Privacy and Security

DATA PROTECTION NOTICE – CUSTOMERS

This Data Protection Notice contains the information You need in order to understand how Your personal data is used by the Insurer and Intermediaries. This information is also available at www.sbisl.co.uk to read the full version, or contact us using the details in Section 11 below.

In this Data Protection Notice:
Insurer refers to the insurance companies on the Somerset Bridge Insurance Services Limited panel of insurers.

Intermediaries refers to third parties, who arrange insurance cover, as well as offer advice and handle claims.

You/Your refers to the policyholder or any other person insured or potentially insured by the contract or potential contract. It is the responsibility of the person seeking the quotation or arranging the insurance to convey the information in this Data Protection Notice to any other such person

Somerset Bridge means Somerset Bridge Insurance Services Limited (a company registered in England with registration number 6334001 and regulated by the FCA with registration number 477112 and for whom we act as an Appointed Representative.

We means Debenhams Retail Limited ( a company registered in England with registration number 83395) acting as an Appointed Representative for Somerset Bridge.

Appointed Representative means a company that can act on behalf of another company which acts as its principal and which is regulated by the FCA and for whom the principal company that they act on behalf of is responsible.

In order to manage our business and provide our services to customers, the Insurer and Intermediaries (we, us, our) collect a certain amount of personal data. “Personal data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information.

This Data Protection Notice sets out the basis on which we gather, use, disclose and process any personal data we collect from You, or that You provide to us. We will use Your personal data only for the purposes and in the manner set forth below which describes the steps we take to ensure our processing of Your personal data is in compliance with the General Data Protection Regulation ((EU) 2016/679) (the GDPR) and any implementing legislation.

Please read the following carefully to understand our use of Your personal data.

Your Right to Object – Please note that You have a right to object to the processing of Your personal data where that processing is carried out for our legitimate interests.

1. What Personal Data we May Collect about You?
In order to provide insurance quotes, insurance policies and deal with any claims or complaints, we need to collect and process personal data about You. If You do not provide the information we need, we may not be able to offer You a quote or provide our services to You. The types of personal data that are processed may include:

Category
Individual details
Types of Data Collected
Name, address, (including proof of address), other contact details such as email address and phone number, gender, marital status, date and place of birth, nationality, marketing preferences, IP address, bank account details or payment card details, vehicle details, relevant criminal convictions, penalty points, employer, job title and family member details, including their relationship to You.

Category
Identification details
Types of Data Collected
Identification numbers issued by government bodies or agencies, including Your driving license number and photographs identifying You.

Category
Credit and anti-fraud data
Types of Data Collected
Credit and anti-fraud data such as credit history, credit score, sanctions and criminal offences, and information from various anti-fraud databases relating to You.
Special categories of personal data and criminal convictions data
Certain categories of personal data which have additional protection under EU data protection law. These categories are health and criminal convictions.

Category
Claims information
Types of Data Collected
Information about previous and current claims, (including other unrelated insurances), which may include data relating to Your health (e.g. injuries and relevant pre-existing conditions), relevant criminal convictions, or other special categories of personal data mentioned above.

Category
Risk details
Types of Data Collected
Information about You which we need to collect in order to assess the risk to be insured and provide a quote. This may include data relating to Your health, relevant criminal convictions, or other special categories of personal data.

2. The Purposes of, and Legal Basis for the Processing of Your Personal Data
We hold, disclose and process Your personal data in order to provide you with insurance cover in accordance with our contract and to take steps at Your request prior to entering into a contract. This includes using Your personal data for:

  • Quotation and Inception;
  • Policy Administration;
  • Claims Processing; and
  • Renewals

We may also use Your personal data where:
a) it is necessary to comply with our legal and regulatory obligations (for example, complying with reporting obligations to the Financial Conduct Authority, the Prudential Regulatory Authority or other applicable regulatory authorities);
b) it is necessary to support our legitimate interests in managing our business, including in connection with (i) the administration of Your policy, (ii) improving our insurance products and services, (iii) prevention and detection of crime, (iv) general risk modelling, (v) transferring books of business, company sales and reorganizations; (vi) analytics provided in each such instance, they are not overridden by Your interests and rights; and (vii) obtaining reinsurance; and/or
c) You have consented to processing Your information in such a way.

3. Criminal Convictions>
The Insurer and Intermediaries may hold, use, disclose and process personal data relating to relevant criminal convictions and offences for the purposes identified above, where necessary to comply with our legal and regulatory obligations, or where necessary to support our legitimate interests. We will only carry out such processing where it is authorised by European Union (EU) or Member State law.

4. Special Categories of Personal Data
We hold, use, disclose and process special categories of personal data (e.g. Your health data) where:

  • You have given us Your explicit consent;
  • the processing is necessary to protect Your, or another’s vital interest;
  • You have manifestly made Your personal data publicly available;
  • the processing is necessary for the establishment, exercise or defence of legal claims; or
  • necessary for reasons of substantial public interest on the basis of law.

5. Who We Share Your Information with
In order to provide our services and to comply with legal obligations imposed on us, it may be necessary from time to time for us to disclose Your personal data to third parties, including without limitation to the following:

  • with the Insurer group, and our agents and third parties who provide services to us, Your Intermediary and other insurers (either directly or via those acting for the Insurer) to help us administer our products and services;
  • with regulatory bodies and law enforcement bodies(where we are required to do so to comply with a relevant legal and regulatory obligation);
  • legal, financial, medical and other professional advisors;
  • with the Insurer’s affiliates assisting with the operations of the Insurer; and
  • with the Insurer’s reinsurers, who provide reinsurance services to the Insurer. Reinsurers will use Your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. Reinsurers will keep Your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies. To the extent the reinsurer is a member of the Insurer group and is subject to GDPR, the reinsurer will process Your personal data where in its legitimate interests to do so. For further information please visit www.sbisl.co.uk

Some examples of the companies that we share your personal data with in order to carry out background checks or assist with your claims are; DVLA, Motor Insurance Bureau, Experian, Lexus Nexus, CUE (Claims & Underwriting Exchange), SIRA (Synetics Solutions Limited) Hunter (Experian), Bank Wizard Absolute (Experian), Iovation, Fraudstar, Featurespace.

6. Transfer of Personal Data outside the EEA
The personal data we collect from You may be transferred to, and stored at a destination outside of the European Economic Area (EEA) for purposes described above. These countries may not provide an adequate level of protection in relation to the processing of Your personal data. Due to the global nature of our business, Your personal data may be disclosed to members of our group outside of the EEA, including in particular Switzerland, Bermuda and the U.S.
However, to ensure that Your personal data receives an adequate level of protection we have put in place the following appropriate safeguards in place to protect the privacy and integrity of such personal data:

  • Model Clauses: standard clauses in our contracts with our above listed third parties to ensure that any personal data leaving the EEA will be transferred in compliance with EU data-protection law. Copies of our current Model Clauses are available on request by using the Insurers’ contact details listed in Section 11; and
  • EU/Swiss-U.S Privacy Shield: an agreement between the EU and the Governments of Switzerland and the U.S concerning the treatment of data concerning EU citizens. Some of our third parties are certified under the EU/Swiss-U.S Privacy Shield.

7. How Long we Keep Your Personal Data
We are required to ensure that Your personal data, as a policyholder, is accurate and maintained in a secure environment for a period of time no longer than necessary for the purposes for which we are processing Your personal data.

Information submitted for a quotation where you did not purchase our product may be retained by us for a period of up to 15 months from the date of the quotation. Where You purchase our insurance product, information will be held for the duration of Your insurance cover and a period of at least 23 years after the end of our relationship. We keep information after our relationship ends in order to comply with applicable laws and regulations and for use in connection with any legal claims.

8. Automated Decision Making
You have a right not to be subjected to decisions based solely on automated processing, including profiling, which produce legal effects concerning You or similarly significantly affects You. However in certain circumstances we are entitled to make decisions based on solely automated decision-making and profiling. These cases are restricted to situations where the decision is necessary for entering into a contract, or for performing that contract with You (i.e. Your policy of insurance or quote), where it is authorised by law or where You have provided Your explicit consent. Where we base a decision on solely automated decision-making You will always be entitled to have a person review the decision so that You can contest it and put Your point of view and circumstances forward.

9. Your Data Rights
You have several rights in relation to Your personal data. You have a right to:

  • access a copy of Your personal data held by us;
  • request rectification of Your personal data if it is inaccurate or incomplete;
  • request erasure of Your personal data in certain circumstances;
  • restrict our use of Your personal data in certain circumstances;
  • move (or port) personal data which You have given us to process on the basis of Your consent or for automated processing;
  • object to the processing of Your data where our legal basis for processing Your data is our legitimate interests; and
  • not to be subject to a decision based on automated processing, including profiling which has legal or similar significant affects.

However, these rights may not be exercised in certain circumstances, such as when the processing of Your data is necessary to comply with a legal obligation or for the exercise or defence of legal claims. If You wish to exercise any of Your rights in this regard please contact us using the details in Section 11. We will respond to Your request in writing, or orally if requested, as soon as practicable and in any event not more than one month after receipt of Your request. In exceptional cases, we may extend this period by two months and if we do this we will tell you why. We may request proof of identification to verify Your request.

10. Consequences of Failure to Provide Information
If the Insurer or the Intermediaries cannot collect information requested from You, it may make it difficult, impossible, or unlawful for us to give You advice on, provide You with, and administer our insurance products.

If the Insurer or the Intermediaries ask for information and You do not wish to give it to us, or if You wish to withdraw consent to the use of Your personal data, the Insurer or the Intermediaries will explain the consequences based on the specific information concerned including whether it is a legal or contractual requirement that we use such data. If You have any queries in respect of the consequences of not providing information or withdrawing Your consent, please contact the Insurer and Intermediaries listed using the details in Section 11.

11. Further Information
If You require any further information about how we use Your data or if You want to exercise any of Your rights under this Data Protection Notice, please contact the Insurer as detailed below:

Somerset Bridge Insurance Services Limited
Data Protection Officer
Somerset Bridge Insurance Services Limited
Lysander House
Catbrain Lane
Cribbs Causeway
Bristol
BS10 7TQ
Data Protection Officer
[email protected]

The Insurer encourages You to review this Data Protection Notice and explore the websites below where additional information about the processing of Your personal data may be found:

  • www.sbisl.co.uk/privacy-and-security/

If You wish to receive a copy of website information of the Insurer and/or the Intermediaries by post, please contact the Insurer and Intermediaries as listed above.

12. Your Right to Complain to the ICO
If You are not satisfied with our use of Your personal data or our response to any request by You to exercise any of Your rights in Section 9, You have the right to lodge a complaint with the Information Commissioner’s Office. Please see below contact details:

England Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Phone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
Email: [email protected]

Scotland
Information Commissioner’s Office
45 Melville Street
Edinburgh
EH3 7Hl
Phone: 0303 123 1115
Email: [email protected]

Wales
Information Commissioner’s Office
2nd Floor
Churchill House
Churchill way
Cardiff
CF10 2HH
Phone: 029 2067 8400
Email: [email protected]

Northern Ireland
Information Commissioner’s Office
3rd Floor
14 Cromac Place
Belfast
BT7 2JB
Phone: 0303 123 1114 (local rate) or 028 9027 8757 (national rate)
Email: [email protected]

13. Important Information about This Data Protection Notice>
Each Insurer and Intermediary providing this Data Protection Notice to You is a separate legal entity and separate data controller in respect of Your personal data.

Terms & Conditions

Debenhams Retail Limited is an Appointed Representative of Somerset Bridge Insurance Services Limited who are authorised and regulated by the Financial Conduct Authority. No 477112. Somerset Bridge Insurance Services Ltd is registered in England and Wales No. 06334001. Registered office Lysander House, Catbrain Lane, Cribbs Causeway, Bristol, BS10 7TQ.

T&Cs apply, please visit: https://www.debenhamsgadgetinsurance.com/

T&Cs apply, please visit: http://www.debenhamslifeinsurance.com

About the switch

 

Somerset Bridge Insurance Services are committed to providing you with great service, and we look forward to providing you with continued cover under our Vavista brand.

Is my cover the same?

Yes. There is no change to your level of cover or policy terms only the brand name has changed

I pay for my insurance monthly, do I need to change my Direct Debit?

No. You do not need to do anything and your current payments will continue from your bank account at the same time each month. Due to the change detailed within this email you will see the name on your bank account appear as Vavista INS and not Debenhams INS.

Do I have to do anything because of this change?

No. There is no change to your level of cover or policy terms, only the brand name has changed.

Will there be any changes to my renewal because of this change?

No. Once your renewal is due, we will follow the same process of finding you the best possible price via our panel of insurers and will write to you with your renewal quote. The only change is that your renewal will be branded as Vavista.

Are there any benefits being a Vavista customer?

Debenhams policyholders can benefit by accessing exclusive wellness content on our website. Which includes a range of interactive modules, webinars and other resources to help care for you, as well as the planet. You can find out more information in the recent email we sent you.

For every policy sold or renewed we plant a tree. We have already funded over 117,000 trees on behalf of our customers and to celebrate Debenhams customers moving to Vavista we have made a donation to plant a further 10,000 trees. You can find out more about our healthy planet initiative here.

How do I contact you?

If you have any Debenhams insurance numbers stored in your phone or written down these will still work for the time being. You can also contact us between 9am and 5:30, Monday to Friday, by calling 0344 776 5324. This includes any changes you may wish to make to your policy. Alternatively, you can email us at [email protected].

What if I have a claim in progress?

Existing claims will remain unchanged and will continue to be processed as normal by your insurer. If you need to make a claim please refer to your policy documents.

What if I don’t want to be a Vavista customer?

We would like to reassure you that the only thing that has changed is the brand of your policy, the level of cover remains exactly the same. However, if you would like to cancel your policy please get in touch via 0344 776 5324 or [email protected]