Fair Processing Notice
Cigna Insurance Services (Europe) Limited ("CISEL") is committed to ensuring your privacy is protected. This Fair Processing Notice ("Notice") sets out details of the information that we may collect from you and how we may use that information. Please take your time to read this Notice carefully. When using our websites, this Notice should be read alongside the website terms and conditions.
CISEL is part of a wider group of companies (the "Cigna Europe group") and, as set out in more detail in this Notice, personal data is shared between companies within the Cigna Europe group in order to provide you with products and services.
By providing your personal information to us, you acknowledge that we may use it in the ways set out in this Notice. We may provide you with further notices highlighting certain uses we wish to make of your personal information. We may also give you the ability to opt-in or opt-out of selected uses such as marketing when we collect personal information.
From time to time we may need to make changes to this Notice, for example, as the result of government regulation, new technologies, or other developments in data protection laws or privacy generally. You should check the website at https://fpn.cignainsurance.co.uk periodically to view the most up to date Notice.
In this Notice references to "we" or "us" or "CISEL" are to Cigna Insurance Services (Europe) Limited and, from 31 Aug 2020, Cigna European Services Limited (CESL) which, from that date, administrates retention of customer information and any future processing in connection with CISEL’s former activity of insurance business administration.
We are the data controller of any personal information you provide to us. This means that we are responsible for complying with data protection laws. This Notice describes what personal information we may collect from you, why we use your personal information and more generally the practices we maintain and ways in which we use your personal information.
We have appointed a data protection officer to oversee our handling of personal information. If you have any questions about how we collect, store or use your information, you may contact our data protection officer using the details set out under the section ‘Contacting us’ in this document.
We collect information about:
- Previous, current and prospective policyholders
- Previous, current and prospective covered parties under policies
- Users of the CISEL websites
- Claimants
We collect information about you:
- On application for a policy
- On underwriting of a policy
- On claim under a policy (for claims received prior to 31 August 2020)
- On renewal of a policy
- When you contact us to make a mid-term alteration to your policy
- When you use our websites
- When you respond to a customer survey
- When you contact us to complain (for complaints received prior to 31 August 2020)
The personal information that we collect will depend on your relationship with us. We will collect different information depending on whether you are a policyholder, a covered party under a policy, claimant, witness, broker or other third party.
Please note, in certain circumstances we may request and/or receive "sensitive personal information" about you. For example we may need access to health records for the purposes of providing you with a policy, processing claims or details of any criminal convictions for the purposes of preventing, detecting and investigating fraud.
If you provide personal information to us about other individuals you agree to inform the individual about the content of this Notice. Please click on the relevant section below for detailed information regarding the types of personal information we are likely to collect and use about you.
- General information such as your name, address, contact details, [date of birth, gender, relationship to the policyholder (where you are not the policyholder)]
- Identification information such as national insurance number, passport number or driving license number
- Information about your job including job title, employment history, education history and professional accreditations
- Information relevant to your insurance policy
- Information relevant to your claim
- Information relating to previous policies or claims
- Financial information such as your bank details, payment details and information obtained as a result of our credit checks
- Information obtained through our use of cookies. You can find more information about this in our cookies policy
- Telephone recordings
- Your marketing preferences
- Details of your current or former physical or mental health
- Information relating to your criminal convictions (including offences and alleged offences and any court sentence or criminal conviction)
- Data concerning your sex life and/or sexual orientation
We collect personal information from a number of different sources including:
- Directly from you or from someone else on your behalf
- From other third parties involved in your insurance policy or claim such as your broker or another insurer, claimants or defendant or witnesses
- From other third parties who provide a service in relation to your insurance policy or claim such as loss adjusters, claims handlers, experts (including medical experts), healthcare providers and other service providers
- From medical reports and counsel opinions
- From emergency assistance and medical services providers
- From claims services providers
- Via publically available sources such as internet search engines, social media sites
- From other companies within the Cigna Europe group
- Through customer surveys
- From credit reference agencies
- Via insurance industry fraud prevention and detection databases and sanctions screening tools
We may process your information for a number of different purposes. For each purpose we must have a legal ground for such processing. When the information that we process is classed as sensitive personal information, we must have an additional legal ground for such processing.
Generally we will rely on the following legal grounds:
- Our provision of your insurance policy and services for activities such as assessing your application, managing your insurance policy, handling claims and providing other services to you
- Where we have an appropriate business need such as maintain our business records, developing and improving our products and services where such business need does not cause harm to you
- Where we have a legal or regulatory obligation to use such personal information
- Where the use is necessary to establish, exercise or defend our legal rights
- Where you have provided your consent to our use of your personal information
Legal grounds:
- Our providing and administering your insurance contract
Additional legal ground for sensitive personal information
- It is necessary for an insurance purpose in administering a current or former policy of insurance including the administration of any claims
Legal grounds:
- Our having an appropriate business need to use your information which does not overly prejudice you
- Our providing your insurance contract
Additional legal ground for sensitive personal information
- The use is necessary for purposes related to your policy and for reasons of substantial public interest
- You have provided your explicit consent
Legal grounds:
- Our having an appropriate business need to use your information which does not overly prejudice you
- Our providing your insurance contract
Additional legal ground for sensitive personal information
- It is necessary for an insurance purpose in administering a current or former policy of insurance including the administration of any claims
- The use is necessary in order for us to establish, exercise or defend our legal rights
Legal grounds:
- Our providing your insurance contract
- Our having an appropriate business need to use your information which does not overly prejudice you
Additional legal ground for sensitive personal information
- It is necessary for an insurance purpose in administering a current or former policy of insurance including the administration of any claims
- The use is necessary in order for us to establish, exercise or defend our legal rights
Legal grounds:
- Our providing your insurance contract
- Our having an appropriate business need to use your information which does not overly prejudice you
Additional legal ground for sensitive personal information
- It is necessary for an insurance purpose in administering a current or former policy of insurance including the administration of any claims
- The use is necessary in order for us to establish, exercise or defend our legal rights
Legal grounds:
- The use is necessary in order for us to comply with our legal obligations
Additional legal ground for sensitive personal information
- It is necessary for an insurance purpose in administering a current or former policy of insurance including the administration of any claims
- The use is necessary in order for us to establish, exercise or defend our legal rights
Legal grounds:
- Our having an appropriate business need to use your information which does not overly prejudice you
Additional legal ground for sensitive personal information
- It is necessary for an insurance purpose in administering a current or former policy of insurance including the administration of any claims
Legal grounds:
- Our having an appropriate business need to use your information which does not overly prejudice you
Legal grounds:
- Our having an appropriate business need to use your information which does not overly prejudice you.
Legal grounds:
- Our having an appropriate business need to use your information which does not overly prejudice you
Legal grounds:
- Our having an appropriate business need to use your information which does not overly prejudice you
Legal grounds:
- Our having an appropriate business need to use your information which does not overly prejudice you
Legal grounds:
- Our having an appropriate business need to use your information which does not overly prejudice you
From time to time, we may share your personal information within the Cigna Europe group or with third parties. If you would like further information regarding the disclosures of your personal information, please see section ‘Contacting us’ in this document for our contact details.
In order to provide you with your policy, your personal information is shared with other companies in the Cigna Europe group. Your personal information might be shared because one company is unable to provide you with any insurance policy but another might be able to assist you or for our general business administration purposes or for the prevention and detection of fraud.
From 31 Aug 2020 the Cigna insurance companies took on responsibility for management of customer enquiries, claims or complaints relating to CISEL’s business activities. A copy of all customer information was provided to the Cigna insurance companies expressly for this purpose. The Fair Processing Notices of the Cigna insurance companies who will undertake this processing can be accessed by the links below:
From 31 Aug 2020, CISEL uses Cigna European Services Limited (CESL) to administrate retention of customer information in connection with CISEL’s former activity of insurance business administration. CESL uses third parties to assist with administration on its behalf.
We also disclose your information to the third parties listed below for the purposes described in this Notice. This might include:
- Our insurance partners such as brokers, other insurers, reinsurers or other companies who act as insurance distributors
- Other third parties who assist in the administration of your insurance policy or claim or to whom the administration of your insurance policy or claim is outsourced, such as loss adjusters, claims handlers, accountants, auditors, lawyers and other experts
- Fraud detection agencies and other third parties who operate and maintain fraud detection registers
- External law firms who are assisting us with recoveries, fraud matters or disputed claims issues
- Investigative firms we brief to look into claims on our behalf in relation to suspected fraud
- Health providers (for example, a hospital which is responsible for any treatment you receive through your policy)
- Our emergency assistance and medical services provider, Healix, and third parties it uses to assist with claims including healthcare providers, overseas agencies and cost containment agencies. Healix's data protection notice can be found on its website
- Our third party claims administration provider, Sentry Solutions, which is a trading style of Rightpath, and any third parties it uses to assist with claims handling. Rightpath's Privacy Policy can be found on its website
- Our regulators
- The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime
- Debt collection agencies
- Credit referencing agencies
- Our third party services providers such as IT suppliers, actuaries, auditors, lawyers, marketing agencies, document management providers and tax advisers
- Our print provider that prints policy documents and customer communications on our behalf
- Third parties who undertake analysis for the purposes of product improvement
- Selected third parties in connection with any sale, transfer or disposal of our business
We may also use your personal information to provide you with information about our products or services or those of our partners which may be of interest to you where you have provided your consent for us to do so.
We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you wish to unsubscribe from emails sent by us, you may do so at any time by clicking on the "unsubscribe" link that appears in all marketing emails. Otherwise you can always contact us using the details set out under the section ‘Contacting us’ in this document to update your contact preferences. Please note, however, that we will continue to send you service related (non-marketing) communications.
We aim to continuously improve the services we offer to our customers. From time to time we carry out customer satisfaction surveys which may be for our own benefit or for more general interest, and we may need to collect further information about you in connection with them. Surveys will usually be carried out by us but in some circumstances we will use an external firm who will carry out the survey on our behalf. We may share information collected through surveys with our partners.
Your participation in such survey is entirely optional but your help and feedback would be appreciated. You can opt out of being contacted in connection with such surveys at any time by clicking on the "unsubscribe" link that appears in all survey emails. Otherwise you can always contact us using the details set out in the section ‘Contacting us’ in this document to update your contact preferences.
We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Notice and in order to comply with our legal and regulatory obligations. If you would like further information regarding the periods for which your personal information will be stored, please see the section ‘Contacting us’ in this document for our contact details.
Where we make a transfer of your personal information outside of the EEA we will take the required steps to ensure that your personal information is protected. Such steps may include:
Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including:
- entering into data transfer contracts and using specific contractual provisions that has been approved by European data protection authorities otherwise known as the "standard contractual clauses"
- only transferring personal data to companies in non-EEA countries who have been deemed by European data protection authorities to have adequate levels of data protection for the protection of personal information. You can find out more about this here
We are also entitled under European data protection laws to transfer your personal information to countries outside the EEA in the following circumstances:
- it is necessary for the performance of the contract we have with you
- it is necessary to protect your vital interests i.e. it is a life or death situation
We have a network of group companies with which we share personal information. These companies are based both within the EEA and outside the EEA. We have appropriate data transfer contracts in place between all such group companies.
If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in the ‘Contacting us’ section in this document.
Under data protection law you have certain rights in relation to the personal information that we hold about you. You may exercise these rights at any time by contacting us using the details set out in the ‘Contacting us’ section in this document.
Please note:
- In some cases we may not be able to comply with your request (e.g. we might not be able to delete your data) for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make and if we can't comply with your request, we will tell you why
- In some circumstances exercising some of these rights (including the right to erasure, the right to restriction of processing and the right to withdraw consent to us processing your sensitive data) will mean we are unable to continue providing you with your policy and may therefore result in the cancellation of your policy. Your policy terms and conditions set out what will happen in the event your policy is cancelled.
Your rights include:
You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests.
Your information will usually be provided to you in writing, unless otherwise requested, or where you have made the request by electronic means, in which case the information will be provided to you by electronic means where possible.
We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it.
In certain circumstances, you have the right to ask us to erase your personal information. Please note that in some circumstances exercise of this right will mean we are unable to continue providing you with your policy and may therefore result in the cancellation of your policy. Your policy terms and conditions set out what will happen in the event your policy is cancelled.
In certain circumstances, you are entitled to ask us to stop using your personal information. Please note that in some circumstances exercise of this right will mean we are unable to continue providing you with your policy and may therefore result in the cancellation of your policy. Your policy terms and conditions set out what will happen in the event your policy is cancelled.
In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice.
You can ask us to stop sending you marketing messages at any time.
You have a right to not be subject to a decision based solely on automated means. Please note that personal data, including sensitive personal data, may be used in the context of auto-renewal of certain types of policies which involves automated decision making to determine what the cost of renewing the policy will be. We will ask you when you purchase your policy if you would like to opt into auto-renewal. However, even if you opted in at this point, you have the right to opt out at any point.
For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. Please note that in some circumstances exercise of this right will mean we are unable to continue providing you with your policy and may therefore result in the cancellation of your policy. Your policy terms and conditions set out what will happen in the event your policy is cancelled.
You have a right to complain to the Information Commissioner's Office (ICO) if you believe that any use of your personal information by us is in breach of applicable data protection laws and regulations.
More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/
Making a complaint will not affect any other legal rights or remedies that you have.
Please contact us using the details in the ‘Contacting us’ section of this document to attempt to resolve any issues before contacting the ICO.
We use a range of organisational and technical security measures to protect your information.
Firewalls are used to block unauthorised traffic to the servers and the actual servers are located in a secure location which can only be accessed by authorised personnel and our internal procedures cover the storage, access and disclosure of your information.
If you have any questions about how we collect, store or use your personal information, you may contact our data protection officer at:
- Data Protection Officer
Cigna Insurance Services (Europe) Limited
1 Knowe Road
Greenock
Renfrewshire
Scotland
PA15 4RJ
- +44 (0) 330 100 9349
We may update this Notice from time to time to ensure that it remains accurate. Please check back each time that you provide additional personal information to us.
This Notice was last updated on 31 August 2020.
