MISSION UNDERWRITERS PRIVACY NOTICE

This privacy notice is issued by Mission Underwriters together with its subsidiaries (“we”; “us” and “our”) and relates to our use of personal data (referred to as “data”) concerning living persons.

Do we process personal data?

We may process data from the following categories of persons (collectively “Insurance Contacts”):

insured persons, insurance applicants and policyholders (“Insureds”);
beneficiaries and other persons named in the insurance policy (“Beneficiaries”);
persons filing a claim under an insurance policy (“Claimants”);
persons who serve as a witness in light of an insurance claim (“Witness”);
and any other person who has had dealings with the Insured in respect of the Insured’s financial interest in their insurance policy.

Additionally, we may process data from the following categories of persons other than Insurance Contacts:

individuals working for one of our business partners (“Business Contacts”);
individuals who otherwise interact with us online or offline, for instance by visiting our offices or filing a general request for information via our website (“General Contacts”); and
individuals who use and visit our website (“Website Visitors”).

In each case, we respect your privacy rights and your rights as a data subject. We will manage and protect your data accordingly, whilst it is in our hands, in accordance with all applicable data protection legislation and in accordance with this privacy notice.

Who is the Data Controller?

We are registered with the Information Commissioner’s Office in the UK, as a data controller, under the registration number of ZB456263. We can be contacted at the following address:

Mission Underwriting UK Limited
One Fleet Place
London
EC4M 7WS

For enquiries relating to how your data is processed, you can contact us at the following address: DPO@missionunderwriters.co.uk

How Will We Use Your Data?

We will use data in the normal course of business to:

Administer insurance policies.
Underwrite insurance policies (including aggregating data with other similar data for actuarial purposes).
Handle claims on insurance policies for Claimants.
Deal with any complaints that you may have.
Verify your identity.
Confirm with third parties that you have received insurance cover.
Where we have a legal basis to do so; help us to identify and market products that may be of interest to you.
Detect and prevent financial crime.

We may use your data, in the course of our business, for the prevention and detection of fraud. Where we suspect fraud, this may entail:

Sharing your data with public bodies including the Police.
Undertaking fraud searches.
Checking your data against fraud prevention databases.

What is the Purpose of Data Processing?

For persons who are Insurance Contacts; we require to process your data in order to arrange and administer a contract of insurance between the Insured and Accelerant Insurance Europe SA (“the Insurer”).

The legal basis for processing your data are as follows:

Processing data is necessary for the arrangement of the insurance contract between the Insured and the Insurer; and the Insurer’s performance of the insurance contract which you will be party to.
Processing your data is necessary for our compliance with certain legal obligations (such as the detection and prevention of financial crime).
Processing your data is necessary in pursuit of our and the Insurer’s legitimate interests in arranging the Insured’s insurance contract.

How Did We Receive Your Data?

If you are an Insured; we will have received your data from either an insurance broker or insurance customer arranging insurance either on your behalf or on behalf of an Insurer.

On occasion, we may also receive/collect your personal data directly from you, such as when you are a Website Visitor or where you are otherwise in direct contact with us. We may also receive your personal data from the following sources:

Persons and companies you are affiliated with or related to including your family members, employer or representative;
We automatically collect certain information when you visit or use our Website;
Credit reference agencies;
Reinsurance companies and other third-party insurance companies with whom you have, had, are applying for, or have filed a claim under an insurance policy;
Anti-fraud databases (such as Claims and Underwriting Exchange (CUE) and Motor Insurance Anti-Fraud Theft Register (MIAFTR) databases), sanctions lists, court judgements and other public databases;
Government agencies (such as the Driver and Vehicle Licensing Agency and HM Revenue and Customs);
Open electoral registers and other publicly available registers such as company registers;
Supervisory, regulatory and other public authorities;
In the event of a claim, third parties including the other party to the claim (claimant/defendant), witnesses, experts (including medical experts), loss adjustors, external counsel, and claims handlers;
Service providers such as organisations operating our website; and
Other public and non-public sources including information that is publicly available online.

What Types of Data Do We Process?

The data we process depends on your relationship with Mission as set out above and whether collection is permitted by applicable law. We collect and process the following categories of data from you:

Categories of Personal Information	Relationship with Mission
Website usage data and related identifiers such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform. Personal Information collected by us also may automatically include information about your visit, including the full Uniform Resource Locators (URLs); clickstream to, through and from our site (including date and time); what you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks and mouse-overs); and methods used to browse away from the page. Please refer to our Cookies Policy for more information about how we use cookies.	Website Visitors
Individual details – name, address, gender, marital status, date of birth, nationality, marketing preferences, vehicle details, penalty points, and family details, including their relationship to you. Contact details, as well as further individual information about you in relation to a claim being made under a policy of insurance such including special categories data – such as medical / health information or criminal history – if the nature of the claim necessitates this. Identification details – identification numbers issued by government bodies or agencies, such as your national insurance number, passport number, tax identification number and driving licence number. Employment history – including information on your previous and current employer, job title, salary, employment benefit option, professional licences and educational/professional qualifications. Financial information – such as bank account or payment card details, income, investment or other financial information including home valuation and household income. Policy/Contractual information – such as details about quotes you receive and policies you hold and with whom you hold them. Fraud and credit related data – such as credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to you. Risk coverage details – information necessary to assess the risk to be insured and provide a quote. This may include data relating to your health, criminal convictions, or other special categories of Personal Information. For certain types of policies, this could also include telematics data. Previous and current claims – information about previous and current claims (including other related insurances), which may include data relating to your health, criminal convictions, or other special categories of Personal Information and, in some cases, surveillance reports. Special categories of Personal Information and criminal convictions data – data concerning your health and criminal offences and convictions data.	Insureds Beneficiaries Claimants
Contact details, as well as further individual information about you in relation to a claim being made under a policy of insurance such including special categories data – such as medical / health information or criminal history – if the nature of the claim necessitates this.	Witnesses
Professional information and contact details such as information about your employer, your position/title and your professional contact details.	Business Contacts
Your marketing preferences.	Website Visitors Business Contacts General Contacts
Inferences drawn from the above-referenced categories of information to assess risk.	All Insurance Contacts
Any other information you voluntarily share with us e.g. when you contact our customer service or otherwise engage with us.	Website Visitors All Insurance Contacts Business Contacts General Contacts

We only process your special category and/or criminal data where strictly necessary. When we do, we will ask for your explicit consent where such is required in accordance with applicable data protection law, or we rely on a specific authorisation in law that allows us to process this information.

Our Lawful Basis for Processing your Data?

We will only use and process your data where we have a purpose and a legal ground to do so (where this is required under applicable data protection law). We use and process data for the purposes and legal grounds set out below, depending on your relationship with us and whether the processing is permitted under applicable law:

Purpose	Relationship with Mission	Legal Ground
To consider an application for an insurance policy, assess and evaluate risk, determine the scope, risk coverage and premium of the policy and where applicable, provide you with insurance cover and any associated services. To manage and administer contracts including or with regard to insurance policies (including dealing with your queries) with you, your employer, our service providers. To manage and administer claims under an insurance policy, including assessing and evaluating the merits of a claim and, where relevant to pay a settlement. To monitor risks and claims by performing spot checks. To perform data analysis, draw up insurance-specific statistics and risk qualifications, and to otherwise improve our insurance and underwriting products and services and carry out market research and risk modelling. To comply with our legal and regulatory obligations as an insurance company, including responding to requests from public authorities and fraud and money laundering prevention.	Insureds Beneficiaries Claimants	The processing of your data is necessary to perform a contract to which you are a party (the insurance policy) or to take steps prior to entering into a contract with you. The processing of your data is necessary for us to comply with legal and regulatory obligations. The processing of your data is necessary to support our legitimate interests in managing our business (or those of a third party), in particular to administer insurance policies and applications, claims and assess risk.
To manage and administer claims under an insurance policy, including assessing and evaluating the merits of a claim and, where relevant to pay a settlement.	Witnesses	The processing of your data is necessary to support our legitimate interests in managing our business (or those of a third party), including to administer claims.
Communicating with you and responding to your queries and complaints, providing you with information about our business upon your request, offering you customer service, and operating, securing and improving our website.	Website Visitors	We have a legitimate interest to operate our website and communicate with you upon your request.
Contact you with respect to products and/or services offered by us which we believe may interest you (including direct marketing).	Insureds Claimants Website Visitors General Contacts	We have a legitimate interest to communicate with you upon your request and send you direct marketing for related products or services. Depending on your location, we may also ask for your consent prior to sending you direct marketing.
Carrying out audits and investigations, and to investigate and resolve complaints, grievances or misconduct.	Website Visitors Insurance Contacts Business Contacts General Contacts	We have a legitimate interest to manage our business and to ensure that all investigations and proceedings are managed efficiently and effectively. We have a legal obligation to do so.
Preparing for and acting in relation to enquiries, investigations or proceedings, by governmental, administrative, judicial or regulatory authorities, including civil litigation.	Website Visitors Insurance Contacts	We have a legitimate interest to manage our business and to ensure that all investigations and proceedings are managed efficiently and effectively.
Complying with our legal and regulatory obligations including the prevention and detection of fraud, money laundering and other crimes.	Business Contacts General Contacts	We have a legal obligation to do so.
In connection with a potential asset or stock acquisition of Mission, or the outsourcing or insourcing of services provided by employees, providing reasonable diligence material to a third party or meeting any disclosure obligations as required by law.	Website Visitors Insurance Contacts Business Contacts General Contacts	We have a legitimate interest to manage our business.
Debugging to identify and repair errors that impair existing intended functionality.	General Contacts	We have a legitimate interest to debug to identify and repair errors that impair existing intended functionality.

Will we use Automatic Decision Making or Profiling?

We use a variety of technologies in calculating risk and insurance premiums and to compare insurance risks against industry averages and patters. This is considered profiling and/or automated decision-making and is necessary to enter into a contract with you – to confirm that the premium amount reflects and adequately matches the associated risk – and/or authorised under applicable law. As a result of these profiling activities, you may be offered a different insurance policy and/or premium, or even be refused insurance.

Profiling may also be used by brokers acting on our behalf to assess information relating to you, to identify and have a good understanding of fraud patterns. Where special categories of personal data are relevant, such as medical history or past criminal convictions for certain types of insurance, such special categories of personal data may also be used for profiling. However, in this case we ask for your prior explicit consent unless we can rely on a basis in applicable law to process this data for profiling purposes.

Will Third Parties Receive Your Data? What Are Their Interests?

We share your personal data with other entities within our Group. Employees only have access to and process data where such access and processing is necessary for such employees to performs the tasks and responsibilities allocated to them; with suitable organisational and technical measures being put in place to safeguard this.

We also share your personal data with the following categories of third parties:

Our service providers (e.g., IT vendors supporting our information security and technology, external counsel and other legal advisors, consultants, auditors, website and data hosting providers, marketing agencies, accountants, etc.);
Governmental authorities including our supervisory regulatory authorities and law enforcement agencies;
Business Contacts;
Contractors, brokers or financial institutions; and
Other third parties (i) upon your request; (ii) to protect and defend our rights and properties; (iii) to detect and/or prevent fraud or money laundering (including Claims and Underwriting Exchange (CUE) and Motor Insurance anti-fraud theft registers; (iv) in the event of a sale, merger or reorganisation of our assets or other restructuring; and/or (v) where we are, or believe in good faith that we are, under a legal obligation to share your data.

International Data Transfers?

The recipients who we share your data with may be located in countries that may have data protection laws that are different to the laws of your country, and in some cases, may not have an adequate level of data protection, which means that local laws may provide for a lower standard of protection for data than the one that applies within your jurisdiction.

We only transfer your data to these jurisdictions in compliance with applicable data protection law and transfer restrictions, and we implement appropriate safeguards where required.

If you are located in the EEA/UK and we transfer your data to other group companies located outside the EEA/UK, we rely on the EU Commission Standard Contractual Clauses (“SCCs” – link here) (amended for use in the UK as appropriate with the application of the international transfer addendum (“Addendum” – link here) to the EU SCCs) (Art. 46(2)(c) GDPR) or the UK standalone international data transfer agreement (“IDTA” – link here). Where your Personal Information is transferred to another recipient outside of the EEA/UK we will seek to enter into SCCs or international data transfer agreement with the recipient, seek assurances from the recipient that they have Binding Corporate Rules in place (Art. 46(2)(b) GDPR) or, in exceptional circumstances, rely on a derogation under applicable data protection law (Art. 49 GDPR) (e.g., where the transfer is necessary for the defence of legal claims). Further, where there is a direct transfer of data from you as an individual to us or one of these recipients outside the EEA/UK we rely on the household exemption where this is available under applicable data protection law. Furthermore, Mission relies on the recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data from the European Data Protection Board.

If you are in the EEA/UK, you may obtain more information with regards to the transfer mechanism used by contacting us using the contact details provided.

If you are in the EEA/UK and would like to receive further details on the safeguards implemented for the transfer of your Personal Information, you may contact us.

How Long Will We Keep Your Data?

Your data will be retained only for as long as is necessary for us to effectively administer your policy of insurance. This means that your data will be retained until claims under your policy are barred; or as long as is necessary to defend against legal claims; or for as long as is required by law; whichever period is the longest.

What Are Your Rights to the Data?

As a data subject, you have rights with respect to the processing of your personal data under our control as follows:

Access: You may ask us what personal data we process and request copies of such personal data. This is limited to personal data only and does not include commercial data such as underwriting data.
Rectification: You may ask us to rectify or update personal data that is inaccurate or incomplete.
Erasure: You may ask us to delete your personal data in certain instances (for example, where the data is no longer necessary for the purpose which it was originally collected or processed; or there is no longer a legitimate interest for us to process the data);
Restriction of processing: Under certain circumstance (such as when you question the accuracy of the personal data we hold on you or the lawfulness of its processing) you may request us to stop processing such data until your request is resolved.
Data portability: in certain cases, you may ask us to send an electronic copy of your personal data directly to you or to another organisation
Object: You may object to any processing of your personal data, including profiling, based on the ground of legitimate interest.
Withdraw Consent: In circumstances where processing of your data is based on consent; of your personal data is based on your consent – you may at any time withdraw your consent however this will not affect any processing we did before withdrawal (this right only applies where consent was the basis of processing your data in the first instance).

Each of the rights set out above are subject to applicable privacy legislation and is not absolute.

In order to exercise the above listed rights, or if you have any complaints about how we process your data; please contact: DPO@missionunderwriters.co.uk

In the event that we are unable to resolve your complaint: You have the right to make a complaint to the Information Commissioner’s Office if you believe that your information has been mishandled by us. The Information Commissioner’s Office can be contacted as follows:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113

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