims
Regulatory requirement relating to unlawful acts or dishonesty
Clearly or obviously made public by you
Prevent or detect crime
Prevent fraud
Authorised by law
Necessary for safeguarding economic well-being of certain individuals
Compliance with legal or regulatory obligations Necessary for insurance purposes
Legal claims
Regulatory requirement relating to unlawful acts or dishonesty
Authorised by law
Establishing, enforcing or defending legal rights Legal claims
Improving quality, training and security Explicit consent
Legal claims
Managing our business operations, e.g. accounts, financial analysis, internal audit Explicit consent
Legal claims
Data analysis (including modelling) Explicit consent
Necessary for insurance purposes
Applying for or claiming on our insurance Explicit consent
Necessary for insurance purposes
Legal claims
Buying, selling, transferring or disposing of our business Explicit consent
Necessary for insurance purposes
Legal claims
Archiving, research or statistical analysis Necessary for archiving, research or statistical analysis

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 using the details below.

3. Who Personal Information is Shared With

In connection with the purposes set out above, we will sometimes share Personal Information with Aviva group companies and third parties, including:

  • Insurance brokers, financial advisers and business partners who help us arrange, manage and underwrite our products and who provide insurance services;
  • Other insurers (either directly or via those acting for the insurer);
  • Our insurers or reinsurers (either directly or through insurance brokers), who provide reinsurance services to us and each other in respect of risks underwritten by Aviva, or insurers who cover Aviva under our group insurance policies. We can supply on request further details of the insurers and reinsurers we provide your Personal Information to and how this may be used. If you require further details, contact us;
  • Third parties who provide you with services relating to your product, e.g. roadside assistance providers, travel assistance providers and healthcare providers;
  • Third parties who provide us, or a third party insurer relevant to your product or claim, with services, e.g. loss adjusters, claims handlers, assistance providers, third-party case managers handling your care or treatment pathway, experts and, in limited circumstances, private investigators; 
  • Medical professionals, if we need to access health records or assessments for the purposes of handling claims;
  • Legal advisers, accountants, financial institutions, auditors and professional service firms who act on our or your behalf, or who represent a third-party claimant;
  • Data analysts and providers of data services who support us with developing our products and prices;
  • 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 and payment card providers who provide us with updated payment card details;
  • Financial crime detection agencies, financial services organisations, sanctions checking providers and third parties who maintain fraud detection databases or provide assistance with investigation in cases of suspected fraud;
  • Regulators who regulate how we operate, including the FCA, PRA, FOS, HMRC, ICO, the Advertising Standards Authority, CBI and any other applicable regulators in your country of domicile;
  • Government agencies and regulatory bodies including the police, courts, DVLA, DVA, DVSA and the DWP;
  • Debt advisers, including where breathing space is requested on outstanding debts;
  • Insurance industry bodies, including the Association of British Insurers and the MIB; 
  • Credit reference agencies;
  • Service providers, including those who help operate our IT and back office systems, underwriting and claims processes and our information security controls and card payment processors;
  • Medical professionals, if we need to access health records or assessments for the purposes of arranging and underwriting certain products or facilitating and handling claims;
  • Clinicians, including hospitals and third party case managers from whom you and others covered under the policy receive insured treatment or who manage your care or treatment pathway;
  • Research agencies and providers of market research services, including customer feedback surveys; and
  • Third parties in connection with any sale, transfer or disposal of our business. 

Some of the organisations we share information with may be located outside of the UK and the EEA. For further information, please see the section on International Data Transfers.

4. Fraud and Other Financial Crime

We use your Personal Information to detect and prevent fraud and other financial crime, including to meet our statutory and regulatory responsibilities in relation to fraud and financial crime.

If you’re making an application or a claim, we may use profiling and other forms of automated processing to assess the probability that your application or claim may be fraudulent. This assessment may involve the use of Sensitive Personal Information or criminal data. For example, we may use your past motoring convictions for motoring insurance or details of any convictions relating to fraud or dishonesty. See Automated Decision Making for further details.

We also use your Personal Information to help us detect fraud committed by brokers or financial advisers. 

To prevent, detect and investigate fraud, we:

  • check public registers (e.g. the electoral roll or registers of county court judgments, bankruptcy orders or repossessions);
  • conduct online searches from websites, social media and other information-sharing platforms;
  • use databases managed by credit reference agencies, insurance industry bodies, fraud detection agencies and other reputable organisations. This includes National Sira administered by Synectics Solutions Limited (as joint data controller together with contributing companies, including Aviva), Experian whose Privacy Policy can be viewed here and the IFB whose Privacy Policy can be viewed here; and
  • share Personal Information and undertake searches with other third parties, including other insurers, fraud prevention agencies, law enforcement agencies, public bodies and our regulators (which include the FCA, PRA, ELTO, CBI, MIB and ICO).

This will help us verify your identity, make decisions about providing you with our products and related services, e.g. paying claims and trace debtors or beneficiaries. 

If you give us false or inaccurate information and we suspect fraud, we’ll record this to prevent further fraud and money laundering. This may be shared between insurers and with fraud prevention agencies and databases.

We can supply on request further details of the agencies and databases we access or contribute to and how this information may be used. If you require further details, please contact us using the details below.

For details relating to information held about you by the DVLA please visit https://dvla.gov.uk/ (in relation to motor insurance, UK domiciled customers only).

How your Personal Information is used and shared by insurers and databases in relation to motor and home insurance (UK domiciled customers only)

The Personal Information you provide will be used by us and shared with other insurers as well as certain statutory and other authorised bodies for:

  • Insurance underwriting purposes, i.e. to examine the potential risk in relation to your (and/or a third party’s) prospective policy so that we can:
    • consider whether to accept the relevant risk;
    • make decisions about the provision and administration of insurance and related services for you (and members of your household);
    • validate your (or any person or property likely to be involved in the policy or claim) claims history (at any time including upon application for insurance, in the event of an accident, incident or a claim, or a mid-term adjustment, or at a time of renewal).
  • Management information purposes. To analyse insurance and other markets for the purposes of:
    • portfolio assessment;
    • risk assessment;
    • performance reporting;
    • management reporting.
  • Anti-Fraud purposes. To detect and prevent fraudulent claims and/or activities by:
    • sharing information about you with other organisations and public bodies including the police;
    • tracing debtors or beneficiaries, recovering debt, managing your accounts and/or insurance policies;
    • undertaking fraud searches. Insurers pass information to fraud prevention agencies and databases including National Sira, the CUE Register and where appropriate the Motor Insurance Anti-Fraud and Theft Register by MIB. This helps insurers check information and prevent fraudulent claims. When we deal with your request for insurance we may search these registers. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
  • Compliance with legal obligations and responsibilities, including:
    • claims management – In the event of a claim we may need to disclose information with any other party involved in that claim, e.g. third parties involved in the incident, their insurer, solicitor or representative and medical teams, the police or other investigators. We also may have to investigate your claims and conviction history;
    • complaints management – If you make a complaint about the service we have provided, we may be obliged to forward details about your complaint, including your Personal Information, to the relevant ombudsman.
    • in relation to motor insurance, information about your insurance policy will be added to the MID managed by the MIB. MID and the data stored on it may be used by certain statutory and/or authorised bodies including the police, the DVLA, the DVA, the IFB and other bodies permitted by law. This information may be used for purposes permitted by law, which include:
      • electronic licensing;
      • continuous insurance enforcement;
      • law enforcement (prevention, detection, apprehension and/or prosecution of offenders);
      • the provision of government services and/or other services aimed at reducing the level and incidence of uninsured driving.

If you are involved in a road traffic accident (either in the UK, the European Economic Area or certain other territories), insurers and/or the MIB may search the MID to obtain relevant information.

Individuals who may be citizens of other countries or their appointed representatives making a claim in respect of a road traffic accident may also obtain relevant information which is held on the MID. It is vital that the MID holds your current registration number. If it is incorrectly shown on the MID you are at risk of having your vehicle seized by the police and/or a fixed penalty notice.

You can check that your current registration number details are shown on the MID at https://www.askmid.com/

How your Personal Information will be processed (in relation to motor insurance, UK domiciled customers only)

  • Information which is supplied to fraud prevention agencies and databases, e.g. National Sira, MIB and MID can include details like your name, address and date of birth.
  • Your data may be supplied to databases in order to facilitate automatic no claim discount validation checks.
  • Your data may be transferred to any country, including countries outside of the UK and European Economic Area, for any of the purposes mentioned above.
  • Under your policy you must tell us about any incident (e.g. an accident or theft) which may or may not give rise to a claim. When you tell us about an incident, we will pass information relating to it to the fraud prevention agencies and databases, e.g. MIB.

You can ask for more information about this. If you require such information, please contact us using the details below.

How we use your Driving Licence Number (in relation to motor insurance, UK domiciled customers only)

We collect your Driving Licence Number (DLN) for insurance underwriting purposes, i.e. to examine the potential risk in relation to your (and/or a third party’s) prospective policy so that we can:

  • Provide your (or any person included on the proposal) DLN to the DVLA to confirm your (or the relevant person included on the proposal) licence status, entitlement and relevant restriction information and endorsement/conviction data. Searches may be carried out prior to the date of the insurance policy and at any point throughout the duration of your insurance policy including at the mid-term adjustment and renewal stage. A search of the DLN with the DVLA should not show a footprint against your (or another relevant person included on the proposal) driving licence.
  • Searches may be carried out at point of quote and, if an insurance policy is incepted, if any changes are made mid-term, and at renewal stage.

Please note that if you give us false or inaccurate information it may invalidate your insurance policy/prospective insurance policy or it could affect the amount we pay to settle any claims you make under the policy.

5. Credit Reference Agencies

To ensure we have the necessary facts to assess your insurance risk, verify your identity, help prevent fraud and provide you with our best premium and payment options, we may need to obtain information relating to you at quotation, renewal and in certain circumstances where policy amendments are requested. We or our agents may undertake checks against publicly available information (e.g. the electoral roll, county court judgments, bankruptcy orders or repossession(s)). Similar checks may be made when assessing claims.

Information about the credit reference agency we use and the ways in which they use and share Personal Information, are explained in more detail on the TransUnion website.

6. Automated Decision Making

We may use automated processes to make decisions. These automated processes use data provided by you, other records we hold about you in our systems and data sourced from third parties to make predictions, including the likelihood that a claim will be made and its value, the likelihood a product will be purchased and the likelihood that a claim might be fraudulent. This helps us to determine eligibility for a policy, the terms of the policy, the price, and whether we can provide you with a monthly credit payment option.

In relation to home insurance only, in order to provide you with a price for your policy, the following steps may be taken:

  • Information about you: The first step is that we know who you are and what you are looking to have insured, e.g. details about your property. 
  • We enrich the information: We carry out checks to validate your information (e.g. confirming your identity) and enrich it with data from third party sources. Information on the third party data sources we use is set out above in Types of Personal Information collected. For example, we use your address to source additional information on the area you live in, such as the distance of your property from a fire station.
  • We calculate your insurance risk: We use statistical modelling techniques to assess the information in order to predict the likelihood that a claim will be made and the likely severity of a claim. This assessment is based on various factors including information about the area you live in such as the likelihood of crime. For example, if you live in an area with high property crime this may lead to a higher premium. All insurers will use different weightings to price insurance and this is confidential to each insurer.
  • Provision of the final price: Once we have a view of your insurance risk we can provide you with a final price, which will include any commission payments and applicable tax.

We may also make automated decisions throughout the life of your policy, e.g. before offering you a renewal or when dealing with a claim.

Where we make an automated decision using Personal Information which has a legal or substantially similar effect, you have certain rights in relation to that decision. In particular, you have the right to receive meaningful information about the logic involved in relation to the decision, the right to human intervention and the right to obtain an explanation of the decision and challenge it. For more information about this right and how to exercise it please see the section on Data Rights below.

7. Profiling and Data Analysis

We use profiling and other data analysis to build, train and audit our insurance models and algorithms (including those used in our Automated Decision Making) and our machine-learning tools. The models, algorithms and tools we use help us do a number of things including:

  • understanding our customers and potential customers better, e.g. how they feel about Aviva, what kind of content or products would be of most use and interest to them, whether they might be displaying characteristics meaning that they may require additional support from us; and
  • predicting the likelihood of events arising to assess insurance risk, the likelihood a product will be purchased or to predict if a claim might be fraudulent.

We use a number of data items as described in this Privacy Policy for these purposes. Before we use any such data, we carry out checks, including ensuring there are no legal restrictions on using the data under data protection laws, the Equality Act 2010 or under FCA rules, and we consider whether use of the data might cause outcomes that are unfairly or unlawfully biased. We then use statistical modelling techniques to assess the data to ensure that the data tells us something meaningful. From time to time, we may share your Personal Information with third parties who provide us with new data which we will test to understand if such new data provides additional understanding.

We may also use profiling and data analysis for other reasons, e.g.to ensure data quality and accuracy and to help us improve our business. 

The purpose of this analysis is not to make decisions about you directly, but your Personal Information, in combination with Personal Information relating to other customers, potential customers and/or data provided by third parties, will be used to conduct data analysis so that we can improve our processes, our products and services and check the way our models, algorithms and machine-learning tools work. The Personal Information you submitted to obtain a quote from us may be used for this analysis whether or not you decided to purchase the product.

Where possible, we pseudonymise the Personal Information in order to perform this analysis. This means that we remove information from which you can be directly identified, e.g. your name, and replace it with a pseudonym or unique identifier. We do this to maximise the security of your information.

8. Retention

We keep Personal Information for as long as is reasonably required for the purposes explained in this Privacy Policy. We also keep records – which may include Personal Information – to meet legal, regulatory, tax or accounting needs. For example, we are required to retain an accurate record of your dealings with us, so we can respond to any complaints or challenges you or others might raise later. We’ll also retain files if we reasonably believe there is a prospect of litigation. The specific retention period for your Personal Information will depend on your relationship with us and the reasons we hold your Personal Information.

To support us in managing how long we hold your data and our record management, we maintain a data retention policy which includes clear guidelines on data retention and deletion.

If you would like more information about our data retention policy, please contact us.

9. International Data Transfers for Private Clients

Sometimes we, or third parties acting on our behalf, may need to transfer Personal Information outside of the UK or European Economic Area (EEA). We’ll always take steps to ensure that any transfer of Personal Information outside the UK or EEA is carefully managed to protect your privacy rights and ensure that adequate safeguards are in place. This might include transfers to countries that the UK or EEA considers will provide adequate levels of data protection for your Personal Information or putting contractual obligations in place with the party we are sending information to. Transfers within the Aviva group will be covered by an agreement entered into by members of the Aviva group (an intra-group agreement) which contractually obliges each group company to ensure that your Personal Information receives an adequate and consistent level of protection wherever it is transferred within the group.

For more information about data transfers and the safeguards we have put in place, please contact us using the details below.

10. Data Rights for Private Clients

You have legal rights under data protection laws in relation to your Personal Information. Read below to learn more about each right you may have.

We may ask you for proof of identity when you make a request to exercise any of these rights. We do this to ensure we only disclose information to the right individual.

We aim to respond to all valid requests within one month. It may take us longer if the request is particularly complicated or you have made several requests. We’ll always let you know if we think a response will take longer than one month. We may also ask you to provide more detail about what you want to receive or are concerned about.

We may not always be able to do what you have asked. This is because your rights will not always apply, e.g. if it would impact the duty of confidentiality we owe to others, or if the law allows us to deal with the request in a different way. We will always explain to you how we are dealing with your request. In some circumstances (such as the right to erasure or withdrawal of consent), exercising a right might mean that we can no longer provide our product to you.

For further information about or to exercise any of your rights, please contact us using the details below.

Your rights are as follows:

Access to your Personal Information

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 below.

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.

Rectification of your Personal Information

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.

Erasing your Personal Information

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.

Restricting processing of 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.

Data portability

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.

Right to object

You can 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.

Automated decision making and profiling

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.

Withdrawing consent

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.

11. Contacting Aviva and Supervisory Authorities

If you have any questions about this Privacy Policy or how to exercise your rights, please contact our Data Protection Officer: 

Write to: The Data Protection Team, Aviva, PO Box 7684, Pitheavlis, Perth PH2 1JR

Email us: DATAPRT@aviva.com

If you'd like to submit a subject access request, please fill out this form or write to us at the above address.

If you’re not happy with the way we’re handling your Personal Information, you have a right to make a complaint with your local data protection supervisory authority at any time.

We ask that you please attempt to resolve any issues with us before contacting your data supervisory authority.

12. Updates

This Privacy Policy is updated from time to time to take account of changes in our business activities, legal requirements and to make sure it’s as transparent as possible, so please check back here for the current version. You can see when this Privacy Policy was last updated by checking at the top of this page.