Data protection and privacy notice

Who are we?

We are MPR Underwriting Limited (“MPR”), company registration number 10529758. Our address is 10th Floor, Chancery Place, 50 Brown Street, Manchester, M2 2JG. We are the providers of the following website: www.mprunderwriting.com We are registered as a Data Controller with the Information Commissioner’s Office with registration number ZA286402. We are committed to protecting and respecting your privacy. This Policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we keep it secure. We will process your personal information on the basis of “Legitimate Interests” and “Explicit Consent” (as defined by the General Data Protection Regulation).

MPR are underwriting agents of the insurer for policies we issue. We have authority to underwrite and administer policies on behalf of the insurer. In order for us to quote and issue an insurance policy we need to collect and process certain information about the policyholder and those covered by the policy. Similarly, in order to administer a claim, we need to collect and process certain information about those parties involved in the claim, e.g. claimants, witness, etc. We also collect personal data and other information for intermediaries that distribute our policies to enable us to meet contractual, regulatory, legal and business interests.

We take our responsibilities to handle your personal data with care very seriously and protecting the privacy of your personal data is of great importance to us. This privacy notice helps you and parties involved in a claim to understand among other things the legal basis and purpose behind our requirement to receive the information and includes details of those that we share it with and why

Important: This Privacy Policy does not supersede the terms of any insurance policy or contract you have with MPR, nor does it limit or affect any rights you have under applicable data protection regulations.
 
What type of Personal Information do we collect about you?

The types of personal information we collect about you depends upon your relationship with MPR.

If you are an insured person or potential insured, we collect personal information of the policyholder, prospective insured, and related individuals in order to determine eligibility for the underwriting and administration of insurance policies. In some instances, we may need to collect sensitive personal information, such as information about your medical or criminal history.
If you are a claimant making a claim under a MPR policy, we may need to collect your contact information, as well as information about your claim and previous claims. We may also need to collect sensitive personal information, depending on the nature of your claim.

If you are a business partner, we will collect your business contact details.

The types of personal and sensitive personal information we may collect includes:

  • Name, Address, Phone Number, Email;
  • Gender;
  • Marital Status;
  • Date and Place of Birth;
  • Government identification numbers – National Insurance, Social Security, Passport, Tax, Driver’s License);
  • Family Information;
  • Banking Information;
  • Health Information/Medical History;
  • Criminal History;
  • Credit History and Credit Score;
  • Claims/Policy Numbers.

How do we collect information about you?

If you are an insured or potential insured, we collect information from you or your representative through the policy application process. We may also collect information about you from your family members or employer, credit reference agencies, anti-fraud databases, sanctions lists, and relevant government agencies, including public registers or databases as well as credit reference organisations.

If you are a claimant, we will collect information about you when you notify us of a claim, or if the claim is made by someone with a close relationship to you or who otherwise has authority to make a claim on your behalf. We may also collect personal information about you from others who are involved in the claim, including lawyers, witnesses, experts, and adjusters. Finally, we may consult other public sources to validate the claim or protect against fraud or other financial crime.

If you are a business partner, we will collect information about you when you or your company provides that information to us as part of the business relationship.

Why do we collect your personal information?

We may collect your personal information for the following purposes:

  • If you are an insured or potential insured:
  • Account setup, including background checks;
  • Evaluating risks to be covered;
  • Risk modelling and underwriting;
  • Customer service communications;
  • Payments to/from individuals;
  • Direct marketing;
  • Complying with legal or regulatory obligations.

If you are a claimant:

  • Managing insurance or reinsurance claims;
  • Defending or prosecuting legal claims;
  • Investigating or prosecuting fraud;
  • Complying with legal or regulatory obligations.

If you are a business partner:

  • Managing our business relationship with you.

How do we protect your personal information?

We will only use your personal information where we are satisfied that:

  • where required, you have provided your consent to use your data in the appropriate manner;
  • we must use your personal information to perform a contract – for example, to manage your insurance policy with us;
  • we have a legitimate interest as a business to use your personal information – for example, to improve our products.

If we are required to collect sensitive personal information about you, we will make sure we have the right to do so. Typically, the right will arise from:

  • our explicit consent to collect and use the information;
  • an insurance-specific exemption provided by regulations enacted by specific European Union (EU) member states, permitting the collection and use of such sensitive personal information;
  • our need to establish, exercise, or defend your legal rights as an insured or claimant, or the rights of MPR.

Please Note: If you provide explicit consent to our collection of sensitive personal information, you may withdraw this consent to this collection and use at any time. However, your withdrawal of consent may prevent us from providing you with appropriate insurance services, and in certain circumstances it may not be possible for insurance coverage to continue. If you choose to withdraw your consent, we will inform you of the possible consequences and effects, including cancellation of your policy.

Where does your personal information go?

We may transfer your personal information to those insurers for whom we underwrite and issue policies on behalf of. We may need to transfer your personal information to third parties to help manage our business and delivery of services to you. Your information may be transferred to, stored and processed outside, the European Economic Area (EEA). We will not transfer your information outside the EEA unless it is to a country which is considered to have equivalent data protection laws or where we have taken all reasonable steps to ensure the firm has suitable standards in place to protect your information.

The third parties may include:

For insureds or potential insureds:

  • Brokers;
  • Other insurers or reinsurers, including those mentioned above;
  • Service providers who supply back office support;
  • Regulators, including the Financial Conduct Authority (FCA),Information Commissioners’ Office (ICO), or Prudential Regulation Authority (PRA);
  • Credit reference agencies;
  • Foreign law enforcement agencies.

For claimants:

  • Third-Party Administrators;
  • Other insurers or reinsurers, including those mentioned above;
  • Adjusters and other claims experts;
  • Service providers who supply back-office support;
  • Outside legal counsel;
  • Credit reference agencies
  • Foreign law enforcement agencies

Whenever it is necessary to transfer your personal information to our affiliates, agents or contractors located outside of the EEA, we will take appropriate steps to ensure that such transfer adequately protects your rights and interests.

Transfers to our service providers and business partners are protected by contractual agreements that also require an adequate level of data protection.

How long do we keep your information?

We will keep your personal information only so long as is necessary to provide service to you under your policy, or for the purposes described above. Specifically, we will keep your information for so long as a claim may be brought under the policy, or where we are required to keep your personal information to satisfy legal or regulatory obligations.
In some cases, we may keep your personal information for longer periods of time, in order to maintain accurate records in the event of future complaints, challenges, or litigation regarding your policy, claims, or other issues that may arise. Once your personal information is no longer required, it will be securely deleted.

Your Rights

You have certain rights in relation to how MPR collects and uses your personal information. To exercise any of these rights, please contact us as set forth below. Your rights include:

Right to Access – you may:

  • confirm whether we are collecting and using your personal information
  • obtain a copy of your personal information from MPR
  • obtain additional information about your personal information, including:
        • what information we have;
        • how we collect your information;
        • how we use it;
        • to whom we disclose it;
        • whether we transfer it outside the EEA, and how we protect it;
        • how long we keep it;
        • your rights;
        • how you can make a complaint.

Right to Rectify – you may ask us to correct personal information that is inaccurate.

Right to Erasure – you can ask us to erase your personal information only where:

  • it is no longer needed for the purposes for which it was collected;
  • you have withdrawn consent that you explicitly provided;
  • it was unlawfully processed;
  • you have an appropriate Right to Object (see below);
  • MPR must comply with a legal obligation to erase the personal information.

MPR is not required to erase your personal information if continued collection and use of it is necessary to comply with a legal obligation to establish, exercise or defend legal claims of the company or our insureds

Right to Restrict Use – you can ask us to restrict the use of your personal data only where:

  • you contest its accuracy, in order to give us the opportunity to verify and correct it;
  • its collection and use is unlawful, but you do not want it erased;
  • it is no longer needed for the purposes for which it was collected, but is still needed to establish, exercise, or defend legal claims;
  • you have exercised the right to object and that decision is pending.

We may continue to use your personal information where:

  • you consented to its use, and have not withdrawn that consent;
  • we must use it to establish, exercise, or defend legal claims;
  • we must use it to protect the rights of another person.

Right to Data Portability – you can ask that we provide your personal information to you in a structured, portable format, or that your personal information be directly transferred to another company, but only if our collection and use of that information is based on your consent, or on the performance of a contract with you;
is carried out by automated means.

Right to Object – you can object to the collection and use of your personal information for which MPR uses “legitimate interest” as its basis for collection, if you believe your fundamental rights and freedoms outweigh our legitimate interests. Once you object, we have the opportunity to demonstrate that our legitimate interests are compelling enough to override your rights and freedoms.

Right to File Complaint – you can file a complaint with your local supervisory authority regarding our collection and use of your personal information.

International Transfers – you can ask for information on the protections under which your personal information is transferred outside of the EEA. We may redact certain portions of this information for reasons of commercial sensitivity.

Subject Access Requests Administration: the following may apply to your request regarding your personal information:

  • We will respond to all valid requests within thirty days;
  • You will not be charged a fee when we process your request. We reserve the right to charge a reasonable fee if your request is unfounded, repetitive or excessive.

How to contact us

Please address all inquiries, requests, and other communications regarding your personal information or this Privacy Policy to:

The Data Protection Officer
enquiries@mprunderwriting.com
10th Floor, Chancery Place
Manchester
M2 2JG
+44 161 241 3550

Links to Insurers’ privacy notices
www.axiscapital.com/about-axis/privacy-data-protection
www.msamlin.com/en/site-services/data-privacy-notice.html