Cover-More UK is committed to the safe and careful use of your personal information. We take reasonable steps to protect any personal or sensitive data you provide to us from misuse, interference, loss, unauthorised access, modification or disclosure. We handle information in an open, fair and transparent way in accordance with the Data Protection Act 1998.
Cover-More Group Limited is an Australian Securities Exchange listed travel insurance and assistance group of companies. Cover-More Travel Insurance Services UK is part of the Cover-More Group.
This Policy will be reviewed at least annually, to ensure it remains up to date. It was prepared in October 2014 and it may be amended from time to time by posting the amended version on our website.
For further information on privacy in the UK, please visit the website of the Information Commissioner at http://ico.org.uk/.
Your Personal Information
3. What is Personal and Sensitive Personal Data?
Personal Data means data that relates to a living individual who can be identified from the data or from the data and other information which is in the possession (or is likely to come into possession) of Cover-More.
Sensitive Personal Data is personal data that includes information about an individual's health, racial or ethnic origins, religious, philosophical or political beliefs, sexual preferences or practices, trade union memberships and criminal records.
Cover-More regularly collects, holds, uses and discloses health information and is committed to providing this type of information with a level of privacy protection, higher than personal data.
4. How We Collect Your Personal Information
Cover-More collects personal information from and on behalf of customers, business partners, suppliers, employers (relating to corporate policies), other insurers and third party service providers.
We will, if it is reasonable or practicable to do so, collect your personal data directly from you. This may happen when you fill out an application form for travel insurance, become one of our representatives, make a claim or request assistance. This may occur over the phone, via email, a website or through one of our agents or partners.
In certain cases we collect your personal data from third parties. For example, we may need to collect personal information from your representative (such as a legal guardian), your travel consultant, the primary policy holder or any of the other organisations referred to below under "Use and disclosure" and identified in Appendix 2.
Where you provide data to a third party to pass onto us as part of the policy application or claims process, we rely on you having provided them with your consent to pass this information to us. In addition, when you provide data, including sensitive data about other individuals on your travel insurance policy, we rely on you to inform them of the information you are providing, how we will use, hold, collect and disclose this data and on you obtaining their consent.
If you are an agent or authorised third party service provider we may obtain information from a credit reporting agency or your agency group head office.
Where your company is the applicant on a corporate policy we may receive your details from your employer.
In addition, we collect information when you visit our website, Facebook page and other pages that we own and manage.
We may also collect information by other means and will take reasonable steps to inform you if and when we do.
5. Your Sensitive Data
Your health information, such as pre-existing medical conditions, is generally required to arrange travel insurance, to make a determination on a claim or to provide you with medical assistance.
Where you provide health information to a third party to pass onto us as part of the policy application or claims process, we rely on you having provided them with your consent to pass this information to us. In addition, when you provide information, including sensitive information about other individuals on your travel insurance policy, we rely on you to inform them of the information you are providing, how we will use, hold, collect and disclose this information and on you obtaining their consent.
Without your consent we will not collect your sensitive personal data. This is subject to some exceptions including where the collection, use and disclosure of the information:
- is necessary for the provision of emergency assistance
- is required by law
- is necessary for the establishment, exercise or defence of a legal claim.
What Personal Data Does Cover-More Collect
We will only collect personal data where it is necessary for us to perform one or more of our functions or activities. We collect the personal data we need to provide travel insurance and travel related products and services, including assistance when you are travelling.
The type of information Cover-More collects and holds varies depending on the type of product or service we provide to you. For example, Cover-More will hold different information about you if you have a travel insurance policy than if you make a claim on a policy or require assistance when travelling. This information may include information about a disability, or medical condition that you have or health information in general.
If you contact us by telephone, these calls may be recorded for training, quality and business purposes.
For the type of personal and sensitive information Cover-More generally holds please refer to Appendix 1.
7. Unsolicited Data
In the event we receive unsolicited personal or sensitive data, we will determine whether or not it is necessary for Cover-More to retain the data in order to provide travel insurance services to the individual concerned. If we determine that the personal data is not necessary for one or more of our functions or activities and that we should not have collected it, then we will as soon as practicable either return it to you, or whoever sent it to us, securely destroy it or otherwise ensure it is de-identified, provided that it is lawful to do so.
8. How Accurate Is Your Personal Information
Cover-More takes reasonable steps to ensure that the personal data collected, used or disclosed is accurate, relevant, complete and up-to-date.
If you believe your personal data is not accurate, complete or up to date, please contact the Cover-More customer service team.
9. Protecting Your Personal Information
We take reasonable steps to securely store your personal data so that it is protected from unauthorised use, access, modification or disclosure. We store personal data in different ways, including in paper and electronic form, on both Cover-More premises and its data centres and our service providers premises and data centres, which include IT service providers and document storage and management providers. These service providers' premises and data centres may also be located overseas. We take reasonable steps to ensure that these service providers and their data centres meet the Cover-More Group's Privacy standards and the data is stored securely in accordance with the Data Protection Act 1998.
We maintain administrative, technical, and physical safeguards for the protection of personal data. Our security measures include, but are not limited to:
- Access to your personal data is limited to authorised personnel who have a legitimate need to know based on their job. In the case of third-party contractors who process personal information on our behalf, similar requirements are imposed. Where an individual employee no longer requires access, that individual's access is revoked
- Only allowing access where the individual seeking access has satisfied our identification requirements, such as a security check on the commencement of a call
- Confidentiality requirements for our employees and suppliers
- Secure Document storage
- Training and education is provided to all group employees in the handling of personal information
- Security measures for systems access
- Antivirus and anti-malware software, and regularly updated virus definitions
- Third parties who we hire to provide services and have access to personal information agree to implement privacy and security practices that we deem adequate
- Personal information provided on computer servers is secured in a restricted and controlled network environment
- When transferring credit card numbers, via payment gateways the data is encrypted
- Employing firewalls and intrusion detection systems
- Third-party contractors who process personal data on our behalf agree to provide reasonable physical safeguards
- Employing physical and electronic means such as alarms and cameras to protect against unauthorised access to buildings
- Effectively and securely destroying data no longer needed, for example, by shredding or pulping in the case of paper records
- Our security procedures and policies are audited on a regular basis to ensure they are updated in accordance with current legal requirements and current levels of security technology.
While Cover-More has security measures in place to protect your data, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, Cover-More cannot warrant or ensure the security of any information you transmit to us or we transmit on your behalf, or to you, in the course of providing services over the internet.
10. Non Completion Of Online Quotes
If you do not complete an online quote request for any reason Cover-More may contact you on the contact details supplied to offer help completing it.
Use and Disclosure
12. How we use and disclose your personal and sensitive data
We use your personal data to provide you with the relevant product or service you have requested including: assessing your travel insurance application; identifying you; to manage and administer the product or service; assessing and paying a claim; or to provide you with assistance when travelling.
For a list of the types of uses of your personal data by Cover-More please refer to Appendix 3.
13. Your Personal Information and Our Related Companies
When assessing your claim, we may refer to information provided by our third party medical and non-medical assistance providers, who include related entities.
We may also use related entities to process and assess your travel insurance application or claim and to administer your insurance policy. These related entities may be based in Australia or overseas in: New Zealand; Australia; Malaysia; China; or India.
By purchasing a policy through us, you are consenting to us sending your information to overseas related entities.
14. Marketing Our Products And Services
We may from time to time, provide you with information about other products, services and offers.
If you do not wish to receive this information, or wish to know the source of the information, please contact the Cover-More customer service team on 01245 272408. You can change your mind about receiving information about our products and services at any time, by contacting us.
Please note we will still need to send you essential information about your insurance, travel alerts, policy and claim documentation.
15. When We Share Your Information With Other Parties
We will only share (disclose) your personal information with third parties if it is required to fulfil service or product obligations to you, or if it is required under law or in an emergency situation.
Before discussing the progress of a claim or the medical and non-medical assistance that we provide with third parties (other than the parties involved in providing such a service), for example, a relative or companion, we will obtain appropriate consent from you, your parent or guardian, power of attorney or executor (as relevant).
For a list of the types of entities Cover-More generally discloses your personal information to please refer to Appendix 2.
16. Transferring Personal Information Overseas
By purchasing a policy through us, we may send your information to overseas parties if required to provide you with medical and non-medical assistance or to progress and assess your claim.
The countries we typically disclose your personal information to are generally located in the geographic regions you travelled during the duration of your policy or countries where Cover-More's offices are located.
Your Privacy On The Internet
17. Collection of Other Information
Cover-More may also collect non-personally identifiable information such as the type of browser, or operating system you use, your domain name, IP address, access times, referring website addresses and page views. Our Internet Service Provider ("ISP") automatically identifies your computer by its IP address. When you visit pages on our website, our ISP may log your IP address. We do not link IP addresses to any personally identifiable information. Your IP address is used to gather broad demographic information only. A User Transaction ID is created each time you enter our website. This ID is used to keep track of your dealings with us, and other requests.
A cookie is a small, text-based file used frequently on some websites and portals. They are designed to assist and streamline the exchange of information between your computer's browser and our computer systems. Other cookies used by Cover-More collect information about the use of our websites. The information collected includes where visitors connect from, what version of browser they use and their path through the site. It helps us to provide personalised features and keep our content fresh and relevant.
Our web pages may contain electronic images, known as web beacons or spotlight tags. These enable us to count users who have visited certain pages of our website. Web beacons and spotlight tags are not used by us to access your personal information, they are simply a tool we use to analyse which web pages customers view, in an aggregate number.
Links To Other Websites
Our web sites may contain links to non-Group web sites. Whilst such links are provided for your convenience, you should be aware that the information handling practices of the linked web sites might not be the same as ours.
Dealing With Cover-More
18 Resolving Your Privacy Issues
19. Gaining Access To And Correcting Your Personal Information
You can request access to your personal information in most cases without restriction or charge. If charges are applicable for providing access we will disclose these charges to you prior to providing you with the information. In limited circumstances, a request for access may be denied, or restricted access given. We will provide reasons in writing for the denial of or limitation on access.
To arrange access please contact us (see the Contacting Us section). In some cases we may be able to deal with your request over the telephone. Access to the requested information may include providing you with copies of the original documentation, providing you with the opportunity for inspection of the documentation at our premises or providing you with a summary.
We will correct personal information if we discover, or you are able to show that the information is incorrect. If you seek correction and Cover-More disagrees that the information is incorrect, we will provide you with our reasons for taking that view and advise you on the further steps you may take.
20. Dealing With Us Anonymously Or Under Pseudonym
You can deal with us anonymously or you may use a pseudonym where it is lawful and practicable to do so. For example, you may inquire about our products or request a quote. However we regret that we will not be able to offer you travel insurance, assess and pay your claim, appoint you as our authorised representative or provide you with medical and non-medical assistance if we cannot identify you.
21. Your Travel Consultant And Your Personal Information
We require our agents and partners to handle your personal information in a manner consistent with this policy. Our agents and partners (including travel consultants) are authorised to arrange your travel insurance.
We rely on you having provided your travel consultant with your consent if you would like us to share information about your claim or existing medical condition assessment with them. You may choose to deal directly with Cover-More if you prefer not to provide them with information about existing medical conditions and health related matters included in your claim.
22. Contact Us
Phone: 01245 272408
The Privacy Officer
Cover-More Insurance Services UK
PO Box 9180
APPENDIX 1: Information Cover-More Typically Collects And Holds
In general, Cover-More may collect and hold the following personal information:
- Name and address
- Date of birth
- Contact details, which may include your telephone number and email address
- Your gender
- Personal data of any other person you wish to insure, including date of birth, gender and name
- Your travel plans
- Information about your medical history and the medical history of any other person you wish to insure
- Personal data, including health information, about anyone who requires assistance under their travel insurance policy
- Information about the medical history of any person that results in a claim that we have to assess
- Information about claims you make or wish to make under your policy
- Your bank account details so that we may pay your claim
- Your credit card provider details so that we may recover any monies payable under the travel insurance provided by the credit card company
- Other information required to administer the product or services you have requested including determining a claim
- Any details contained within identity documents provided to us
- The type of medical and non-medical assistance you have been provided with either by us, our service providers or your own medical practitioner
- Employment and income information for cancellation and loss of Income claims Background and credit checks (for authorised representatives and suppliers
APPENDIX 2: Entities Cover-More Typically Discloses To And/Or Collects From
Below are the types of entities Cover-More may collect your personal information from and may disclose your personal information to. This is not an exhaustive list.
- Our Insurer, Europäische Reiseversicherung A.G (ERV),
- Other insurers, including your insurer if not Cover-More
- The co-insured on any insurance policy, so we may confirm details of the insurance
- Your travel agent, broker or the consultant who sold you the travel insurance
- Your employer (if a corporate policy)
- Claims administrators
- Investigators, in relation to claims
- Translators, for claims and assistance
- Goods replacement suppliers to settle your claim
- Banks and foreign currency providers to settle your claim
- Transportation and accommodation providers
- Travel consultants and wholesale travel agencies
- Any company who we may claim against
- Medical practitioners and specialists
- Medical providers such as hospitals
- Emergency assistance providers
- Security providers and consultants
- Family members in the event of a medical emergency
- Witnesses, when making a claim
- Record management and storage businesses
- Companies who perform statistical analysis on our behalf
- Customer survey businesses and mystery shopping agencies
- Accreditation or certification organisations
- Our professional advisors including lawyers, accountants, tax advisors and auditors
- Debt collection agencies and other parties that assist with debt-recovery functions
- Police and law enforcement bodies to assist in their functions
- Courts of Law or as otherwise required or authorised by law
- Regulatory or government bodies for the purposes of resolving customer complaints or disputes both internally and externally or to comply with any investigation by one of those bodies
- Insurance reference bureaus
- Data retrieval agencies
- Credit providers or credit reporting agencies (if you are our representative or supplier)
- Printing, mail and distribution companies
- Telecommunication providers
APPENDIX 3: Cover-More's List Of Uses And Disclosure Of Personal Information
We use and in some instance disclose your personal information when we, or third parties appointed by us, provide the following services:
- To identify you and other policy holders
- Arranging and managing your travel insurance with us
- To assess an application for a product, including assessing any existing medical conditions
- Evaluating, managing, processing and paying an insurance claim
- To recover monies due by other insurers
- Evaluating the emergency care and assistance you require and other customer care activities
- Providing medical and non-medical assistance, including settling costs on your behalf
- Dealing with enquiries or complaints
- To monitor and improve the services provided by us and our agents or service providers, the products we provide or our operations
- For planning, product development and research purposes and to seek feedback on products and services (including those products and services offered by others on our behalf)
- Carrying out market analysis and research and product analysis and development
- Enhancing our services for our website visitors
- Conducting internal investigations in relation to crime and fraud prevention, detection or prosecution
- Training our staff
- To identify and develop products or services that may interest you and market them to you (unless you ask us not to do so)
- Carrying out accreditation or certification activities
- For any other purposes that would be reasonably expected
- Processing orders or applications to become a customer for our additional products and services, such as Global Sim
- Carrying out credit checks, credit reporting and compliance checks through ASIC on our authorised representatives and suppliers
- Carrying out debt-recovery functions