Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and what to do if you have a complaint.

This privacy policy does not apply to any third-party websites that may have links to our own website.

1 Who are we and what do we do?

Union Income Benefit Holdings Ltd is a company specialising in insurance and financial products. We are authorised and regulated by the Financial Conduct Authority to distribute non-investment insurance products, register number 307575. This can be checked on the FCA website: www.fca.org.uk. Our contact details can be found at section 16.

We collect, use and are responsible for certain personal data about you. When we do so we must comply with the UK General Data Protection Regulation (UK GDPR). If you are in the European Union we must also comply with the EU General Data Protection Regulation (EU GDPR) in relation to our services we offer to such individuals. We are independent of your Union and we are responsible for processing your personal data not the Union.

2 Terminology

It would be helpful to start by explaining some key terms used in this policy:

We, us, our - We are Union Income Benefit Holdings Ltd (UIB). Our registered office is 14th Floor 33 Cavendish Square, London, W1G 0PW and our company registration number is 03877610. We are registered with the Information Commissioner’s Office and our registration number is Z5289358.

We are part of the Embignell Group, a full list of the group companies and our trading names can be found here:

Embignell group companies and trading names

Personal data - Any information relating to an identified or identifiable individual

Special category personal data - Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic data. biometric data (where used for identification purposes) and data concerning health, sex life or sexual orientation

Data subject - The individual who the personal data relates to

3 Personal data we collect about you

We collect or use the following information:

Your name, address and telephone number
Information to enable us to check and verify your identity, for example your date of birth or passport details
Gender and pronoun preferences
Occupation and employment details
Marital status
Electronic contact details, for example your email address and mobile phone number
Information relating to, and administrating or assisting in the administration of the taking out and maintaining a policy of insurance and any claims made
Information to enable us to undertake identity or other credit and financial checks on you
Your financial details so far as relevant to your insurance policy
Payment details (including card or bank information for transfers and direct debits)
Information about how you interact with and use our website, products, services and social media presence
Audio recordings such as calls
Details of your spouse/partner and dependents or other family members or nominated beneficiaries of a policy of insurance
Health information such as your medical records or medical reports to administrate, or assist in the administration of, a policy of insurance and any claims made
If you have come to us through a trade union, your trade union membership details

The main purpose of collecting and using this information is to provide and administer the insurance products we offer to you. However, we may also collect and use the above information for the purposes set out in section 5.

If you do not provide personal data we ask for, it may delay or prevent us from providing insurance services including assisting in administrating any claims.

4 How your personal data is collected

We collect most of the above information from you.

However, we may also collect information directly from a third party, for example:

those who provide us with your details where you have expressed an interest in hearing about insurance products
your doctors, medical and occupational health professionals
your employer
your trade union
the electoral role or other identity provider
other interested parties who may provide information to us such as Insurers, Coroners, Police or other government agencies and your representatives
other companies within the Embignell Group or other third-party insurance brokers
via our website—we use cookies and similar technologies on our website (for more information on cookies, please see our Cookie Policy); and
via our security, information technology (IT) systems.

5 How and why we use personal data

Under data protection law, we can only use your personal data if we have a proper reason, for example:

you have given consent—where we need your consent, we will ask for it separately of this privacy policy and you can withdraw consent at any time;
to comply with our legal and regulatory obligations;
to fulfil any contractual obligations with you or take steps at your request before entering into such a contract; or
for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You have the right to object to processing based on legitimate interests. We must then stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms or the processing is required to establish, exercise or defend legal claims.

We use your personal data for the following reasons:

Providing services to you. We may use your personal data to fulfil our contractual obligations with you or to take steps at your request before entering into such a contract.
To act as a point of query and in order to assist in the administration of a policy of insurance and any claims made.
Preventing and detecting fraud against you, us or a third party. We may use your personal data for our and/or your legitimate interests or that of a third party, ie to minimise fraud that could be damaging for you, us or a third party.
Conducting checks to verify the identify customers and other activities necessary to comply with professional, legal and regulatory obligations that apply to our business. Depending on the circumstances we may use your personal data to comply with our legal and regulatory obligations or for our legitimate interest to protect our business, interests and rights.
To enforce legal rights or defend or take legal proceedings. Depending on the circumstances we may use your personal data to comply with our, or a third party’s, legal and regulatory obligations or for our, or a third party’s, legitimate interests to protect our business, interests and rights and those of a third party.
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies. Depending on the circumstances we may use your personal data to comply with our legal and regulatory obligations or for our legitimate interests to protect our business, interests and rights.
Ensuring internal business policies are complied with, for example policies covering security and internet use. We may use your personal data for our legitimate interests to make sure we are following our own internal procedures so we can deliver the best service to you.
Operational reasons, such as improving efficiency, training and quality control. We may use your personal data for our legitimate interests to be as efficient as we can so we can deliver the best service to you.
Ensuring the confidentiality of commercially sensitive information. Depending on the circumstances we may use your personal data for our legitimate interests to protect trade secrets and other commercially valuable information and to comply with our legal and regulatory obligations.
Statistical analysis to help us manage our business. We may use your personal data for our legitimate interests to be as efficient as we can so we can deliver the best service to you at the best price.
Protecting the security of systems and data used to provide services, preventing unauthorised access and changes to our systems. Depending on the circumstances we may use your personal data for our legitimate interests to prevent and detect criminal activity that could be damaging for you and/or us and to comply with our legal and regulatory obligations.
Updating and enhancing customer records. Depending on the circumstances we may use your personal data to fulfil our contract with you or to take steps at your request before entering into a contract, to comply with our legal and regulatory obligations or for our legitimate interests to ensure we can keep in touch with our customers about existing and new services.
Providing information updates and/or marketing our services and those of selected third parties to existing and former customers and third parties. Depending on the circumstances we may use your personal data for our legitimate interests to promote our business. Where we collect consent you can withdraw this at any time.
Credit checks. Depending on the circumstances we may use your personal data to comply with our legal and regulatory obligations or for our legitimate interests to assist in the administration of insurance policies.
To handle complaints. Depending on the circumstances we may use your personal data to comply with our legal and regulatory obligations or for our or your legitimate interests to ensure complaints are dealt with properly.
External audits and quality checks. Depending on the circumstances we may use your personal data for our legitimate interests to achieve and maintain relevant accreditations so we can demonstrate we operate at the highest standards and to comply with our legal and regulatory obligations.
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary. Depending on the circumstances we may use your personal data to comply with our legal and regulatory obligations or for our legitimate interests to protect, realise or grow the value in our business and assets.
Where we process special category personal data (see section 2 ‘Terminology’), we will also ensure we are permitted to do so under data protection laws, for example:
we have your explicit consent;
the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent;
the processing is necessary to establish, exercise or defend legal claims; or
the processing is necessary for reasons of substantial public interest.

6 Marketing

We may use your personal data to send you updates (for example by email, text message, telephone, post or social media channels) about our services and the services of others within the Embignell group, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see section 5 ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information about our products. Where this is not the case, we will always ask for your consent.

In all cases, you have the right to opt out of receiving marketing communications at any time by:

contacting us at dataprotection@embignell.com;
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.

7 Who we share your personal data with

We routinely share personal data with:

companies within the Embignell Group (see section 2 ‘Terminology’);
providers of insurance products;
your trade union
third parties we use to help deliver our services to you, for example providers of our case management and finance system, IT service providers including cloud service providers such as data storage platforms, shared service centres and financial institutions in connection with invoicing and payments;
third party external advisors or experts engaged in assisting the course of providing you with a policy of insurance and assisting with its administration and any claims, for example your doctors, medical and occupational health professionals;
other third parties we use to help promote our business, for example marketing agencies;
our banks;

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We ensure all outsourcing providers operate under service agreements that are consistent with our legal and professional obligations.

We or the third parties mentioned above may occasionally also share personal data with:

our external auditors, for example in relation to the audit of our organisation, in which case the recipient of the information will be bound by confidentiality obligations
our professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations and to protect our business, interests and rights and those of interested third parties.
claims investigators and validators to protect our business, interests and rights and those of interested third parties.
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition or asset sale or in the event of our insolvency. Usually, information will be anonymised but this may not always be possible and the recipient of any of your personal data will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us as section 16).

8 Where your personal data is held

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described in section 7 ‘Who we share your personal data with’.

Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see section 10 ‘Transferring your personal data abroad’.

9 How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law.

As a general rule, we will keep your personal data for at least ten years from the conclusion of our relationship, in case you, or we, need to bring or defend any complaints or claims. However, different retention periods apply for different types of personal data which is determined by our retention policy.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

If you would like further information about how long we keep your personal data, please contact us (see ‘How to contact us at section 16).

10 Where your personal data is held

Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see section 10 ‘Transferring your personal data abroad’.

11 How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

If you would like further information about how long we keep your personal data, please contact us (see ‘How to contact us at section 16).

12 How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

If you would like further information about how long we keep your personal data, please contact us (see ‘How to contact us at section 16).

13 Your rights

You have the following rights, which you can exercise free of charge:

Access - You have the right to ask us for copies of your personal data. You can request other information such as where we get personal data from and who we share personal data with. There are some exemptions which means you may not receive all the information you ask for
Rectification - You have the right to ask us to correct or delete personal data you think is inaccurate or incomplete.
Erasure (also known as the right to be forgotten) - You have the right to ask us to delete your personal data in certain situations.
Restriction of processing - You have the right to ask us to limit how we use your personal data in certain situations, for example if you contest the accuracy of the data.
Data portability - You have the right to ask that we transfer the personal data you gave us to another organisation or to you in certain situations.
To object - You have the right to object at any time to your personal data being processed for direct marketing (including profiling) and in certain other situations to our continued processing of your personal data, for example processing carried out for our legitimate interests unless we are able demonstrate compelling legitimate grounds for the processing which override your interests or for establishing, exercising or defending legal claims.
Not to be subject to automated individual decision making - The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consent - When we use your consent as our lawful basis, you have the right to withdraw that consent at any time. You may withdraw consents by contacting us at dataprotection@embignell.com. Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

If you make a request, we must respond to you without undue delay and in any event within one month.

If you would like to exercise any of those rights, please:

email, call or write to us—see section 16 ‘How to contact us’; and
provide enough information to identify yourself for example your full name, address and any reference or policy number and any additional identity information we may reasonably request from you;
let us know what right you want to exercise and the information to which your request relates.

14 Keeping your personal data secure

We have implemented appropriate technical and organisational measures to keep your personal data confidential and secure from unauthorised access, use and disclosure. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We require our business partners, suppliers and other third parties to implement appropriate security measures to protect personal data from unauthorised access, use and disclosure.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are required to do so.

15 How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see ‘How to contact us’ at section 16). We hope we will be able to resolve any issues you may have.

You may also have the right to lodge a complaint with the Information Commissioner’s Office (the UK data protection regulator also known as the ICO).

The contact details for the ICO are: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113

16 Changes to this privacy policy

We may change this privacy policy from time to time. When we do we will publish the updated version on our website and ask for your consent to the changes if legally required.

17 Updating your personal data

We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please contact customer services if any of the personal data you have provided to us has changed, for example your surname or address—see ‘How to contact us’ at section 16.

18 How to contact us

You can contact us and or our Group Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to update your personal details, to exercise a right under data protection law or to make a complaint.

Our contact details are below:

By Email:

Group Data Protection Officer/Data Protection Team - dataprotection@embignell.com

Customer Services - customercare@uibuk.com

By post:

Customer Services, Union Income Benefit Holdings Ltd, Fleet Street 154, 160 Fleet Street, Blackfriars, London, EC4A 2DQ

By telephone:

Customer Services: 0343 178 1255

19 Do you need extra help?

If you would like this policy in another format (for example audio, large print, braille) please contact customer care—see ‘How to contact us’ at section 16.