Privacy policy

The Health Insurance Group ("THIG") respects your privacy and is committed to protecting your personal data.

Please use the glossary to understand the meaning of some of the terms used in this privacy notice.

Purpose of this privacy notice

This privacy notice aims to give you information on how THIG collects and processes your personal data when using our insurance intermediary services, including any data you may provide through our website when you purchase an insurance product or service.

This privacy notice is not intended for children and we do not knowingly collect data relating to children, other than when we place insurance coverage to insured member’s dependent children under our insurance partner’s policy terms and conditions.

It is important that you read this privacy notice, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them unless otherwise stated.

Controller

Health and Protection Solutions Limited is the controller and responsible for your personal data (referred to as, "we", "us" or "our" in this privacy notice).

We will let you know which entity will be the controller for your data when we place an insurance product with an insurance company or you use our intermediary services.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have, any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are: The Health Insurance Group

Full name of legal entity: Health and Protection Solutions Limited

Name or title of DPO: Mike Thomas                     

Postal address: West Park House, 23 Cumberland place, Southampton SO15 2BB          

Email: compliance@healthinsurancegroup.co.uk

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) - the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 17th August 2018

The data protection law in the UK changed on 25 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact data includes billing address, delivery address, email address and telephone numbers.
  • Financial data includes bank account and payment card details.
  • Transaction data includes details about payments to and from you and other details of insurance products and services, you have purchased from us.
  • Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
  • Health data includes any medical or clinical data that we use to arrange your insurance policy.
  • Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature or use of our services. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do collect special categories of personal data about you (this includes details about your sex, ethnicity, age, information about your health and genetic data). We do collect information about criminal convictions and offences for the detection of fraud and to meet our legal obligations for financial sanctions checks by relevant Government Authorities. Where we process special categories of personal data (sensitive data), such as health data, we may rely on one of the legal grounds to do so. Where appropriate we apply an exemption for insurance purposes, or we may ask to obtain your specific consent. For example, we may ask for your constent if we are assisting you in relation to a claim or claims payment or a representative has been appointed to act on your behalf such as the employer or a relative. Please note that in some cases, if you do not provide your consent, we may not be able to provide our intermediary services to you.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, if you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or provide our services to you (for example, to provide you with intermediated insurance services). In this case, we may have to cancel the contract you have with us and the services we provide you with, but we will notify you if this is the case.

2. How we collect personal data

We use different methods to collect data from and about you including through:

  • Direct interactions - you may give us your identity, contact, health and financial data by filling in our application forms or by corresponding with us via post, phone, and email or otherwise. This includes personal data you provide when you:
    • Apply to use our insurance intermediary services
    • Subscribe to our insurance intermediary services
    • Request marketing to be sent to you
    • Enter a competition, promotion or survey
    • Give us some feedback
  • Automated technologies or interactions - as you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources - we may receive personal data about you from various third parties and public sources as set out below:
    • Technical data from the following parties:
      1. Analytics providers such as Google based outside the EU
      2. Advertising networks based inside or outside the EU
      3. Search information providers based inside or outside the EU
    • Contact, financial and transaction data from providers of technical, payment and delivery services based inside or outside the EU.
    • Identity, health and contact data from insurers, reinsurers, aggregators, third party medical claims administrators based inside or outside the EU.
    • Identity and contact data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the insurance intermediary service contract we are about to enter into or have entered into with you.
  • Where we need to assess any information including health data to perform our obligations under the intermediary insurance contract.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new member for our insurance intermediary services

(a) Identity

(b) Contact

(c) Health

Performance of a contract with you

To process and deliver the insurance intermediary services including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us from insurers

(c) process health and medical information as an intermediary

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(f) Contact

(g) Health

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Health

(d) Profile

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our insurance products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our insurance products/services, to develop them and grow our business)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our insurance products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our insurance products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about our insurance services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

  1. Promotional offers from us

    We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

    You will receive marketing communications from us if you have requested information from us or purchased our insurance services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

     

  2. Third-party marketing

    We do not share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by emailing optout@healthinsurancegroup.co.uk or by following the opt-out links on any marketing message sent to you or by contacting us at West Park House, 23 Cumberland place, Southampton SO15 2BB any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of insurance intermediary services provided to you from us, or other related transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 3 above.

  • Internal third parties as set out in the glossary.
  • External third parties as set out in the glossary.
  • Specific third parties such as insurance and reinsurance companies, credit reference agencies and other authorities for legal and compliance purposese.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

We do not currently transfer your data outside the European Economic Area (EEA).

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

We will only retain your personal data for as long as necessary to fulfil the purpose we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law, we have to keep basic information about our customers (including contact, identity, financial, health and transaction data) for six years after they cease being customers for tax purposes.

In some circumstances, you can ask us to delete your data: see request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. More details of these rights can be found below and at www.ico.org.uk. Please see the rights below:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best insurance intermediary service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of the insurance intermediary contract including processing Health data for assessing suitable insurance coverage for you and assessing any claims under the insurance coverage with our insurance partners to which you are a party or to take steps, at your request before entering into such an insurance contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal third parties

Other companies in our Group acting as joint controllers or processors and who are based the United Kingdom and provide IT and system administration services and undertake insurance services.

External third parties

  • Service providers acting as processors [or joint controllers] based in the United Kingdom who provide IT and system administration services for us related to our insurance intermediary services.
  • Insurance companies providing insurance risk coverage and services associated with the medical insurance we place for you as part of our intermediated insurance services we provide you.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local laws. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain insurance products or insurance intermediary services to you. We will advise you if this is the case at the time you withdraw your consent.