Security and Privacy
Liberty Insurance Ireland's Security and Privacy Statement.
1.0 Who is responsible for your personal information?
Liberty Insurance dac, with company number 494729 and its registered address at Dublin Road, Cavan ("Liberty") in Ireland is the registered data controller in relation to personal information held by it about you for the purposes of the Data Protection Act 1988 and 2003.
2.0 What details do we collect and why?
Subject to data protection laws, we will use the personal information you provide through the Liberty website, or which is otherwise collected from you or third parties (for example Insurance Link), whether online or offline, for various purposes depending on our relationship with you and/or the person you represent.
1. For example, this may include (as applicable):
- to register you as a user of the Liberty website,
- to send information you request, to handle your insurance queries, applications and any policy and related claims,
- to send you marketing information about products and/or services (further details below),
- to manage and deal with your claim against our insured customer or to deal with your appointed agent, or representatives, and
- for underwriting, claims handling, fraud prevention, anti-money laundering and counter terrorism financing purposes.
2. We will do this at a local company and/or at a Liberty Mutual Insurance Group level as appropriate (as part of shared services) and will be carried out subject to applicable law. This personal information will be held in the data systems of Liberty or by our agents or subcontractors or by other Liberty Mutual Insurance Group companies (further details below).
3. We may use this personal information for our business processes and activities including analysis, review, audit, forecasts, business planning and transactions (using de-personalised data where required) and dealing with insurance and/or legal claims; and for compliance with our legal, regulatory and other good governance obligations. We may record or monitor all phone calls to protect you and us and for training and quality purposes.
4. We may check the information you provide against other information available to the public (such as the edited electoral roll, court judgments, bankruptcy or repossessions) and other insurance industry databases, and depending on your relationship with us this may involve (as applicable) carrying out bankruptcy/judgement debt checks, fraud prevention, anti-money laundering and counter terrorism financing checks, subject to data protection law. Subject to data protection law, we may exchange information with other insurers, either directly or through people acting for us and them (such as loss adjusters or private investigators), the Garda Síochána, other police services, other law-enforcement agencies or any person authorised by law to access customer records.
3.0 Sensitive details
We may need to collect sensitive personal information about claimants and insured customers (such as information about physical or mental health or medical conditions, criminal and/or motor convictions and pending proceedings, and bankruptcy/debt details) and others named on an insured customer's insurance policy and third parties involved in a claim.
By going ahead with a Liberty insurance quote or policy, making a claim against a Liberty insured customer, or submitting personal information, including sensitive personal information, to us through the Liberty website or otherwise, as applicable, you will be explicitly agreeing to us, our agents, other insurers and the other persons who we describe in this notice processing that information for all purposes as are or may be relevant from time to time to your relationship with Liberty, including but not limited to those described in this notice. Before you provide personal information, including sensitive personal information, about others (e.g. from the other people named on your policy if you are an insured customer, or from the person on whose behalf you are claiming against a Liberty insured customer if you are an agent), you should make sure they have seen a copy of this notice and make sure they agree to you disclosing it to us.
We may amend the personal information so that you cannot be identified from the data either by itself or when combined with any other data we hold. That data will not be subject to this notice or data protection law. We may use it for insurance administration purposes including analysis of trends, carrying out actuarial work, planning insurance service delivery, risk assessment and costs and charges.
5.0 What details do we share, who with and why?
We will only take instructions to change a policy from you, your husband, wife or civil partner or your parent. We will only take instruction to cancel or lapse a policy from you. In some cases we may also deal with other people contacting us on your behalf as long as we have your permission. If you would prefer that we only deal with you, please let us know.
In exceptional circumstances it may be necessary for us to deal with other people, for example, if you are incapacitated and if a next of kin contacts us in relation to your policy.
We may pass information about you and your claims history to:
- Our agents and service providers and other companies in the Liberty Mutual Insurance Group (as part of shared services);
- Our Policyholder
- other insurers, either directly or through people acting for us and them (such as intermediaries, loss adjusters or private investigators and solicitors);
- any agent acting for you;
- regulatory organisations which we belong to or are governed by;
- the police, other law-enforcement agencies, government agencies or regulatory authorities, and any other person or organization if this is needed by law; and
- any other person where necessary to perform any insurance contract with you so we can protect ourselves from risk or to make sure we meet with regulations.
- with the Insurance Link database, run by Insurance Ireland. This information includes identification details and the nature of any damage suffered by anyone involved in a claim, in some cases including types of injuries. This information may be shared with other insurers and/ or statutory authorities.
When a claim is finalised, the settlement data may be shared with the policyholder (and/or the intermediary) as the claim could impact the renewal premium.
The purpose of engaging in this insurance industry service is to help us authenticate information provided to prevent fraud and protect customers and to assess information at underwriting stage. This helps prevent multiple claims on the same injury or damage, assists in investigating fraud and the integrity of information provided. Where previous claims are identified through Insurance Link, insurers may exchange additional information on those claims, more information is available on Insurance Link at their website.
We may also use the information you provide to obtain information from the National Vehicle and Driver File held by the Department of Transport. We may transfer your information to other countries (further details below).
Subject to data protection law, we may disclose personal information, including sensitive personal information described above, to anyone we transfer our rights and duties to under this policy, for example, to a third party in relation to any sale(s) of our business in whole or part. For the avoidance of doubt such disclosure would only be to actual purchasers of the business in whole or in part, not prospective purchasers.
6.0 Where are your details sent?
Personal information will be held in the data systems of Liberty including Liberty Group companies and our/their agents, cloud and other service providers and may be transferred to countries outside of the European Economic Area including to Liberty Mutual Insurance Group companies and our/their agents, cloud and other service providers. Liberty ensures by contractual agreements with its service providers that no personal data is transferred outside of the EEA unless that country ensures an adequate level of protection for the rights and freedom of data subjects in relation to the processing of personal data.
By submitting personal data a Policyholder agrees to the transfer, storing or processing of the data as outlined above.
7.0 Contacting you
We may contact you with a reminder that your insurance is due to be renewed. This contact may be made by a number of communication methods in addition to traditional correspondence, see section 8 below. We will use the details you have given to us to provide you with information about our products and services and those of other companies in the Liberty Mutual Group companies and other companies whose products and services may interest you. However, we will not do so if you have already told us you do not want this information. By providing us with information (including any personal information) and agreeing to the terms hereof you consent to the information being used for these purposes. We may also use your information for these purposes after your policy has come to an end unless you ask us not to.
8.0 How might we contact you?
From time to time we may contact you using the information you have provided in relation to our products and services in any of the following ways:
- By phone
- By post
- By email
- By text message
- Through digital and/ or other remote applications
9.0 Why might we contact you?
- about an enquiry you have made;
- with relevant products or services offers;
- in relation to your policy or quote;
- to ask for your feedback/views on the products & services we provide;
- to tell you about any important changes to our website; or
- where there is another genuine reason for doing so.
10.0 How to Opt out
You can change your mind about receiving marketing information from us at any time. Each time we contact you electronically with marketing information or a marketing message, you can choose not to receive further marketing information from us to that email address or phone number. This is known as an "opt-out". If you want to "opt-out", you can do so by following the instructions included in each electronic communication or please phone us at 1890 89 1890 or email us at firstname.lastname@example.org. Please make sure you tell us about any changes to your marketing preferences for each affected address, email address or phone number you have registered with us
12.0 Fraudulent Emails Warning
Liberty will never contact you by email to request an update of your personal or private information. If you receive any such emails please contact us by telephone immediately.
13.0 Change to Statement
We may occasionally update this privacy statement. The updated version will be effective when it is posted. Therefore we would suggest you periodically review this statement to stay informed about how we process your personal information. Your continued use of the website following the posting of changes to this policy will mean you consent to and accept those changes. If you do not consent to such changes you can delete your user account and stop using the website.
This website links to other websites which are operated and controlled by third parties which may or may not have their own privacy policies and those other websites may link to this website. We are not responsible for privacy practices of third parties including website operators to whom you provide your information. You should read the privacy policies on all third party websites carefully before using them and in particular before providing your information to them.
15.0 Copies of your personal information
You can ask us for a copy of the information we hold about you by writing to our Customer Services Manager (see contact details below) and enclosing a cheque for €6.35. Please allow up to 40 days for us to send this information to you. You may also ask us to change or delete any information we hold about you and we will make all reasonable efforts to update our records if we feel it is appropriate. Please help us to ensure your personal information is accurate by telling us as soon as reasonably possible in the event of change of address, contact details or other circumstances.
If you have any questions about this notice you should contact our Customer Services Manager at Liberty Insurance, Liberty Insurance, Dublin Road, Cavan, Co. Cavan or email@example.com.
Details about insurers' obligations to you regarding your information is contained in the Data Protection Commissioner’s Code of Practice on Data Protection for the Insurance Sector which you can view by visiting www.dataprotection.ie.
You can obtain confirmation on what information is held about you and your previous claims on Insurance Link by visiting www.inslink.ie.
This statement was last modified 11 November 2016.