Privacy Notice

Type of Personal Data

Examples of data

Additional Support Needs Data (Special Category)

Physical or mental health conditions, cognitive impairments, disabilities, medication or treatment details, financial resilience information to assess support needs, power of attorney declarations, distress or confusion indicators, requests for third-party support or representation, additional support needs

Appearance and Behavioural Data

Height, weight, gender identity, lifestyle data, descriptive characteristics, demographic segment, behavioural profiling, purchase/claim patterns, website pager view

Authentication Data

Passwords, security questions, memorable information

Background Check Data

Disclosure and Barring Check data or similar background checks information 

Claim and Complaint Data

Claim reference number, type of claim (e.g. theft, injury, travel delay), incident date, location, description of loss, alternative insurance coverage

Communication Data

Call recordings, emails, letters, complaint records, instant messaging, social media

Consent and Preference Data

Claim form consents, third-party data sharing authorizations, marketing consent data, cookie consent

Contact Details

Home address, correspondence address, email address, phone number

Credit Assessment Data

Credit score, reports from credit reference agencies, bankruptcy filings, County Court Judgments (CCJs), debt repayment history, financial history

Criminal Offence Data (Special Category)

Criminal convictions or allegations 

Demographic Data

Marital status, country of residence/citizenship, nationality, number of dependents, language preference, title (Mr/Ms), age

Device/Technical Data

Device type, browser type, operating systems, geolocation data, referring websites, IP address, login data (for online claim portals), API failures, usage data, analytics customer ID, metadata

Employment and Occupation Data

Job title, employer details, income, employment status (relevant for income protection or liability claims), employment history, professional qualifications, accreditations and certifications, job description, reasonable adjustments, accidents at work, sickness and unemployment

Financial Data

Bank account details, credit card numbers, premium/payment history, compensation amounts

Fraud & Sanctions Data

Fraud alerts and notifications, sanctions list screening, politically exposed person status (Special Category), publicly available records, sanctions checks

Health Data (Special Category)

Medical conditions and diagnosis, medical reports (e.g., GP or specialist records), hospital records, medical history, disability details, mental health conditions, medication and treatment details, vaccination status, evidence of temporary or long-term illness

Identification Data

Full name, date of birth, gender, national insurance number, identity information (e.g., passport or driving license)

Marketing & Engagement Data

Survey responses, promotional entries, feedback, communication preferences, marketing preferences, trust pilot invitations, newsletter

Photographs and Video Evidence

Images of damage, items you travelled with, images to prove ownership, CCTV footage, dashcam footage, images submitted to support claims

Policy Data

Policy number, policy type, start/end dates, coverage details

Special Categories of Personal Data

Racial or ethnic origin, religious beliefs, sexual orientation if relevant

Third-Party, Associated Person or Dependent Data

Spouse or partner’s name, date of birth, contact details, medical information related to Third Parties (if relevant), travel details, children’s names or ages, next of kin, beneficiaries, travel companions, emergency contact information, grant of probate and executor of the estate data

Travel Data

Departure and return dates, duration of travel, destinations, fight number and booking references, accommodation details, transport arrangements, planned activities, purposes of travel, visa copies, flight tracking data, lounge visits data

Trade Union Membership (Special Category)

Trade Union Membership, Name of the Trade Union

Usage & Interaction Data

Website and mobile app activity logs, session metadata, clickstream data, chatbot interaction records, cookie data, frequency of access, web accessibility customisation data (e.g., for vulnerable customers), traffic source data

Vehicle or Property Data

Vehicle registration, damage reports, repair invoices, property ownership or damage assessments, licenses

Witness Data

Names, contact info, statements from witnesses, details of other parties involved in the claim

Processing activity

Purpose

Personal Data Categories

Legal Basis

Policy Application and Underwriting

To assess eligibility, determine premiums, and issue policies

Additional Support Needs Data, Contact Details, Demographic Data, Employment and Occupational Data, Financial Data, Health Data, Identification Data, Policy Data, Trade Union Membership Data, Travel Data, Usage and Interaction Data, Vehicle or Property Data

Performance of Contract, Legitimate Interest, Consent

Claims Processing and Management

To investigate, evaluate, and settle insurance claims

To assess third-party liability

 To provide regular or emergency medical assistance

Additional Support Needs Data, Claim and Complaint Data, Communication Data, Consent and Preference Data, Contact Details, Demographic Data, Device Technical Data, Employment and Occupational Data, Financial Data, Fraud and Sanctions Data, Health Data, Identification Data, Marketing and Engagement Data, Photographs and video evidence, Policy Data, Third Party, Associated Person or Dependent Data, Trade Union Membership Data, Travel Data, Usage and Interaction Data, Vehicle or Property Data, Witness Data

Performance of Contract, Legal Obligation, Legitimate Interest, Vital Interest

Provision of Travel Disruption Products and Services 

To provide insurance coverage for flight disruption

To track flight to assess eligibility for travel disruption service

Contact details, Identification Data, Travel Data

Performance of Contract

Provision of Medical Assistance

To provide regular or emergency medical assistance

To facilitate identification of available doctors

Additional Support Needs Data, Claim and Complaint Data, Communication Data, Consent and Preference Data, Contact Details, Demographic Data, Device Technical Data, Employment and Occupational Data, Financial Data, Fraud and Sanctions Data, Health Data, Identification Data, Marketing and Engagement Data, Photographs and video evidence, Policy Data, Third Party, Associated Person or Dependent Data, Trade Union Membership Data, Travel Data, Usage and Interaction Data, Vehicle or Property Data, Witness Data

Performance of Contract, Legal Obligation, Legitimate Interest, Vital Interest

Automated decision-making

To assess eligibility and process claims automatically

Additional Support Needs Data, Claim and Complaint Data, Communication Data, Consent and Preference Data, Contact Details, Demographic Data, Financial Data, Health Data, Identification Data, Marketing and Engagement Data, Photographs and Video Evidence, Policy Data, Third-Party, Associated Person or Dependent Data, Travel Data, Usage and Interaction Data, Vehicle or Property Data, Witness Data

Consent

Fraud Detection and Prevention

To detect, investigate and prevent fraudulent claims or activities

Background Checks Data, Claim and Complaint Data, Communication Data, Credit Assessment Data, Criminal Offence Data, Device and Technical Data, Fraud & Sanctions Data, Identification Data

Legal Obligation, Legitimate Interest

Customer Service and Communication

To respond to enquiries, provide assistance, and manage communications

Communication Data, Contact Details, Identification Data

Performance of Contract, Legitimate Interest

Product Marketing and Promotion

To send marketing communications, offers, and gather feedback

Consent and Preference Data, Contact Details, Marketing & Engagement Data

Consent, Legitimate Interest

Regulatory Compliance and Reporting

To comply with legal and regulatory requirements including filing of regulatory reports

Additional Support Needs Data, Claim and Complaint Data, Contact Details, Criminal Offence Data, Financial Data, Fraud & Sanctions Data, Identification Data, Policy Data

Legal Obligation, Legitimate Interest

Risk Assessment and Pricing

To assess risk factors and set pricing for insurance products

Additional Support Needs Data, Appearance and Behavioural Data, Claim & Complaint Data, Demographic Data, Employment and Occupational Data, Health Data, Policy Data, Trade Union Membership Data, Travel Data

Legitimate Interest, Performance of Contract

Customer Account and Online Portal Management

To provide secure access to customer accounts and manage authentication

Appearance and Behavioural Data, Authentication Data, Device/Technical Data, Identification Data, Usage and Interaction Data

Performance of Contract, Legitimate Interest

Provision of assistance for individuals with

additional support needs 

To identify and provide additional support for vulnerable customers

Additional Support Needs Data, Contact Details, Health Data, Identification Data

Legitimate Interest, Consent, Legal Obligation

Data Security and System Monitoring

To secure systems, detect cyber threats, and monitor usage

Authentication Data, Device/Technical Data, Usage & Interaction Data

Legitimate Interest, Legal Obligation

Authorised Representative Submissions & Evidence Handling

To process data related to third parties supporting the claims process for policyholders

Contact Details, Health Data, Third-Party, Associated Person or Dependent Data, Travel Data

Performance of Contract, Legitimate Interest

Product and Pricing Model Development

To enhance or create insurance products and refine pricing through behavioural and risk data modelling

Additional Support Needs Data, Appearance and Behavioural Data, Claims and Complaint Data, Demographic Data, Employment and Occupational Data, Health Data, Identification Data, Policy Data, Trade Union Membership Data, Travel Data

Legitimate Interest

Internal Training and Quality Monitoring

To monitor and improve the quality of services, particularly through review of recorded calls and interactions

Communication Data, Device/Technical Data, Usage & Interaction Data

Legitimate Interest

Legal Claims and Dispute Management

To handle disputes, legal claims, and enforcement

Claim and Complaint Data, Communication Data, Criminal Offence Data, Financial Data, Fraud & Sanctions Data, Identification Data, Policy Data

Legal Obligation, Legitimate Interest

Research, Analytics and Claims Process Evaluation

To assess customer satisfaction with claims processing

To improve products, services, and customer experience

Aggregated or pseudonymised data derived from any of the above categories, Contact Details, Device and Technical Data, Identification Data, Marketing and Engagement Data, Policy Data

Legitimate Interest, Consent

Cookie Category

Explanation

Legal basis

Strictly necessary

Enables core site functions such as navigation, security, and session management.

Legitimate Interest

Functionality

Remembers choices such as language and accessibility settings to provide enhanced features.

Consent, Legitimate Interest

Analytics and performance

Measures usage and helps improve the site by understanding interactions with pages and features.

Consent

Advertising

Tailors content or measures the effectiveness of marketing.

Consent