Claims Privacy Notice

1. Introduction

This Privacy Notice (“Notice”) explains how Aon, a part of Aon UK Limited (registered number 0210725), including its affiliated companies and subsidiaries, and UK branch of Aon Belgium BV (registered number BR020969) (“Aon”) makes use of the personal information collected about you in connection with the insurance product or service (the “Service”). Throughout this Notice, Aon may be referred to as “Aon”, "we", "us", or "our".

We are a company incorporated in England and Wales and have our registered office at The Aon Centre, The Leadenhall Building, 122 Leadenhall Street, London, EC3V 4AN.

 

2. Collecting Your Information

2.1	The information we collect about you may include the following:

1. Basic personal details, such as your name, current and previous address, contact details, date of birth, age, gender, email address, job title and marital status;
2. Company details, including name and address.
3. Demographic details, such as lifestyle information and insurance requirements, including details of your home(s) or commercial properties, possessions (including valuable articles or company property), the security of your properties, details of any surveys, appraisals or valuations, details of your travel plans including countries to be visited and length of trips, details of your car, van, motorcycle or any other form of motor vehicles;
4. Existing and previous insurance policy details, previous accident and claims history and details of any criminal convictions not spent under the Rehabilitation of Offenders Act
5. Driving history, certifications and insurance details, such as driving license details, the period for which a license has been held, existing and previous insurance policy details, previous accident and claims history, details of any motoring convictions and details of your employment;
6. Financial details, such as payment card and bank account details, details of your credit history, earnings information, tax and accountancy information and bankruptcy status;
7. Claims details, such as information about any claims concerning your home(s) or commercial properties, possessions (including valuable articles or company property) insurance, your motor insurance policy or your accident or travel insurance policy;
8. Education and professional experience data such as education and training history, names of previous employers, titles of previous job roles, degrees and qualification certifications; and
9. Health information like medical records of you or any other members covered under the policy, which may be required for the purposes of underwriting or claims processing;

 

2.2

You are required to provide any personal information we reasonably require (in a form acceptable to us) to meet our obligations in connection with the services we provide to you, including any legal and regulatory obligations. Where you fail to provide or delay in providing information we reasonably require to fulfil these obligations, we may be unable to offer the services to you and/or we may terminate the services provided with immediate effect.

 

2.3

Where you provide personal information to Aon about third party individuals (e.g. information about your spouse, civil partner, child(ren), dependents or emergency contacts), where appropriate, you should provide these individuals with a copy of this Notice beforehand or ensure they are otherwise made aware of how their information will be used by Aon.

 

3. Processing Your Information

The information collected from you is used for managing and processing your claim, including:

1. Managing insurance and reinsurance claims;
2. Assess your application to receive the Services;
3. Carry out due diligence, identity, credit reference, bankruptcy, sanctions, data validation and other vetting and risk management agency checks;
4. Evaluate risks relating to your prospective or existing insurance policy;
5. Processing payments
6. Investigating and settling claims or complaints in relation to insurance policies and / or Service provided;
7. Defending or prosecuting legal claims by facilitating the prevention, detection and investigation of crime and the apprehension or prosecution of offenders;
8. Facilitate the prevention, detection and investigation of crime and the apprehension or prosecution of offenders;
9. Transfer books of business to successors of the business in the event of a sale or reorganisation;
10. Fulfil legal and regulatory obligations and monitor compliance with the same;
11. Perform analytics for risk modelling purposes and to analyse trends;
12. Conduct market research and canvass your views about the services to develop and improve our products and service offerings generally;
13. Offer other products and services that may be of interest to you.

 

4. Information collected from Third Parties

In addition to sourcing personal information from you directly, we may also collect personal information about you from other parties like insurers, reinsurers, witnesses, experts, loss adjusters, solicitors and claims handlers or any other relevant entity for underwriting, claims handling and fraud prevention purposes.

 

5. Recipients of Your Information

We may disclose your personal data and sensitive data to insurers, reinsurers, legal advisers, loss adjusters, solicitors, experts, the policyholder, claims database and claims investigators, where necessary to investigate, exercise or defend legal claims, insurance claims or other claims of a similar nature. In the context of providing the Services, we and other insurance market participants need to collect, use and share personal information. To help you understand how insurance market participants may process personal information across the insurance lifecycle, please see the Insurance Market Core Uses Information Notice available on the website of the UK insurance industry association, Lloyd’s Market Association (“LMA”).

 

6. Overseas Transfers of Your Information

6.1

We operate on a global and worldwide basis and we therefore reserve the right to transfer personal information about you to other countries including without limitation [For example, India, United States of America] to be processed for the purposes outlined in the Notice. In particular, we may make such transfers to offer, administer and manage the Service provided to you and improve the efficiency of our business operations. We shall endeavour to ensure that such transfers comply with all applicable data privacy laws and regulations and provide appropriate protection for the rights and freedoms conferred to individuals under such laws.

6.2

Where we collect personal information about you in the United Kingdom (the “UK”) or the European Economic Area (the “EEA”) we may transfer the information to countries outside the UK or EEA for the processing purposes outlined in this Notice. This may include transfers to countries that the European Commission (the “EC”) and UK data protection regulator consider as providing adequate data privacy safeguards and to some countries that are not subject to an adequacy decision. Aon has an intra-group data transfer agreement in place which regulates cross-border transfers of your personal information within the Aon Group and which incorporates the UK standard contractual clauses approved by the UK data protection regulator. Where we transfer personal information to countries that are not subject to an adequacy decision, we shall put in place appropriate safeguards, such as standard contractual clauses approved by the EC or UK data protection regulator, as appropriate. Where necessary, we may implement additional technical, organisational or contractual measures to ensure an adequate level of protection for your personal information. Where required, further information concerning these safeguards can be obtained by contacting us.

 

7. Information Security

The security of your personal information is important to us and we have implemented appropriate security measures to protect the confidentiality, integrity and availability of the personal information we collect about you and ensure that such information is processed in accordance with applicable data privacy laws.

 

8. Legal Grounds for Processing

We rely on the following legal grounds to collect and use your personal information:

a. Legal and regulatory obligations	The collection and use of some aspects of your personal information is necessary to enable us to meet our legal and regulatory obligations. For example, Aon is licensed and regulated by the Financial Conduct Authority (the “FCA”) and is required to provide the Service in accordance with FCA rules.
b. Legitimate interests	The collection and use of some aspects of your personal information is necessary to enable us to pursue our legitimate commercial interests, e.g. to operate our business and to enable processing of your claims. Where we rely on this legal basis to collect and use your personal information, we shall take appropriate steps to ensure the processing does not infringe the rights and freedoms conferred to you under applicable data privacy law.
c. Insurance purposes	Except where we need to process special categories of data as part of the delivery of our Service, we will not usually ask you for special categories of data (such as information relating to physical or mental health) when you correspond with us. Depending on the nature of your correspondence with us (e.g. as part of our [e.g. claims processing services]), it is possible that you provide us with information that contains some special categories of personal data and which will therefore be included in the information that we collect or record. To the extent that we do process any special categories of data in this way, we do so under Article 9(2)(g) of the UK GDPR and Section 10(3) of the DPA 2018 (necessary for reasons of substantial public interest), in that it meets a condition in Part 2 of Schedule 1 of the DPA 2018 and we have an appropriate policy document covering this processing activity or we will ask for your explicit consent where appropriate to do so.
d. Preventing and detecting Fraud	We will use your personal information, including information relating to criminal convictions or alleged offences to prevent and detect fraud, other financial crime and crime generally in the insurance industry.
e. Consent	In Limited circumstances, where we collect special categories of data (such as information relating to physical or mental health) from witnesses, family members or experts as part of deliveries of our Service, we would do so only after seeking your explicit consent.

 

9. Retention of Your Information

We retain appropriate records of your personal information to operate our business and comply with our legal and regulatory obligations. These records are retained for predefined retention periods that may extend beyond the period for which we provide the Service to you. In most cases we shall retain your personal information for no longer than is required under the applicable laws. We have implemented appropriate measures to ensure your personal information is securely destroyed in a timely and consistent manner when no longer required.

 

10. Accuracy of Your Information

We rely on the availability of accurate personal information in order to provide the Service to you and operate our business. You should therefore notify us of any changes to your personal information, particularly changes concerning your contact details, bank account details, insurance policy details or any other information that may affect the proper management and administration of your insurance policy and/or the Service provided to you.

 

11. Your Information Rights

You have the following rights under applicable data privacy law in respect of any personal information we collect and use about you: The right to access your personal information or be provided with a permanent copy of the information being held about you. The right to request the correction of your personal information or in cases where the accuracy of information is disputed, to supplement the information to give notice that you dispute its accuracy. The right to request the erasure of your personal information, particularly where the continued use of the information is no longer necessary. The right to object to the use of your personal information, particularly where you feel there are no longer sufficient legitimate grounds for us to continue processing the information. The right to object to the use of your personal information for direct marketing purposes. See section 11 below for further information. The right to request the restriction of your personal information from further use, e.g., where the accuracy of the information is disputed, and you request that the information not be used until its accuracy is confirmed. The right to request that some aspects of your personal information be provided to you or a third party of your choice in electronic form to enable its reuse. The right to withdraw consent at any time, whenever we have asked for your consent for processing your personal information without affecting the lawfulness of processing based on consent before its withdrawal. See Section 8(e) above for further information. The right to complain to the relevant data protection regulator about our processing of your personal information. It is important to note, however, that some of the rights described above can only be exercised in certain circumstances. If we are unable to fulfil a request from you to exercise one of your rights under applicable data privacy law, we will write to you to explain the reason for refusal. Where required, further information concerning these rights and their application can be obtained by contacting the Global Data Privacy Office (email: data.privacy@aon.co.uk).

 

12. Direct Marketing

We will use your personal information to send you direct marketing about other products and services that we feel may be of interest to you. We will give you the opportunity to refuse direct marketing at the point that you apply or register to receive the services and, on each occasion, thereafter that you receive direct marketing communications from us. You can also change your marketing preferences at any stage by contacting us. Please note that, even if you opt out of receiving direct marketing communications, we may still send you service-related communications where necessary.

 

13. Complaints

If you wish to make a complaint about the way we use your personal information you should raise this with us by contacting Central Complaints in the first instance either by any one of the below methods: E-Mail: Central.Complaints@aon.co.uk Phone: +44 (0)1252 768662 Post: Briarcliff House, Kingsmead, Farnborough GU14 7TE However, if you are not satisfied with the way we have handled your complaint you have the right to raise the matter with the relevant data protection regulator. England Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate) Scotland Information Commissioner's Office 45 Melville Street Edinburgh EH3 7HL Tel: 0131 244 9001 Wales Information Commissioner's Office 2nd floor Churchill House Churchill way Cardiff CF10 2HH Tel:029 2067 8400 Northern Ireland Information Commissioner's Office 3rd Floor Cromac Place Belfast BT7 2JB Tel: 0303 123 1114 (local rate) or 028 9027 8757 (national rate)

 

14. Contact Information

If you have any questions about the content of this Notice or the rights conferred to you under applicable data privacy law, you should contact the Global Data Privacy Office at the following address: Data Protection Officer Aon Services Corporation The Aon Centre The Leadenhall Building 122 Leadenhall Street London EC3V 4AN email: data.privacy@aon.co.uk

 

15. Changes to this Notice

This Notice is not contractual and we reserve the right to reasonably amend it from time to time to ensure it continues to accurately reflect the way that we collect and use personal information about you. Any updates or changes to this Notice will be made available to you. We encourage you to periodically review this Notice so that you will be aware of our privacy practices. This Notice was last updated on 28th February 2024.