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Identity Protection from CPP provides support, expertise and insurance cover to help you combat and recover from identity theft and identity fraud.

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Card Protection is a comprehensive service for use in the event of card loss, theft and related fraud.

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Definitions in the Identity Protection Alert product terms and conditions apply when used in this Privacy Notice.

  1. Information about CPP and the Insurer

CPP is registered as a data controller with the Information Commissioner’s Office (“ICO”) under registration number Z5773216. The Insurer is registered as a data controller with the ICO under registration number Z5107254.

The Insurer and CPP are part of the CPPGroup Plc group of companies (“CPP Group”). You can find out more about the CPP Group by visiting www.cppgroup.com.

The Insurer and CPP take the privacy of their customers seriously. Both the Insurer and CPP are responsible for the personal information which You provide to them.

If You have any questions about this Privacy Notice, including any requests to exercise Your legal rights, please get in touch using the following contact details:

 

  1. What personal information is collected?

The Insurer and CPP may collect and use the following information:

  • Your name and contact information (including email address and mobile phone number) and any other contact details You provide to the Insurer or CPP or to a business partner who introduced You to the Insurer or CPP, which includes card providers and banks;
  • Your date of birth;
  • financial information including bank account details and card payment details;
  • if You have chosen to register these with CPP, details of Your passport and/or driving licence;
  • information that You provide when You renew Your Policy;
  • answers to additional security questions which You provide;
  • records of any correspondence with You regarding any specific enquiry You make, for example if You call, email or write to the Insurer or CPP. The Insurer and CPP will also hold copies of letters or emails You send or documents You provide in relation to Your Policy where this is relevant, for example bank statements; and
  • information about other products and services You obtain from members of the CPP Group.

 

  1. How the Insurer and CPP use Your personal information

The Insurer and CPP will only use Your personal information when the law allows them to. Most commonly, the Insurer and CPP will use Your personal information where:

  • CPP needs to perform the CPP Agreement;
  • the Insurer needs to perform the contract for the Policy it is about to enter into or has entered into with You;
  • it is necessary for the Insurer’s and/or CPP’s legitimate interests (or those of a third party) and Your interests and fundamental rights do not override those interests; or
  • required to comply with a legal or regulatory obligation.

If CPP processes Your personal information for direct marketing purposes it will do so on the basis that You have given Your consent to the processing of Your information for this specific purpose.

 

  1. What do the Insurer and CPP do with Your personal information?

Set out in the table below is a description of all the ways the Insurer and CPP use Your personal information, and the legal bases they rely on to do so. This identifies what the Insurer’s and/or CPP’s legitimate interests are, where appropriate. The Insurer and CPP may process Your personal information for more than one lawful ground depending on the purpose for which they are using the information. Please get in touch if You need details about the specific legal ground relied on to process Your information where more than one ground has been set out in the table below.

 

 Data  Controller

 Purpose/Activity

Lawful basis for processing including basis of legitimate interest

The Insurer  

To make decisions on Your Product, including at renewal. The Insurer  does not envisage that any decisions will be taken about You using automated means, however the Insurer will notify You in writing if this position changes

Performance of the contract for the Policy

The Insurer  

To provide You with and manage the Policy and provide the insurance benefits described in these terms and conditions

Performance of the contract for the Policy

The Insurer  

To process any Claim You make in connection with Identity Fraud

Performance of the contract for the Policy

The Insurer  

To communicate with You by e­mail, telephone or post if You have purchased a Policy from the Insurer, either regarding the purchase or other matters regarding transactions between You and the Insurer or Your customer relationship with the Insurer

Performance of the contract for the Policy

The Insurer  

To contact You regarding any specific enquiry You make

Performance of the contract for the Policy

The Insurer  

To improve its products and services

Necessary for the Insurer’s legitimate interests (to develop its business and inform its marketing strategy)

The Insurer  

Fraud prevention

Necessary to comply with a legal obligation

The Insurer  

Debt collection

Necessary for the Insurer’s legitimate interests (to recover debts due to it)

CPP

To make decisions on Your Product, including at renewal. CPP does not envisage that any decisions will be taken about You using automated means, however CPP will notify You in writing if this position changes

Performance of the contract for the CPP Agreement

CPP

To process and collect payments from You, including on behalf of the Insurer, when due in relation to Your Product

Performance of the contract for the CPP Agreement

CPP

To introduce You to the Insurer in respect of Your Policy renewal

Performance of the contract for the CPP Agreement

CPP

To provide You with and manage the CPP Agreement and provide the services provided under this

Performance of the contract for the  CPP Agreement

CPP

To communicate with You by e-mail, telephone or post regarding  transactions between You and CPP or Your customer relationship with CPP   

Performance of the contract for the  CPP Agreement

CPP

To contact You regarding any specific enquiry You make

Performance of the contract for the  CPP Agreement

CPP

To contact You by e­mail, telephone or post in order to share information with You about products, services and events from CPP and other members of the CPP Group that may be of interest to You

You have consented to this.

CPP

To contact You for market research purposes, if You have not objected to such use

Necessary for CPP’s legitimate interests (to help it provide a better service to You, and to develop and improve its products and services)

The Insurer  and CPP

Internal record keeping

(a) Necessary for the Insurer’s and CPP’s legitimate interests (for running their businesses) (b) Necessary to comply with a legal obligation

The Insurer  and CPP

Statistical analysis

Necessary for  the Insurer’s and CPP’s legitimate interests (to study statistical trends within their businesses, to develop their businesses and inform their marketing strategies)

The Insurer  and CPP

To confirm Your correct address with third party ID service providers in order to contact or update You as required

(a) Necessary for the Insurer’s and CPP’s legitimate interests (for running their business and helping to provide a better service to You (b) Necessary to comply with a legal obligation

 

  1. If You fail to provide personal information

Where the Insurer and/or CPP need to collect and use personal information by law, to enter into a contract with You, or under the terms of a contract they have with You, and You fail to provide that information when requested, then CPP may not be able to enter into or perform the CPP Agreement and/or the Insurer may not be able to enter into or perform the contract for the Policy.

 

  1. Direct Marketing and Market Research

CPP may wish to provide You with information about CPP Group’s new products, promotions, special offers and other information which may be of interest to You and invite You to take part in market research. This may occur by post, telephone, email or SMS (unless You have asked us not to do so).

CPP will ensure that any direct marketing or market research that You receive or are contacted about by electronic means provide a simple means for You to opt-out. For example, in emails it may provide You with an ‘unsubscribe’ link.

You can change Your mind at any time about marketing or taking part in market research by informing CPP using the contact details in section 1 of this Privacy Notice. In such cases CPP would not necessarily remove all Your personal information from its database(s) but would note and respect Your changed preferences. CPP will stop any marketing or market research to which You object or withdraw Your consent to within a reasonable period, in order to allow sufficient time for the change to be administered.

 

  1. Who does the Insurer and CPP share Your personal information with?

Service Providers

Your personal information will be made available to authorised service providers (including other companies in the CPP Group which provide services to the Insurer and CPP, and CPP when it is acting as a service provider to the Insurer) and third party suppliers, including ID checking service providers, which perform certain services on the Insurer’s and/or CPP’s behalf e.g. confirming the current address for policyholders, providing certain benefits under the Product, providing IT support and maintenance, providing hosting services, providing online payment services and providing marketing services.

These service providers may have access to personal information needed to perform their functions but are not permitted to share or to use such information for any other purpose. The Insurer and CPP require all third parties to respect the security of Your personal information and to treat it in accordance with the law.

 

When You make a Claim

If You make a Claim, the Insurer or CPP may share Your information with the police, other insurers and fraud prevention agencies to prevent fraudulent claims.

 

Third party companies who provide aspects of the Product

Cifas

If You consent, Your personal information may be passed to Cifas in accordance with the Protective Registration feature of Your Product. In this case Your personal information will be used to create a Protective Registration record about You within the Cifas National Fraud Database, which will then be made available to the members of Cifas and to fraud prevention agencies participating in Cifas. The Protective Registration record will be used to help prevent fraud and money-laundering and to verify Your identity. There may be a slight delay when You apply for financial products and services as extra checks are made. Where the risk of fraud is very low some companies may instead accept the application and then contact You separately to ensure the application is from You. Further details of how Your information will be used by Cifas when using this aspect of the Product, and Your data protection rights, can be found by contacting CPP on the contact details set out in paragraph 1 of this Privacy Notice.

 

Experian

As set out in the Experian Identity Plus Service feature of Your Product, You will be required to register with Experian for the Experian Identity Plus service and when You register, You will be required to agree to their Privacy Policy (which can be found at https://cpp.experiancs.co.uk/documents/privacypolicy.pdf).

If You request a copy of Your credit report, Your personal details will be passed to Experian so they can provide You with this. Experian will verify Your identity by checking the details You provide against details held on databases to which they have access. Experian will keep a record of this check which may be used by other organisations for verification and fraud prevention services. If You have requested a copy of Your credit report, the Insurer or CPP may ask Experian to provide them with Your updated personal and contact information to ensure that their records remain accurate. If You register for Experian’s Identity Plus Web Monitoring services, the ‘Privacy Policy’ on the website at https://cpp.experiancs.co.uk/documents/privacypolicy.pdf will explain how Your personal information is used. They will only share Your personally identifiable information with third parties to carry out Your instructions and to provide specific services.

All communications between You and the Experian Identity Plus website, while logged in, are protected through secure socket layer (SSL) encryption. All information You provide to them is stored on their secure servers. Experian asks for Your permission before sending You email communications.

 

Other companies within the CPP Group

The Insurer and CPP may share limited personal information with companies in the CPP Group e.g. to the extent needed for proper management and parental analysis and decision making.

 

Other organisations

The Insurer and/or CPP may also disclose Your personal information:

  • When they are required to do so in the course of providing You with the features of the Product.
  • In response to a court order, or a request for cooperation from a law enforcement or other government agency;
  • To establish or exercise the Insurer’s or CPP’s legal rights; to defend legal claims; or as otherwise required or permitted by applicable laws and/or regulations;
  • When the Insurer or CPP believe that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property or safety of the Insurer or CPP, other CPP Group members, customers, staff, suppliers or others; to comply with applicable law or cooperate with law enforcement; or to enforce the Insurer’s or CPP’s terms or other agreements;
  • To prospective or actual buyers in the event that the Insurer or CPP sell any of their business or assets, or to other CPP Group members in the event of a reorganisation. The Insurer and CPP will not otherwise transfer, disclose, sell, distribute or lease Your personal information to third parties unless they have Your permission to do so or are otherwise required or permitted to do so by law.

 

  1. Will personal information be transferred abroad?

The Insurer and CPP will ensure that if they transfer Your personal information from countries inside the European Economic Area (“EEA”) to countries outside the EEA, adequate safeguards are put in place to protect Your personal information in accordance with any applicable data protection legislation from time to time in force including the Data Protection Act 2018 or any successor legislation and (for so long as and to the extent that the law of the European Union has legal effect in the UK) the General Data Protection Regulation (GDPR). Please get in touch using the contact details set out in section 1 of this Privacy Notice if You want further information on the specific mechanism used by the Insurer and/or CPP when transferring Your personal data out of the EEA.

 

  1. How long will the Insurer and CPP hold personal information?

The Insurer and CPP will not retain Your personal information for longer than necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. Please note that by law the Insurer and CPP have to keep basic information about their customers (including contact details, financial information and details relating to policies) for at least seven years after they cease being a customer for tax and legal purposes.

 

  1. Your rights

Under certain circumstances, by law You have the right to:

  • Request access to Your personal information (commonly known as a “data subject access request”). This enables You to receive a copy of the personal information the Insurer or CPP holds about You and to check that it is lawfully processing it.
  • Request correction of the personal information that the Insurer or CPP holds about You. This enables You to have any incomplete or inaccurate information the Insurer or CPP holds about You corrected. If You think any information the Insurer or CPP has about You is incorrect or incomplete, please contact the Insurer or CPP as soon as You can using the contact details set out below so that this can be corrected or updated as soon as possible.
  • Request erasure of Your personal information. This enables You to ask the Insurer or CPP to delete or remove personal information where there is no good reason for continuing to process it. You also have the right to ask the Insurer or CPP to delete or remove Your personal information where You have successfully exercised Your right to object to processing (see below), where the Insurer or CPP may have processed Your information unlawfully, or where the Insurer or CPP are required to erase Your personal information to comply with the law. Note however, that the Insurer and CPP may not always be able to comply with Your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of request.
  • Object to processing of Your personal information where the Insurer or CPP are relying on a legitimate interest (or those of a third party) and there is something about Your particular situation which makes You want to object to processing on this ground. You also have the right to object where CPP are processing Your personal information for direct marketing purposes.
  • Request the restriction of processing of Your personal information. This enables You to ask the Insurer or CPP to suspend the processing of Your personal information, for example if You want the Insurer or CPP to establish its accuracy or the reason for processing it.
  • Request the transfer of Your personal information to another party.

 

If You want to exercise any of these rights, please get in touch using the contact details set out in section 1 of this Privacy Notice. You will not have to pay a fee to access Your personal information (or to exercise any of the other rights). However, the Insurer and CPP may charge a reasonable fee if Your request for access is clearly unfounded or excessive. Alternatively, the Insurer and CPP may refuse to comply with the request in such circumstances.

The Insurer and CPP may need to request specific information from You to help confirm Your identity and ensure Your right to access the information (or to exercise any of Your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

The Insurer and CPP will try to respond to all legitimate requests within one month. Occasionally it may take the Insurer and CPP longer than a month if Your request is particularly complex or You have made a number of requests. In this case, the Insurer and/or CPP will notify You and keep You updated.

You also have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues. The ICO’s contact number is 0303 123 1113 and further contact details can be found at this website https://ico.org.uk/global/contact-us. The Insurer and CPP would, however, appreciate the chance to deal with Your concerns before You approach the ICO so please contact the Insurer and/or CPP in the first instance.