Consumer privacy notice
This notice describes how we collect, store, use and share personal data. It also explains the rights you may have in relation to the personal information that we hold about you. It applies to personal data provided to us directly and indirectly, both by you, and by others on your behalf.
1. Who we are
Throughout this notice, when we say ‘we’ or ‘us’ we’re referring to the Royal London Mutual Insurance Society Limited, a company registered in England and Wales, authorised and regulated by the FCA (registration number:99064).
This is the ‘parent’ company of the Royal London Group and is your main point of contact for all of our companies. We have several different companies who sit underneath. Within the Royal London Group, one or more of the following authorised and regulated firms will process information to provide your products and services:
- Royal London Marketing Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales number 4414137.
- Royal London Savings Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales number 3642633.
- Royal London Asset Management Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales number 2244297.
- Royal London Marketing (CIS) Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales number 3390839.
- RLUM (CIS) Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales number 2369965.
- Royal London (CIS) Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales number 8629353.
2. What is personal data and why do we collect and process it?
Personal data is defined under the General Data Protection Regulation (GDPR) as any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
In essence, personal data is your personal information. Please see section 3 below for the type of personal data that we collect. We collect and process personal data primarily in order to provide you with our products and to administer a policy you have with us. Section 4 of this privacy notice tells you what you can expect us to do with your personal data when you make contact with us or use one of our services.
3. What kinds of personal data do we hold about you?
When we collect your personal data, we’ll let you know if any of it is optional. If it is, we’ll explain why it would be useful to us, and you can decide whether it’s something you’re happy for us to have.
Dependent on the type of product and service provided we may collect and process the following personal data about you:
- Information about you - such as your name, age, gender, date of birth, work/profession, hobbies and nationality.
- Special category data - this is personal data that needs more protection because it is sensitive. Where it is relevant to your policy, we will collect information relating to your medical history, health, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, and biometric data, where it is used for identification purposes.
- Government identifiers – for example, information from your identification documents, such as your driving license, National Insurance number or passport.
- Contact information – for example, your address, email address and phone numbers.
- Online information – for example Cookies and IP address (your computer’s internet address), if you use our websites.
- Financial information – for example salary and your bank account details for any payments you make to us or we make to you. If we need to verify information on your finances, we will require copies of your financial accounts.
- Telephone calls or video recordings – for example voice recording when you contact us, complete a survey at the end of a call to our Customer Services Team or CCTV footage if you visit our offices.
- Contractual Information – for example details about your products and benefits.
- Family & beneficiaries’ information – for example your marital status, dependants, next of kin, family medical history or nominated beneficiaries. If you provide information on another individual it’s important you ensure they are aware of the detail you`ve provided to us. Their personal data will be processed in accordance with this Privacy Notice, so please let them know it’s important that they read this policy.
4. How we use your personal data
We use your personal data for a number of reasons:
- Providing a quote, underwriting, processing your application, setting up and administering your policy We need this information to help us calculate your premium. For larger cases we may need additional financial information. We use this information to establish if, and on what terms, we can offer you insurance cover.
- Completing any requests, making and receiving payments, or managing any queries or claims you make.
- Verifying your identity, preventing fraud and financial crime.
- Researching our customers’ opinions and exploring new ways to enhance the servicing experience we provide to meet your needs.
- Assessing, developing and managing our products, systems, prices, our business and brand.
- Fulfilling any other legal or regulatory obligations.
- Sending you information relating to your product.
- Telephone calls may be recorded to allow you to give us instructions by phone, to analyse, assess and improve our customer service, for training and quality purposes, to manage complaints and to protect you and your information from fraud and financial crime.
- Identifying vulnerable customers to help determine whether we need to take further steps to ensure these customers are not disadvantaged in any way. (please refer to section 10 for further information).
- Automated decision making as part of our sales process when you receive a quote and profiling as we may make an assumption on you (please refer to section 10 and 11 for further information).
- Sending you marketing information by post, or where you have provided permission to be contacted by email, text and other electronic means – you can easily change your mind and “opt out” of receiving marketing information by emailing us: GDPR@Royallondon.com or ringing us on 0345 602 1885. If you’re a member, sending you membership information and managing your rights.
- We also use your information to create “lookalike audiences” to help us target campaigns to new people who are similar to our best customers.
- Managing the relationship with your Financial Adviser, if you have appointed one.
- Monitoring the use of our websites – for further information please see our Cookies Policy
5. Where do we get your personal data from?
Most of the personal data we get comes directly from you when you apply for one of our products or services, or from your Financial Adviser if you have appointed one. We may also, where necessary, obtain personal data about you from other sources.
- Medical professionals – for example if we need information to set up your policy or to support a claim. We will only do this if you provide us with consent.
- Premium quotation services - If you used an introducer or a quotation service (price comparison website) to obtain premium quotes for you, the service provider will share some of your information with us.
- Tracing companies - if we lose touch, we may use a trusted 3rd party to find you and reunite you with your policy, if we can.
- Data brokers
- if it’s necessary and reasonable to obtain contact information (email and phone numbers) to carry out customer research, promote brand awareness or remind you about the benefits of your plan; or;
- to help put our customers into groups for product development and assessment purposes.
- Affinity partnerships - where you have taken a policy out via one of our partnerships, we will receive your information from them. Further information on the partnership will have been provided when you took out the policy.
- Introducers – if you receive a quote from one of our introducers or a price comparison website.
- The policyholder to the policy, on behalf of another person covered or a beneficiary.
- ‘Third party’ cookies` - to collect information on how visitors use our website. Our Cookies Policy can give you more information.
- Publicly available information - including social media websites and online content, newspaper articles, television, radio and other media content, court judgements, public registers, electoral register and specialist databases (for example Companies Registration Office, and Dow Jones).
7. What are our legal grounds for using your personal information?
The GDPR and associated legislation sets outs specific grounds under which your personal data may be lawfully processed. The legal grounds for the processing of personal data by us will depend on the purpose for which the processing is being carried out.
We`ll only use your personal data when one of these grounds has been satisfied. Below you can see how we use your personal data and the legal grounds for processing this:
Use of your information
Buying in Information
We may obtain your email address from data brokers if, for example we’d like to use it for a research project. We will ensure the data broker has obtained your consent to the sharing of your information.
To set up your policy we may need to contact a medical professional or your GP. However, we will only do so when you provide consent, by signing our declaration form.
In order to assess a claim, we will also ask for your consent before we contact your medical practitioner or your GP so they can provide the necessary information.
If you wish to avail of our Helping Hand service, we will need your consent to pass your contact details to Red Arc who administer the service.
We process your information to be able to treat you as a vulnerable customer (if due to personal circumstances you are in a vulnerable position). You may, at your discretion provide us with this type of information on a voluntary basis and based on your consent.
Where appropriate, we may also contact you, and send marketing communications which may be of interest, if you have given us consent to do so. (Further information on marketing can also be found in the Legitimate Interest section below)
On our website we use ‘third party’ cookies that collect information about how visitors use our website. Please see our Cookies Policy for further information.
Your personal data may be processed when we receive your consent.
The consent you provide must be freely given, informed, specific, unambiguous and given with a positive affirmative action.
Your consent can be withdrawn at any time.
Setting up and administering your policy
This covers all the usual activities, such as
Completing any requests or claims you make
If we lose touch
We may use a trusted 3rd party to find you and reunite you with your policy.
Necessary for the performance of a contract
The personal data you provide or that of a joint party to the contract may be processed when it is necessary to enter into or perform a contract. E.g. where we process your information to assess your application, calculate your premium or to provide your policy.
We use your personal data & special category data, where necessary, to comply with legal obligations including:
Necessary for compliance with a legal obligation
Your Personal data may be processed where Royal London has a legal obligation to perform such processing.
|We may disclose your information to the Police or other authorities if we have serious concerns about your wellbeing.||
Necessary to protect vital interests
This will usually only apply in "life‑or-death" scenarios.
In certain cases, and where necessary, the special category data provided may be processed for the following purposes:
Necessary to provide legal advice and legal proceedings
The 2018 Data Protection Act provides legal grounds for processing special category data (medical information) for legal advice and legal proceedings.
The medical information you, or your medical practitioner, or GP provided will be used, where necessary, for underwriting your policy or for claims assessment.
In certain cases, the information provided may be for another individual or family member who is party to your policy.
We’ll also obtain information from a medical professional in the event of a death claim.
We’ll share your information with our reinsurers for example, if we need another opinion or on specialist cases.
Necessary for an insurance product
The 2018 UK Data Protection Act also provides legal grounds for processing your special category data (medical information) in connection with an insurance or pension product.
Necessary for legitimate interests
We also use your personal data when we have a “legitimate interest” and that interest isn’t outweighed by your privacy rights. Each activity is assessed, and your rights and freedoms are considered to ensure that we’re not being intrusive or doing anything beyond your reasonable expectation. We’ll assess the information we need, so we only use the minimum.
If you want further information about processing under legitimate interests, you can contact us using the details below.
You also have the right to object to any processing done under legitimate interests. We’ll re-assess the balance between our interests and yours, considering your particular circumstances. If we have a compelling reason, we may still continue to use your personal data.
We use legitimate interests for the following:
|Use of your personal data||Legitimate interests|
Our products are developed with a particular set of customer needs in mind. In order to make sure your policy is still suitable for you and is working as we intended, we combine your information with other customers to analyse and segment it.
We’ll use your underwriting responses and claims information to analyse how we can redesign products or make our underwriting process easier, with better outcomes for potential and existing customers and policyholders.
To assess and develop our products, systems, prices, business and brand
We need to be able to identify groups of customers who will want new products or services that we are considering developing.
We need to develop those products and services, and make sure our product charges are fair.
We need to make sure we are treating you fairly and check your product is suitable for you.
We need to make sure that we are looking after your money and that we have enough money to pay our customers when the time comes.
We collect and provide service information on your policy.
We financially assess the performance of our business; we conduct risk management exercises and we carry out long-term statistical modelling.
We manage our network and information security (for example: developing, testing and auditing our websites and other systems, dealing with accidental events or unlawful or malicious actions.)
We use CCTV at our premises.
We share your information with Royal London Group and our service providers. Your data will only be transmitted within the Group and to our service providers when appropriate safeguards, including contractual provisions, are in place.
To manage our business:
To improve our service quality and for training purposes.
To help us understand our risks, provide management information and help us to manage our business.
To ensure that our systems are always secure and that your data is always protected.
To prevent and detect fraud, dishonesty and other crimes (for example, to prevent someone trying to steal your identity).
To protect our staff and visitors for health and safety reasons and security purposes.
For internal administrative, audit, statistical, or research purposes. Where possible, we will make your data anonymous.
We may conduct research before we launch new products or before we make changes or improvements to existing products to make sure it’s the right thing to do. We might also conduct research to ask customers what they think of Royal London, our products and services.
Where we don’t have your contact details, we may obtain your telephone number from data brokers to contact you for a research project. However, we always take steps to check that you have not objected to such contact, e.g. by checking the National Directory Database.
To research our customers’ opinions and new ways to meet our customers’ needs
We need to make sure our products are suitable for the intended audience and to identify gaps in the market.
We need to see how many categories of customers we have and to tailor our products and services accordingly.
We need to make sure our communications are easy to understand and that our products are being sold to the correct audience.
We need to make sure our research is efficient and connects with the right types of people, so we can be confident of any decisions we make based on the results.
8. Overseas Transfers
We sometimes use third parties located in other countries to provide support services. As a result, your personal data may be processed in countries outside the European Economic Area (EEA).
These services will be carried out by experienced and reputable organisations on terms which safeguard the security of your information and comply with the European data protection requirements. Some countries have been assessed by the European Commission (EC) as being ‘adequate’, which means their legal system offers a level of protection for personal information which is equal to the EC’s protection. Where the country hasn’t been assessed as adequate, the method we have chosen to safeguard your information is ‘standard contractual clauses’ within the legal agreement to safeguard the processing of your personal data.
The European Commission and the UK have recognised ‘standard contractual clauses’ as offering adequate safeguards to protect your rights and we’ll use these where required ensuring adequate protection for your information as prescribed by the GDPR. The European Commission approved standard contractual clauses are available here.
We use ‘standard contractual’ clauses for the below activities, to help us provide:
- IT support and technology development with operations based in India.
- Reassurance services with our global reassurance partners who have operations based in the United States and Bermuda.
- Services with other providers/suppliers, research partners and administrators who have operations based in India and the United States.
We will always ensure your personal data is provided with adequate protection and all transfers of personal information outside the EEA are done lawfully.
We have put in place security measures designed to prevent your Personal Data and Special Categories of Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We use Transport Layer Security (TLS) to encrypt and protect email traffic. We also use the Clearswift Managed Email Security Service to protect our outgoing email traffic. However, if your email service doesn’t support TLS or if you do not wish to use our Clearswift Managed Email Security Service, we may not be able to communicate with you by email, and any emails we do send or receive will not be protected by encryption, and could be intercepted. We may also change our Email Security Service provider at any time without notice and without changing the provision in this notice.
Once we receive your information, we use strict procedures and security features to protect your information from unauthorised access.
In the event of a potential data security breach we will notify you and the Data Protection Commissioner’s Office if we are legally required to do so, or there is a risk to your rights and freedoms as a result of the breach.
10. How long do we keep personal information for?
We will retain your personal data for as long as it is considered necessary for the purpose for which it was collected, and to comply with our legal and regulatory requirements. This will involve retaining your personal data for a reasonable period of time after your policy or your relationship with us has ended.
In the absence of specific legal, regulatory, contractual requirements or technical reasons, your personal information is kept for 7 years after our relationship with you has ended.
There are some exceptions to this rule:
- We are running a programme as part of our need to treat our customers fairly. Until this finishes, we’ll be keeping your information beyond seven years.
- The Financial Conduct Authority requires us to keep some pension transfer information indefinitely.
- If you applied for a quote for one of our Consumer products we will keep your details on file for two years. This is for analysis purposes so we can develop our business and also for marketing purposes, if you have not opted out of receiving these communications.
- As part of our business we undertake specific research and statistical analysis for underwriting, actuarial and pricing purposes. In this event we may retain minimised personal data, some of which may be medical information. The use of this data will not be used to make a decision against you.
- Where there is a dispute, legal or otherwise, between us which requires us to keep your personal information.
11. Do we make solely automated decisions about you or profile you?
Automated decisions are where a computer makes a decision about you without a person being involved. We also profile our customers, which means we make assumptions about you to help us treat you fairly.
We make automated decisions about you as part of the underwriting journey. We ask relevant information about your job, interests, travel, health and family history – for example we need to know if one of your interests is skydiving, as this would increase your risk and potentially your premium.
You have the right to ask for a person to review the automated decision, so you can also ask for the decision to be made via our manual underwriting process
There are some cases where we won’t be able to offer a decision online and will need your application to be reviewed by our underwriting team. They may request further information from you or from your medical professional before we’ll be able to confirm whether we can offer you cover, and on what basis.
We will undertake checks for the prevention and detection of crime as we are required by law to do so. These checks use automated means to make decisions about you. This may result in declining the services you requested and stopping services currently provided to you. Please see section 11 “your rights” for further information.
The Financial Conduct Authority defines a vulnerable consumer as someone who, due to their personal circumstances, is especially likely to experience disadvantage. It’s been identified a lot of people will be vulnerable at some point in their life, so we need to make sure we can identify who these customers are and support them.
We’ve created our own method, using socio-economic data from Experian and additional research with consumers, to help us assess levels of vulnerability within the UK population. We then use this information to help identify how many of our customers are likely to be more vulnerable, and ensure our products are designed with this in mind. For example, we may provide additional information on our statements where we suspect our customers might be less financially capable or less engaged in financial matters.
In the future we’d like to keep a note of the category you fall into, against your records, so we can tailor our communications to suit you. Before we do this, we’ll assess if this is fair.
Socio economic profiling
We may analyse your personal data to create a profile so that we can contact you with information relevant to you. When building a profile, we use Experian software, to provide us with insight into our customers. The software uses a variety of publicly available and market research sources to divide the population into a series of categories. The categories are a way of grouping people who are likely to have similar social, demographic (i.e. age, location) and financial circumstances. The results are assessed and combined so we get a picture of our customers as a whole, and tailor the products and services we provide. Please see section 11 “What are my rights” for further information.
In the future we’d like to keep a note of the category you fall into, against your records, so we can tailor our communications to suit you. Before we do this, we’ll assess if this is fair.
In the future we’d like to keep a note of the category you fall into, against your records, so we can tailor our communications to suit you. Before we do this we’ll assess if this is fair.
12. What are my rights?
Your rights are outlined below. The easiest way to exercise any of your rights would be to contact our Data Protection Officer at the contact details provided. We will provide a response within 30 days, if not sooner. There is normally no charge for exercising any of your rights. We may ask you for proof of identity when you request to exercise some of these rights to ensure we are dealing with the right individual.
Access to your personal information
You have the right to find out what personal data we hold about you, in many circumstances. Please see section 15 below for our contact details.
Correcting or adding to your personal information
If any of your details are incorrect, inaccurate or incomplete you can ask us to correct them or to add information.
Withdrawing your consent
If you have provided consent for us to use your personal data, you have the right to withdraw your consent at any time. If you withdraw consent, then we may not be allowed to use your data going forward. However, it would not invalidate any processing that was carried out before you withdrew consent.
Withdrawal of consent may impact the product and services we can provide to you, or the ability to administer your policy such as a claim. In this event, we will let you know what the impact would be.
Transferring your personal data to another organisation (Data portability)
In some circumstances you can ask us to send an electronic copy of the personal data you have provided to us, either to you or to another organisation.
Objecting to the use of your personal data for legitimate interests
You also have the right to object to any processing done under legitimate interests. We will re-assess the balance between our interests and yours, considering your particular circumstances. If we have a compelling reason, we may continue to use your personal data, if that reason is not outweighed by your privacy rights. However, we will inform you of that decision and reasoning for continuation of processing.
Objecting to direct marketing
You have a specific right to object to our use of your personal data for direct marketing purposes, which we will always act upon.
Objecting to automated decision making
You have a right to object if we have made an automated decision, including profiling, which has legal and significant effect against you. You may also have the right to challenge the decision and ask for a human review. These rights do not apply if we are authorised by the law to make such decisions and appropriate safeguards are in place to protect your rights.
Restricting the use of your personal data
If you are uncertain about the accuracy or our use of your personal data, you can ask us to stop using your personal data until your query is resolved. We will let you know the outcome before we take any further action in relation to this data.
Right to Erasure
You can ask us to delete your personal data in some circumstances, such as if your policy has ended and we do not need to keep it for legal or regulatory reasons. If we are using consent to process your personal data and you withdraw it, you can ask us to erase it.
14. Changes to our Privacy Notice
Making sure that we keep you up to date with privacy information is a continuous responsibility and we keep this notice under review. We will update our notice as changes are required.
If we need to use your personal data for a new purpose which we haven’t previously told you about, we will contact you to explain the new use of your data. We will set out why we are using it and our legal reasons.
This privacy notice was last updated on the 25th September 2020.
15. Contact us
If you have any questions or comments regarding this privacy notice, or if you are unhappy about the way Royal London uses your information, please contact us using the details below.
Post: Data Protection Officer, Royal London, Royal London House, Alderley Park, Congleton Road, Nether Alderley, Macclesfield, SK10 4EL.