A-Plan Holdings UK Privacy Notice - v2.3

Introduction

This privacy notice tells you what you can expect us to do with personal information we hold on you, what kinds of information we hold, how we receive it and who we receive it from. It also explains who else we may share your information with, and gives you details about your data rights and how you may use them.

This privacy notice is updated from time to time, to reflect any changes in how we use and handle personal information. If we make any significant changes, we will let you know directly.

This version of the privacy notice was published on the 3^rd April 2023. It contains updates to reflect recent additions to the trading names we are known by, and changes in our wider group of companies. We haven’t made any significant changes to the ways we use your personal data, or the kinds of organisations we share your information with since the previous version of our privacy notice was published. 

A few definitions

To be clear on what we mean in this privacy notice:

• “we” and “us” means A-Plan Insurance;
• “Howden UK & Ireland” means the Howden UK & Ireland group of companies, which includes A-Plan Insurance. You can find a list detailing all the companies in this group by clicking here;
• “the Howden Group” means Howden Group Holdings Limited and any company or organisation in which Howden Group Holdings Limited holds significant share capital, which includes Howden UK & Ireland. You can find more information about the other companies in the Howden Group by visiting howdengroupholdings.com;
• “third-party” means someone who isn’t you, us, Howden UK & Ireland or the wider Howden Group.

Who does this privacy notice relate to?

This privacy notice relates to the following types of individuals, where we hold your personal information:

• Individuals who are clients, including prospective clients who have received an insurance quotation, former clients who have previously held an insurance policy with us, and client representatives, for example those with power of attorney;
• Our business/corporate clients and their employees, including prospective and former clients and client representatives;
• Visitors to our websites;
• Individuals who contact us with a query, concern or complaint;
• Individuals named on our insurance policies, such as named drivers, joint policy holders, or beneficiaries;
• Individuals who request information from us or permit us to contact them for marketing purposes;
• Third parties who make a claim against, or are subject to a claim from one of our policyholders in relation to a collision, accident or other insured event.

Customers of our Endsleigh Loop and Ingenie brands can find bespoke information about how these telematic insurance products work in our product-specific privacy notices, available below.

To view the Endsleigh Loop privacy notice, click here.

To view the Ingenie privacy notice, click here.

There are other types of individuals who this privacy notice does not relate to, for example A-Plan employees and sub-contractors (including prospective and former employees and sub-contractors), employees of our current, former or prospective business partners and service suppliers, and members of the press.

If you are one of these individuals and would like further information on how we collect, use and store your data, please contact us. Our contact details are shown in the “how you can contact us” section of this notice.

A bit about us

Who we are

We are A-Plan Insurance.

• Our full company name is A-Plan Holdings;
• We are registered in England under company number 00750484.
• Our registered office address is 2 Des Roches Square, Witney, OX28 4LE, UK;

You can find more information about our financial service and data protection registrations, as well as our international representatives, in the “ ” section of this notice.

We trade under a number of brands which incorporate the A-Plan name, and are also known by the following other trading names and brands:

Allstyles	Cherished Vehicle Insurance Services
CLAi	CLA Insurance Services
Classic & Collectors	Clubcare Insurance Services
Countryside Alliance Insurance Services	Crusader Leisure Vehicle Insurance
Diversity Insurance	Donecomparing.com
Endsleigh Loop	Endsleigh Select
Endsleigh Young Driver	Faith Insurance
Family Insurance Services	Fire Insure
Golfplan	Golfplan Insurance Services
Golfplan International Golf Insurance Services	Golfplan International Insurance Services
Health Service Discounts	Home Direct
Howden	Howden Insurance Services
Ingenie	IngenieTemp
Instructor Cover Plus	Insurance for Caravans
Insurance for Holiday Homes	Insurance for Homes Abroad
Insurance for Trailer Tents	LeasePlan Fleet Insurance Services
Maserati Insurance Services	Motor Direct
Motorhome Direct	NHS Insure
Nurse Insure	Oliver & Sanders
Personal Insurance Partners	Pol Plan
Police Insure	Primo
R K Harrison	RH
RH45	RH Classic
RH Classic Vehicle	RH Specialist Vehicle
Sheltons	Shield Total Commercial Insurance Services
Shield Total Insurance	TR Register Insurance Services
Trust a Trader Insurance	Vint-tro Cover
Watkin Davies Insurance Consultants	Whitehouse

How you can contact us

We take data privacy seriously and your opinion matters to us. If you have any questions about this policy or how we use your information you can contact us in the following ways:

In branch: You can find your nearest A-Plan branch by using our branch locator tool available here.
By e-mail: privacy@aplan.co.uk
By telephone: 01993 893311
By post: A-Plan Insurance, 2 Des Roches Square, Witney, OX28 4LE, UK

If you have a current insurance policy with us, you can also contact the relevant branch or office directly, by using the contact details shown in your policy documents.

Our Data Protection Officer

As part of Howden UK & Ireland, A-Plan Insurance’s Data Protection Officer is Jonathan Cumpstey. He can be contacted in the following ways:

By e-mail: dpo@aplan.co.uk

By post: FAO The Data Protection Officer, Howden UK & Ireland, 2 Des Roches Square, Witney, OX28 4LE, UK.

What information we collect and how we use it

We collect your information and use it in different ways depending on your relationship with us and how you have interacted with us. This can include information we share with or receive from other third parties.

The lawful ways we use your data

We use your information for the following lawful reasons:

• To enter into or perform a contract; for example, to provide you with an insurance quotation, to start, change or cancel an insurance policy, to manage any claims which arise, to answer any queries you may have, action your requests or perform any debt recovery.
• To comply with a legal obligation; for example, the rules set by our regulator the Financial Conduct Authority (FCA), to fulfil your data rights under data privacy laws, handle complaints about data privacy or our financial products and services and to comply with other legal requirements;
• For our legitimate business interests; for example, to detect and prevent fraud, money laundering and other financial crimes, monitor and improve our business and our products and services, demonstrate compliance with applicable laws and regulations, handle legal claims, respond to other types of complaint not previously mentioned, and some marketing activities. Where we rely on this lawful reason, we assess our business needs to ensure they are proportionate and do not affect your rights. In some instances, you also have the right to object to this kind of use. For more information, visit the “Your data rights” section of this notice.
• With your consent; for example, when you ask us to provide you with information or permit us to contact you for marketing purposes. You can withdraw your consent at any time, for more information please visit the  “Your data rights” section of this notice.
• To protect vital interests: in extreme or unusual circumstances, we may need to use your information to protect your life or the lives of others.

When we collect your personal data

We collect personal data from you when:

• You request an insurance quotation from us, either directly or via a third-party price comparison website when they have permission to share your information with us;
• When you are named on the insurance policy of another individual, for example as a named driver on a vehicle insurance policy, a joint policy holder, or a beneficiary;
• You purchase, change or cancel an insurance policy;
• We need to manage a claim made against your policy or that you bring against one of our policyholders;
• You contact us to request information or to make a complaint;
• You visit our website or the websites of other Howden UK & Ireland companies;
• You take part in a competition, prize draw or survey;
• You visit one of our stands and give us your information, for example at a show or trade fair;
• You have given permission to other companies to share your information with us;
• You have made your information publicly available, and we have a legitimate reason to review it.

We also collect your information from other third-party sources where we have legal grounds to do so. These include anti-fraud and crime-prevention agencies, credit reference and vetting agencies, and other data providers.

We use cookies (small text files stored in your web browser) and other techniques to monitor how you use our website. For more information on what these are and how to opt out of these, please see our Cookies Notice, available here.

What information we use and hold about you

Depending on your relationship with us, we may hold the following types of information about you:

Identity and contact data: for example, your name, date of birth, postal address, telephone number and e-mail address. 

Payment and account data: for example, your bank account details, credit/debit card details and information about your purchases with us, including any payment plans or arrears. 

Location data: for example, your postal or IP address, the location of any insured property, and in the event of a claim, where the collision, theft or other incident occurred. 

Correspondence data: for example, copies of letters and e-mails we send you or you send to us, and notes or call recordings of any telephone conversations. 

Internet data: for example, information collected by cookies and other online technologies such as Facebook pixels and Google Analytics, as you use our website or contact us by online methods.

You can find more information about the information we collect using cookies and other technologies in our Cookies Notice, available  . 

Information we obtain from other sources; including credit agencies, anti-fraud and other financial crime prevention agencies, price comparison websites, and other data providers. This can include demographic data and interest-based data. 

Complaint data: for example, what the complaint was, how we investigated it and how we resolved it, including any contact with the Financial Ombudsman Service or other third-party adjudicator services.

Some of our processes combine different sets of information we hold. This can include combining different data sets we have about you, or combining your information with that of other individuals.

Sensitive personal data

to your health and any medical conditions, or data relating to criminal convictions. We only collect this information where it is relevant to do so, such as:

• When it is relevant to the type of insurance you are enquiring about, have purchased, previously held or that you have been named on;
• When it is relevant to a claim you have made or that someone else has made against you;
• Where it is relevant to a complaint or issue you have raised with us, and;
• To arrange alternate forms of correspondence for you, such as Braille, audio format or Touch-Type services.

Certain types of information are known as “special categories” under data protection law, and receive additional protection due to their sensitivity, for example information that reveals your race or ethnicity, your political views or your religious beliefs. We only use these types of data with your explicit consent, or to protect your vital interests or when it is necessary to meet a lawful purpose under the current legislation.

Who we share your information with

Where applicable, we share your personal information with the following types of third parties when we have a valid reason to do so;

• Other companies in Howden UK & Ireland and/or the wider Howden Group;
• Business partners, brokers, intermediaries, suppliers and agents involved in delivering products and services to you, including additional products purchased alongside your insurance policy such as breakdown cover or legal expenses cover;
• Price comparison websites and other similar companies who offer ways to research and apply for financial products and services;
• Credit reference, credit scoring and fraud prevention agencies;
• Debt collection agencies;
• Law enforcement, government bodies, regulatory organisations, courts and public authorities, for example the Financial Conduct Authority (FCA), The Financial Ombudsman Service, The Information Commissioner’s Office (ICO) and HMRC;
• Our panel of insurers and, where necessary, other insurers and those acting on their behalf, for example loss adjusters, solicitors and claims experts;
• Centralised insurance databases such as the Claims and Underwriting Exchange (CUE), the DVLA/DVA (NI), the Insurance Fraud Bureau (IFB) and the Motor Insurance Database (MID);
• Media agencies and other marketing organisations that we advertise with or conduct marketing activities through;
• A third party where disclosure is required to comply with legal or regulatory requirements;
• Personal representatives appointed by you to act on your behalf, or those appointed to represent a third-party claimant.

Our websites may also share information with Google via the use of internet cookies, where you have agreed to this. You can find out more information about how Google uses data collected by cookies on Google’s Privacy & Terms site, available here.

Transferring data internationally

For business purposes, to help prevent/detect crime or where required by law or regulation, we may need to transfer your personal data internationally. Where we do this, we will ensure that your information is protected in accordance with the applicable data protection requirements.

If the data protection laws of the country that the recipient of your data is based in are not recognised as providing sufficient protection by relevant laws, we will ensure that the recipient enters into a formal and enforceable legal agreement that reflects the standards required.

You have the right to ask us for more information about the safeguards we use when sending your personal data overseas. You can request more information by contacting us on the details shown in the “how you can contact us” section of this notice.

Retaining and destroying data

We retain information about you and the products you purchase to meet a number of legal and regulatory requirements, as well as our own legitimate business interests. For the period we retain your information, it is held securely by us or by third-party service suppliers contracted to store it on our behalf.

You can request further information about our retention periods and the data sets that they apply to by contacting us on the details shown in the “how you can contact us” section of this notice. 

Automated decision-making and profiling

We use the information you provide to build a profile of you. We use this to assess whether we are able to offer you an insurance product and to determine the specifics of an insurance policy, for example the premium you pay and the compulsory excess for any claim. Much of the use of your data is done by “automated means” (done by computer without significant intervention by human beings), and this includes some of the decisions we make using your information, for example whether we can offer you insurance cover, the premium you pay and the terms of the policy.

You have rights in relation to automated decision-making and profiling. See the “your data rights” section of this notice for more information. 

Your obligation to provide information to us

Where we collect information from you in relation to insurance, you are under a legal duty to give us information.

If you are a personal client – that is, someone buying insurance which is wholly or largely unrelated to their profession, you are under a legal duty to answer all questions we ask fully and honestly, to the best of your knowledge. This is known as a “duty to take reasonable care not to make a misrepresentation”, and is a requirement of the Consumer Insurance (Disclosure & Representations) Act 2012.

Business and commercial clients are under similar duty, known as “fair presentation”. This means that, in addition to answering our questions fully and honestly, you must also make reasonable searches for and disclose any significant or material facts which are relevant to the insurance being arranged. This includes reasonable searches of information available to other interested parties, such as agents and other people or organisations covered by the insurance, and is a requirement of the Insurance Act 2015.

We will provide you with further information on these legal duties, including which duty is applicable to you, when we arrange your insurance.

Failing to answer all questions asked fully and honestly, and failing to make reasonable searches or disclose material facts relevant to the insurance policy if you are a business client, may lead to a higher premium being payable, special terms or a higher excess being imposed, or the policy being cancelled or voided.

Your data rights

Data protection law gives you rights relating to your personal information. This section gives you an overview of these and how they relate to the information you give us.

The UK supervisory authority for data rights, the Information Commissioner’s Office (ICO), has also published detailed information about your rights on their website: www.ico.org.uk under the section entitled “for the public”.

Your right to access

You have a right to request copies of the personal information we hold on you, along with meaningful information on how it is used and who we share it with.

This right always applies, but there are some instances where we may not be able to provide you with all the information we hold. For example, we may not be able to provide you with your personal data where doing so could have an adverse impact on one or more of the following:

• The privacy, rights or freedoms of other individuals;
• The prevention and detection of crime, including financial crimes such as insurance fraud and money laundering;
• Legal professional privilege, or;
• Negotiations with the individual(s) concerned.

The above list is illustrative only and is not exhaustive, but it does give the most-common scenarios that arise in connection with insurance.

Normally, we will tell you if we are unable to provide you with some or all of your personal data and explain why when we respond to your request, unless the relevant laws or regulations prevent us from doing so.

Your right to rectification

If information we hold is inaccurate or incomplete, and this has an impact on the way we are using your data, you have the right to have any inaccuracies corrected and for any incomplete data to be completed.

If you ask us to rectify your information, we will either confirm to you that this has been done, or if there is a valid reason that this cannot be done, we will let you know why.

Your right to erasure (the right to “be forgotten”)

You have the right to request that your personal information is erased in certain circumstances, for example if the data is no longer needed for the purpose(s) it was originally collected for.

If you ask us to erase your information, we will either confirm to you that this has been done, or if we are unable to delete it, let you know why and also inform you how long we will hold it for. For more information, see the “retaining and destroying data” section of this notice. 

Your right to restrict processing

You can ask us to restrict the use of your information in certain circumstances.

If you ask us to restrict your information, we will either confirm to you that this has been done, or if we are unable to restrict it, we will inform you why.

Your right to object to direct marketing

You can always object to receiving direct marketing from us.

If you do so, we will ensure that you do not receive such material going forward, unless you change your mind and specifically request it in the future.

Your right to object to automated decision-making

You can object to decisions made about you using your information and undertaken by purely automated means.

If you do so, we will arrange for someone to assess the automated decision and confirm the outcome of this assessment to you.

Your right to challenge our legitimate interests

You can challenge the use of your personal data where we use a legitimate business interest as a lawful basis to process your information. You can find more information on when we use this lawful basis in the “lawful ways we use your data” section of this notice. 

If you do so, we will either confirm to you that the processing has stopped, or there is a valid reason for the processing to continue, we will inform you why.

Your right to object to the use of your information for statistical purposes

You can object to us using your information for statistical purposes in some instances.

If you do so, we will either confirm to you that the processing has stopped, or there is a valid reason for the processing to continue, we will inform you why.

Your right to data portability

In certain circumstances, you have the right to request that your information be compiled into a common, machine readable format and either provided directly to you or sent by us to a third-party you nominate.

If you request this, we will either act upon your instruction and confirm to you that we have done so, or if there is a valid reason that this cannot be done, we will tell you why.

Your right to complain

If you are unhappy with how we have used your data or if you believe we have failed to fulfil your data rights, you have the right to complain to us, and can contact us to raise your concerns using the details shown in the “how you can contact us” section of this notice. 

If you remain unhappy with our response you may raise a complaint with a supervisory authority responsible for data rights in the public interest. In the UK, this is the Information Commissioner’s Office (ICO). Although they do not award compensation, the ICO can investigate concerns brought to them and take action if they decide that an organisation has failed to meet its data protection obligations. The ICO can be contacted using the following details:

Via their website: www.ico.org.uk
By e-mail: casework@ico.org.uk
By telephone: 0303 123 1113
By post: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.

Exercising your data rights

You can exercise any of your data rights by contacting us using the information in the “how you can contact us” section of this notice and telling us which right (or rights) you would like to exercise.

More information about us

A-Plan Insurance maintains a number of authorisations and registrations in relation to our business:

• We are authorised and regulated by the UK Financial Conduct Authority (FCA) under register number 310164;
• We are registered with the UK Information Commissioner’s Office (ICO) under registration Z7199305;
• We are regulated by the Guernsey Financial Services Commission (GFSC) under reference 2731967;
• We are registered with the Guernsey Office of the Data Protection Authority (ODPA);
• We are regulated by the Jersey Financial Services Commission (JFSC);
• We are registered with the Jersey Office of the Information Commissioner (JOIC) under reference 100159.

For our Guernsey clients, we also maintain a representative in the Bailiwick in accordance with legal and regulatory requirements:

Network Insurance & Financial Planning Limited, Network House, 3 Jubilee Terrace, South Esplanade, St Peter Port, Guernsey, GYl lAH.