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 website, 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 your policy.

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 CISEL 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.

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 at section 14.

We collect information about:

  • Previous, current and prospective policyholders
  • Previous, current and prospective covered parties under policies
  • Users of the CISEL website
  • Claimants

We collect information about you:

  • On application for a policy
  • On underwriting of a policy
  • On claim under a policy
  • On renewal of a policy
  • When you contact us to make a mid-term alteration to your policy
  • When you use the CISEL website
  • When you respond to a customer survey
  • When you contact us to complain

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: (a) to inform the individual about the content of this Notice; and (b) to obtain any consent where we indicate that it is required for the processing of that individual's personal data in accordance with 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.

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

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 14 below for our contact details.

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 in section 14 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 section 14 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 section 14 below for our contact details.

We (or third parties acting on our behalf) may store or process information that we collect about you in countries outside the European Economic Area ("EEA"). 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 placing the party we are transferring information to under contractual obligations to protect it to adequate standards. If you would like further information regarding the steps we take to safeguard your personal information, please contact us using the details set out in section 14.

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 section 14.

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:

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 Drake Circus
Devon PL1 1QH
+44 (0) 330 100 6403

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 10 April 2019.