At Chubb ("we", "us"), we routinely collect and use personal data about individuals, including insured persons, claimants or business partners ("you"). We are aware of our responsibilities to handle your personal data with care, to keep it secure and comply with applicable privacy and data protection laws.
How this Policy Works
The purpose of this Policy is to provide a clear explanation of when, why and how we collect and use information which may relate to you ("personal data").
We have designed this Policy to be as user friendly as possible. Click on a topic in the list below to find out more, or explore individual topics in more detail by following the various links. We have labelled sections of the Policy to make it easy for you to navigate to the information that may be most relevant to you.
Do read this Policy with care. It provides important information about how we use personal data and explains your statutory rights. This Policy is not intended to override the terms of any insurance policy or contract you have with us, nor rights you might have available under applicable data protection laws.
Chubb is a group of companies, including the Combined Insurance and ACE Europe Life brands. The Chubb group company which was originally responsible for collecting information about you will be principally responsible for looking after your personal data (your Data Controller). If you have an insurance policy with us, this will be the Chubb company named on that policy.
You can find out the identity of each company that is processing your personal data in the context of providing your insurance cover in the following ways:
Where you took out the insurance policy yourself: the Chubb company or / and, if purchased through a broker, the broker will have provided you with its name, address and contact details.
Where your employer or a third party took out the policy for your benefit: you should contact your employer who should provide you with details of the Chubb company.
Where your personal data has been passed to another Data Controller (e.g. a reinsurer): the first Data Controller will inform you of the other Data Controllers with whom they have shared your personal data who you can contact about their use of your personal data, as we do in Section 6 of this policy.
A description of the entities that make up the Chubb group is available at https://www.chubb.com/us-en/about-chubb.
You should be aware that although one Chubb company may be principally responsible for looking after your personal data, information may be held in databases which can be accessed by other Chubb companies. When accessing your personal data, Chubb companies will comply with the standards set out in this Policy.
Prospective Insureds and Insured Persons. In order to underwrite and administer insurance policies, we collect information about the prospective insured, policyholder and related parties. This may include background and contact information on the prospective insured, policyholder or their representative, and matters relevant to the assessment of risk and management of insurance policies. The prospective insured or policyholder may be an individual, company or their representative. The level and type of personal data we collect and use varies depending on the type of policy that is applied for or held and may include information on other individuals who need to be considered as part of the policy. In some instances, it is necessary for us to collect and use Sensitive Personal Data, such as information about health or past criminal convictions. We are required to establish a legal exemption to use your Sensitive Personal Data - see Section 5 for further details.
If you are an insured person, from time to time you may need to provide us with the personal data of third parties, for example an injured third party in relation to a claim under a liability policy. Wherever possible, you should take steps to inform the third party that you need to disclose their details to us, identifying Chubb as your insurer. We will process their personal data in accordance with this Policy.
Claimants. If you are making a claim under a policy, we will collect your basic contact details, together with information about the nature of your claim and any previous claims. If you are an insured person we will need to check details of the policy you are insured under and your claims history. Depending on the nature of your claim, it may be necessary for us to collect and use Sensitive Personal Data, such as details of personal injury you may have suffered during an accident.
Business Partners and Visitors. If you are a business partner, we will collect your business contact details. We may also collect information about your professional expertise and experience. We may collect your contact details, if you visit our website, register for a newsletter or attend one of our events. If we collect personally identifiable information through our website, we will make it clear when we collect personal information and will explain what we intend to do with it.
For more information on what information we collect please see Appendix 1
Prospective Insureds and Insured Persons
Business Partners and Visitors
If you telephone Chubb (for example, when notifying a claim or discussing that claim with us) or if Chubb telephones you (for example, to sell an insurance policy) we may record the telephone call. We may also use Interactive Voice Response ("IVR") technology to automate responses to voice commands, and to analyse call recording data. We use call recordings as an evidence of your agreement to purchase an insurance policy or submit a claim, to help train our staff and to provide an accurate record of the call in case of complaints or queries. We may also analyse call recordings using automated technology in order to detect where there may be customer service failings (and then to resolve these), or to detect potential evidence of fraud.
Prospective Insureds and Insured Persons. If you are a prospective insured or an insured person we will use your personal data to consider an application for an insurance policy, assess and evaluate risk, and subject to applicable terms and conditions, provide you with a policy. The underwriting process may include Profiling. If we have provided you with your policy we will use your personal data to administer your policy, deal with your queries, and manage the renewal process. We will also need to use your personal data for regulatory purposes associated with our legal and regulatory obligations as a provider of insurance.
Claimants. If you are a claimant we will use your personal data to assess the merits of your claim, and potentially to pay out a settlement. We may also need to use your personal data to evaluate the risk of potential fraud, a process which may involve Profiling, which uses automated processes. If you are also an insured person, we will use personal data related to your claim to inform the renewal process and potentially future policy applications.
Business Partners and Visitors. If you are a business partner we will use your personal data to manage our relationship with you, including sending you marketing materials (where we have appropriate permissions) and to invite you to events. Where relevant, we will use your personal data to deliver or request the delivery of services, and to manage and administer our contract with you or with your employer. If you are a visitor, we will use your personal data; typically, to register for certain areas of our website, enquire for further information, distribute requested reference materials, or invite you to one of our events.
Data analytics. We routinely analyse information in our various systems and databases to help improve the way we run our business, to provide a better service and to enhance the accuracy of our risk and other actuarial models. We take steps to protect privacy by aggregating and where appropriate anonymising data fields (particularly in relation to Policy Information and Claim Details, as defined in Appendix 1) before allowing information to be available for analysis.
Before collecting and/or using any Sensitive Personal Data we will establish a lawful exemption which will allow us to use that information. If your Sensitive Personal Data is collected on a form (including on a website) or over the telephone, further information about the exemption may be provided on that form. This exemption will typically be:
PLEASE NOTE. If you provide your explicit consent to permit us to process your Sensitive Personal Data, you may withdraw your consent to such processing at any time. However, you should be aware that if you choose to do so we may be unable to continue to provide insurance services to you (and where you withdraw consent to an insurer’s or reinsurer’s use it may not be possible for the insurance cover to continue). This may mean that your policy needs to be cancelled. If you choose to withdraw your consent we will tell you more about the possible consequences, including the effects of cancellation, (which may include that you have difficulties finding cover elsewhere), as well as any fees associated with cancellation.
Please see Appendix 2 to find out more about the information we collect and use about you and why we believe it is appropriate to use that information for such activities
We work with many third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data.
For Prospective Insureds and Insured Persons these third parties may include:
For Claimants this may include:
We may be under legal or regulatory obligations to share your personal data with courts, regulators, law enforcement or in certain cases other insurers. If we were to sell part of our businesses we would need to transfer your personal data to the purchaser of such businesses.
Insurance involves the use and disclosure of your personal data by various insurance market participants such as intermediaries, insurers and reinsurers. The London Insurance Market Core Uses Information Notice [https://www.londonmarketgroup.co.uk/gdpr] sets out those core necessary personal data uses and disclosures. Our core uses and disclosures are consistent with the London Market Core Uses Information Notice. We recommend you review this notice.
Please see below for relevant definitions:
Assistance Providers: these are a special category of service provider, which we use to help provide you with emergency or other assistance in connection with certain policies (e.g. certain travel policies).
Brokers: insurance brokers arrange and negotiate insurance coverage for individuals or companies and deal directly with insurers, such as Chubb, on behalf of the individuals or companies seeking coverage.
Claims Experts: these are experts in a particular field which is relevant to a claim, for example medicine, forensic accountancy, mediation or rehabilitation, who are engaged by Chubb to help us properly assess the merit and value of a claim, provide advice on its settlement, and advise on the proper treatment of claimants.
Data Controller: means a natural or legal person (such as a company) which determines the means and purposes of processing of personal data. For example, a Chubb entity which sells you an insurance policy will be your Data Controller as it determines how it will collect personal data from you, the scope of data which will be collected, and the purposes for which it will be used.
ICO: the Information Commissioners Office regulates the processing of personal data by all organisations within the UK.
Other Insurers / Reinsurers: some policies are insured on a joint or "syndicate" basis. This means that a group of insurers (including us) will join together to write a policy. Policies may also be reinsured, which means that the insurer will purchase its own insurance, from a reinsurer, to cover some of the risk the insurer has underwritten in your policy. Chubb purchases reinsurance, and also act as a reinsurer to other insurance firms.
PRA: the PRA is the Prudential Regulation Authority, which is a financial regulatory body. The PRA focuses on the prudential regulation of financial services firms. When discharging its general functions, the PRA is responsible for contributing to the securing of an appropriate degree of protection for policyholders.
Profiling: means using automated processes without human intervention (such as computer programmes) to analyse your personal data in order to evaluate your behaviour or to predict things about you which are relevant in an insurance context, such as your likely risk profile.
Sensitive Personal Data: means any personal data relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership. At Chubb, (other than in the context of our employees, which is outside the scope of this Policy) we routinely only process Sensitive Personal Data relating to health or criminal convictions.
Service Providers: these are a range of third parties to whom we outsource certain functions of our business. For example, we have service providers who help us with the administration of setting up a new policy record. Some of these providers use 'cloud based' IT applications or systems, which means that your personal data will be hosted on their servers, but under our control and direction. We require all our service providers to respect the confidentiality and security of personal data.
Solicitors: we frequently use solicitors to advise on complex or contentious claims or to provide us with non-claims related legal advice. In addition, if you are a claimant you may be represented by your own solicitor(s).
Telematics data: allows a more personalised renewals quote through the use of data provided automatically to us by a device which monitors your behaviour. An example is data collected from a device fitted to a vehicle reflecting driving behaviour.
Third Party Administrators (or TPA’s): these are companies outside the Chubb group which administer the underwriting of policies, the handling of claims, or both, on our behalf. We require all TPAs to ensure that your personal data is handled lawfully, and in accordance with this Policy and our instructions.
We may use your personal data to send you direct marketing communications about our insurance products or our related services. This may be in the form of email, post, SMS, telephone or targeted online advertisements.
In most cases our processing of your personal data for marketing purposes is based on our legitimate interests to provide information you might find helpful to manage your insured risks, insurance renewals and other products, services and offers that may be of interest to you, although in some cases (such as where required by law) it may be based on your consent. You have a right to prevent direct marketing of any form at any time - this can be exercised by following the opt-out links in electronic communications, or by contacting us using the details set out in Section 12.
We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.
From time to time we may need to share your personal data with members of the Chubb group who may be based outside Europe (outside of the European Economic Area). We may also allow our Service Providers or Assistance Providers, who may be located outside Europe, access to your personal data. We may also make other disclosures of your personal data overseas, for example if we receive a legal or regulatory request from a foreign law enforcement body.
We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests:
You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us as set out in Section 12 if you would like further information.
'Automated Decision Making' refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.
As Profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.
If you are a Prospective Insured and Insured Person, we may use automated decision making to carry out a credit check on you. In an underwriting context, profiling is routinely carried out on your Personal Risk Information (as defined in Appendix 1) to assess your individual risk (or the impact you might have on the cumulative risk of a group of Insured Persons) in order to calculate insurance premiums or to make a decision about whether to extend or renew cover. We may also apply Automated Decision Making to Telematics Data to make decisions about renewal quotes.
If you are a Claimant, we may use Profiling or other forms of automated processing to assess the probability that your claim may be fraudulent or suspect in some way.
Where Sensitive Personal Data is relevant to the Profiling, such as medical history for life insurance or past motoring convictions for motor insurance, your Sensitive Personal Data may also be used in the models.
You have certain rights in respect of automated decision making, where that decision has significant effects on you, including where it produces a legal effect on you. See Sections 10 and 11 for more information about your rights.
We will retain your personal data for as long as is reasonably necessary for the purposes listed in Section 4 of this Policy. In some circumstances we may retain your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulator, tax or accounting requirements.
In specific circumstances we may also retain your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.
We maintain a data retention policy which we apply to records in our care. Where your personal data is no longer required we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.
You have a number of rights in relation to your personal data.
You may request access to your data, correction of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, data portability and various information in relation to any Automated Decision Making and Profiling or the basis for international transfers. You may also exercise a right to complain to your Supervisory Authority. More information about each of these rights can be found by clicking on the relevant link or by referring to the table set out further below.
To exercise your rights you may contact us as set out in Section 12. Please note the following if you do wish to exercise these rights:
|Right||What this means|
You can ask us to:
You can ask us to rectify inaccurate personal data.
We may seek to verify the accuracy of the data before rectifying it.
You can ask us to erase your personal data, but only where:
We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:
There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request
You can ask us to restrict (i.e. keep but not use) your personal data, but only where:
We can continue to use your personal data following a request for restriction, where:
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another Data Controller, but in each case only where:
You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
|Automated Decision Making||
You can ask not to be subject to a decision which is based solely on automated processing (see Section 9), but only where that decision:
In such situations, you can also obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.
However, in these situations you can still obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.
You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Economic Area.
We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.
You have a right to lodge a complaint with your local supervisory authority about our processing of your personal data. In the UK, the supervisory authority for data protection is the ICO (https://ico.org.uk/).
We take the confidentiality of all records containing personal data seriously, and reserve the right to ask you for proof of your identity if you make a request in respect of such records.
We will not ask for a fee to exercise any of your rights in relation to your personal data, unless your request for access to information is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.
We aim to respond to any valid requests within one month unless it is particularly complicated or you have made several requests in which case we aim to respond within three months. We will let you know if we are going to take longer than one month. We might ask you if you can tell us what exactly you want to receive or are concerned about. This will help us to action your request more quickly.
|Third Party Rights||
We do not have to comply with a request where it would adversely affect the rights and freedoms of other data subjects.
The primary point of contact for all issues arising from this Policy, including requests to exercise data subject rights, is our Data Protection Officer.
The Data Protection Officer can be contacted in the following ways:
Data Protection Officer,
Chubb, 100 Leadenhall Street,
EC3A 3BP, London
If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.
Updated March 2020