1. Our Responsibilities to You and Your Personal Information
At Accelerant, we collect and use personal information about individuals, including insured persons, claimants, business partners and other third parties. We take our responsibilities to handle your personal data in accordance with data protection laws very seriously. As part of our responsibility, it is important that we provide you with the information in this notice so that you understand how, why and when we collect, use and retain your personal information, your rights in relation to that information and the conditions under which we may disclose your personal information to third parties. This Information Notice sets out how we collect and use your personal data.
Under data protection law, we are required to provide you with a lot of information about how we collect and use your personal data. It is easy for all this information to become confusing rather than helpful.
We therefore use a layered approach to provide you with the information required by law. This means that we may provide the information required in a number of different formats and documents. In particular, it means that, in our initial contact with you, we may provide you only with the most important information about how we will use your personal data; but we will always provide you with easy access to all the further information you need about our privacy practices.
Please read this Information Notice carefully.
2. Who Are We?
Accelerant is the brand name used to refer to companies within the Accelerant Holdings Group. We, Accelerant Insurance Limited, underwrite insurance business via delegated authority. We also work through a network of business relationships that we establish with the insurance market participants who we may rely upon to underwrite and administer policies and adjudicate claims on our behalf. The Accelerant entity that originally collected information from you will be principally responsible for managing your personal information.
3. What Information Do We Collect?
The type of personal information we collect about your will depend on your relationship with Accelerant.
If you are an insurance person or potential insured, we collect personal information of the policyholder, prospective insured and related individuals in order to determine the eligibility to underwrite and administer insurance policies. In some instances, we may need to collect special category data such as health information or criminal history.
If you are making a claim under your insurance policy that was placed by Accelerant, we may need to collect your contact information, as well as information about your claim and previous claims. We may also need to collect special category data such as health information or criminal history, depending on the nature of your claim. For further details on the types of personal information we may collect about you, please see below to view the table.
If you are a witness and we receive your information in relation to a claim being made under a policy of insurance, we may need to collect your contact information, as well as further information about you. We may also need to collect special category data such as health information depending on the nature of the information you are providing us.
If you visit our websites (NOTE: WE DON’T DO THIS YET), personal data collected by us may automatically include technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform. Personal data collected by us also may automatically include information about your visit, including the full Uniform Resource Locators (URLs); clickstream to, through and from our site (including date and time); what you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks and mouse-overs); and methods used to browse away from the page.
If you are a business partner, we will collect your business contact details and other details that you provide to us.
The personal data we collect about you:
|Type of Personal Data||Details|
|Individual details||Name, address (including proof of address), other contact details (e.g., email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to you|
|Identification details||Identification numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving licence number|
|Financial information||Bank account or payment card details, income or other financial information|
|Risk details||Information about you that we need to collect in order to assess the risk to be insured and provide a quote. This may include data relating to your health, criminal convictions, or other special categories of personal data. For certain types of policies, this could also include telematics data|
|Policy information||Information about the quotes you receive and policies you take out|
|Credit and anti-fraud data||Credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to you.|
|Previous and current claims||Information about previous and current claims (including other related insurances), which may include data relating to your health, criminal convictions, or other special categories of personal data and, in some cases, surveillance reports|
|Special categories of personal data||Certain categories of personal data, which have additional protection under the GDPR. The categories are health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation.|
4. Where Do We Get Your Personal Data From?
We might collect your personal data from various sources, including:
- Your family members, employer or representative;
- Your use of our website;
- Other insurance market participants;
- Our business partners;
- Credit reference agencies;
- Anti-fraud databases, sanctions lists, court judgements and other databases;
- Government agencies such as the DVLA and HMRC;
- Open electoral register;
- Regulators, including the Financial Conduct Authority (FCA), Information Commissioner’s Office (ICO) and the Prudential Regulation Authority (PRA); or
- In the event of a claim, third parties including the other party to the claim (claimant/defendant), witnesses, experts (including medical experts), loss adjustors, solicitors, and claims handlers
It will depend on your particular circumstances which source we will get your personal data from.
5. The Reasons Why We Collect Your Information
Quotation and inception
- Setting you up as a client, including possible fraud, sanctions, credit and anti-money laundering checks
- Evaluating the risks to be covered and matching the appropriate policy/premium
- Payment of premium where the insured/policyholder is an individual
- Client care, including communicating with you and sending you updates
- Payments to and from individuals
- Managing insurance and reinsurance claims
- Defending or prosecuting legal claims
- Investigating or prosecuting fraud
- Contacting the insured/policyholder to renew the insurance policy
- Evaluating the risks to be covered and matching appropriate policy/premium
- Payment of premium where the insured/policyholder is an individual
- To provide information to our service providers, auditors, contractors, agents and group companies that perform activities on our behalf
- General risk modelling
- Transferring books of business, company sales and reorganisations
- Complying with our legal and regulatory obligations
- Managing our business relationship with you
- Direct marketing
6. Our Legal Grounds of Processing
We will only use your personal data when the law allows us to do so. In general, we will use your personal data:
- 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;
- Where we are processing your personal data for an insurance-specific exemption provided by laws enacted by specific European Union Member States, which permits us to collect and use your special category data; or
- Where you have given your consent.
In some circumstances, applicable data protection laws may require us to obtain your consent to the processing of your personal data. Where this is the case, we will ask you for your consent in accordance with those laws. You may withdraw your consent to such processing at any time. This will not affect the lawfulness of any processing that took place before your consent was withdrawn.
Please note that if you withdraw your consent in relation to an insurance policy that we are administering or a claim that we are handling, then this is likely to impact our ability to administer that insurance policy and handle claims. In order to provide insurance cover and deal with insurance claims in certain circumstances, insurance market participants may need to process your special categories of personal data, such as medical and criminal convictions records, as set out against the relevant purpose.
Your consent to this processing by an insurance market participant may be required for the insurance market participant to process your special categories of personal data.
When calculating insurance premiums, insurance market participants may compare your personal data against industry averages going forward. This is known as profiling and is used to confirm that the premium amount reflects the associated risk.
Profiling may also be used by insurance market participants to assess information that you provide, in order for us to identify and understand fraud patterns. Where special categories of personal data are relevant, such as medical history or past convictions for certain types of insurance, your special categories of personal data may also be used for profiling.
We might make some decisions based on profiling and without staff intervention (general known as automated decision-making). In response to your request, we will provide details to you of any automated decision-making undertaken without staff intervention, including:
- Where automated decision-making is applied;
- The type of logic involved;
- The consequences of the application of automated decision-making; and
- The identity of any facility that you may contact in order for you to have the logic explained to you and to submit further information so that the decision may be reconsidered.
8. Retention of Your Information
We will retain your personal data only for so long as is necessary and for the purpose for which it was originally obtained, in accordance with our data retention policy .
In particular, your personal data will be retained for so long as there is any possibility that either you or we may wish to bring a legal claim under this insurance, or where we are required to keep your personal data for legal or regulatory reasons.
9. Transferring Your Information Outside the EU
We may need to transfer your personal data to one of our branches outside the European Economic Area (EEA) or to insurance market participants or their affiliates or sub-contractors that are also located outside the EEA. For the purposes set out above, we may transfer your personal data to our group companies, service providers, business partners and governmental or public authorities located in other countries.
Where your personal data is transferred to a destination outside the European Economic Area (EEA), local laws may provide for a lower standard of protection for personal data than is applicable within the EEA. We therefore require our group companies and third parties to have appropriate safeguards in place so that your personal data is protected. These appropriate safeguards include the use of European-approved model contract clauses. If you would like further details of how your personal data will be protected by us if it is transferred outside of the EEA, please contact us or the relevant insurance market participant.
10. Your Rights
If you have any questions in relation to our use of your personal data, you may contact us using the contact details set out in Section 13 Contact Details. You may have the right to require us to:
- Provide you with further details on the use we make of your personal data/special category of data;
- Provide you with a copy of the personal data that you have provided to us;
- Provide you with a copy of the personal data that you have provided to us;
- Update any inaccuracies in your personal data that we hold;
- Delete any special category of data/personal data that we no longer have a lawful ground to use;
- Withdraw – where processing of your personal data is based on your consent – your consent so that we stop that particular type of processing;
- Object to any processing of your personal data based on the legitimate interests ground, unless our reasons for performing that processing outweigh any prejudice to your personal data protection rights; and
- Restrict how we use your personal data, while a complaint that has been submitted by you is being investigated.
In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege).
11. Your Right to Complain to the ICO
If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights, or if you think we have breached the applicable data protection law requirements, then you have the right to complain to the ICO. The ICO’s contact details are as follows:
Information Commissioner’s Office
Tel: 0303 123 1113 (local rate) or 01625 545 745
Fax: 01625 524 510
The Information Commissioner’s Office – Scotland
45 Melville Street
Telephone: 0303 123 1115
Information Commissioner’s Office – Wales
2nd Floor, Churchill House
Telephone: 0330 414 6421
The Information Commissioner’s Office –
Telephone: 028 9027 8757 / 0303 123 1114
12. Direct Marketing and Email Marketing
We may also use your contact information to provide you with information about our products and services that we think may be of interest to you. We may contact you about the by email, if you have previously consented to this or the information relates to products or services previously purchased by you.
Where this is the case, our legal basis for processing is our legitimate interests in carrying out marketing activities.
We will get your express opt-in consent before we share your personal data with any company outside Accelerant for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Our contact details are in Section 13 Contact Details below.
13. Contact Details
For all details regarding compliance with data protection laws, please contact our Head of Compliance by the following means:
Head of Compliance
Accelerant Insurance Limited
14. Key Terms
|Insurance market participants||An intermediary, such as a broker or coverholder, who helps you arrange your insurance cover or handle claims, or an insurer or reinsurer.|
|Personal data||Any information relating to an identifiable person who can be directly or indirectly identified|
|Special category data||Certain categories of personal data, which have additional protection under the GDPR. The categories are health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation.|
|We, us||Accelerant Insurance Limited|
|You, your||An insured person or potential insured, beneficiary (someone who has an interest under the insurance policy), a witness, or a claimant making a claim under and insurance policy|