Wesleyan Group privacy notice

Who we are

The Wesleyan Group of Companies (known as "Wesleyan", "we", "our", "us") is committed to protecting the privacy and security of your personal information. You may have a relationship with one or more of our companies, including Wesleyan Assurance Society, Wesleyan Financial Services Ltd and Wesleyan Unit Trust Managers Ltd. Find out more about our  Group of Companies.

This privacy notice explains how and why Wesleyan use your personal data. Where we use terms such as "we", "us" and "our" in this policy, we mean Wesleyan.

Our privacy notice

This notice applies to prospective customers, current customers and former customers to the Wesleyan Group of Companies and describes how we collect and use personal information about you in accordance with the General Data Protection Regulations ("GDPR") and other data protection laws. 

Customers of Practice Plan, DPAS and Quality Plan will receive a separate privacy notice specific to the products and services they each provide.

We’re committed to protecting the privacy and security of your personal information. We ask that you read this privacy notice carefully as it contains important information regarding your personal information.

You should also read any other privacy notices that we give you, that might apply to our use of your personal data in specific circumstances from time to time.

For the purposes of data protection law, including the Data Protection Acts 1998 and 2018 and the General Data Protection Regulation (together, DP Law) Wesleyan is a "controller". This is a legal term which means that we are responsible for deciding how we hold and use personal information about you. 

This privacy notice explains what we do with any personal information which we collect from you, including when you use our website and when you interact with us in other ways offline, for example when you take out a policy with us.

Please note that you do not have to transfer your information to us; however, if you do not, it will severely limit your ability to use our products and services.

At the foot of this notice, we’ve included contact details for our Data Protection Officer, which you can use if you wish to ask us for further information or to exercise your rights.

We reserve the right to change the policy at any time, so please check back regularly to keep informed of updates to this notice.

What type of personal data do we collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Depending on the services and products we provide to you, we may collect, store, and use the following categories of personal information about you:

Who you are

• Where you live and how to contact you
• Your name
• Your date of birth and/or age
• Your home address and correspondence address (where this is different) and address history
• Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, driving licence or birth certificate, if this is necessary for us to comply with our legal and regulatory requirements
• Your marital status, family, lifestyle or social circumstances if relevant to the application (for example the number of dependents you have)
• What we learn about you from letters, emails and conversations between us;
• Details of the devices and technology you use
• Usage data about how you use our products and services
• Personal data which we obtain from Fraud Prevention Agencies (see the section on Fraud Prevention Agencies below)
• Your marketing preferences
• Where you "like" us or make posts on our pages on social networking websites, such as Facebook, YouTube and Instagram
• If you take a survey or interact with us in various other ways - demographics information and information about subjects that may interest you.

Financial Information

• Your financial position, status and history
• Your salary and other sources of income
• Any savings
• Bank account details, payroll records, tax status information and credit scores
• Details of any personal or corporate insolvency proceedings involving you
• Information about your employment records (including salary, pension and benefits information, job titles, work history, working hours, training records and professional memberships, location of employment or workplace)
• Information about your registration with professional bodies and Companies House, and any sanctions made against you
• Personal information about your credit history which we obtain from Credit reference agencies including data which originates from Royal Mail (UK postal addresses), local authorities (electoral roll), the insolvency service, Companies' House, other lenders and providers of credit (who supply data to the Credit Reference Agencies), court judgments decrees and administration orders made publicly available through statutory public registers (see the section on Credit Reference Agencies below).

Special Categories of Personal Data

We may also collect, store and use the following "special categories" of more sensitive personal information:

• Information about your race, ethnicity or sexual orientation (where any of these could be established from information you provide to us)
• Information about your physical and mental health, including any medical condition, health and sickness records (where this is relevant to products we offer, such as health insurance as well as processing any subsequent claims)
• Information about criminal convictions and offences (as part of our fraud prevention checks and where this is relevant to policies such as car insurance).

How is your personal data collected?

Directly from you

We may collect your personal data directly from you by the following means:

• Enquiry, quotes, claim and application forms you submit or emails or correspondence you may send to us
• When you consider purchasing or actually purchase a product or service from us
• Telephone calls with you (which may be recorded)
• Via cookies when you access our websites, applications, social media (such as Facebook pixels) or emails (see our cookie policy for further information)
• When you create a My Wesleyan account
• When you carry out transactions through our website or any related websites
• Information we have gathered from asking you to respond to surveys or if you take part in our competitions or promotions.

If you pass us any information about another person, you confirm you have their authority to share that information with us.

From third parties

We may also collect your information from third parties such as:

• Companies that introduce you to us
• Where you’ve agreed for your information to be passed onto us (e.g. by a family member when you may not be able to disclose the relevant information directly or by a third-party referrer who is introducing business to us)
• Brokers
• Social networks
• Fraud, money-laundering and sanctions prevention agencies
• Public information sources such as Companies House, court decisions, bankruptcy registers and the electoral register
• Agents working on our behalf, including tracing agents
• Your and our solicitors
• Credit Reference Agencies ("CRAs") or other background check agencies (see further details below)
• Medical professionals (where you have agreed to this)
• Government and law enforcement agencies
• Debt counselling and debt management agencies and charities.

How we use your personal data

We collect and process your data for several purposes. For each purpose, Wesleyan must explain to you the legal ground which justifies our processing your personal data. The following are the legal grounds that are relevant to us. Some of these grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

Processing is necessary to perform our contract with you for a product or service or for taking steps prior to entering into a contract during the application stage:

• To identify you and, if applicable, the Companies you own or of which you are a director
• Evaluating your application and providing you with a quote (this maybe provided directly by us or a third party)
• To carry out credit checks (see further details below)
• Administering and servicing the contract we have entered into with you (or propose to enter into with you) and managing the product or facility, which may include any mutual benefits that you may be entitled to
• Administering and managing your account and associated services, updating your records, tracing your whereabouts to contact you about your account and doing this for the recovery of debt
• Claims management in relation to policies you hold with us or via a third party which are managed by us
• Sharing your personal data with certain third-party service suppliers such as payment service providers
• All stages and activities relevant to managing your account including enquiry, application, administration and management of accounts, illustrations, requests for transfers of equity, setting up/changing/removing guarantors; closing of accounts
• To manage how we work with other companies that provide services to us and our customers
• To manage fees, charges and interest due on customer accounts
• To exercise our rights set out in agreements and contracts
• To provide banner advertisements for products and services via your My Wesleyan account.

Processing necessary to comply with our legal obligations

• To verify your identity in order to comply with anti-money laundering regulations and to carry our checks with Fraud Prevention Agencies pre-application, at the application stage and periodically after that
• To comply with laws that apply to us
• To establish, defend and enforce our legal rights or those of any other member of the Wesleyan Group
• For activities relating to the prevention, detection and investigation of crime
• To carry out monitoring and to keep records
• To deal with requests from you to exercise your rights under data protection laws
• To process information about a crime or offence and proceedings related to that (in practice this will be relevant if we know or suspect fraud).
• To pursue our legitimate interests, provided your interests and fundamental rights do not override those interests
• Anti-fraud and money laundering purposes
• Providing you with information about products and services based upon any preferences you may have expressed and/or which we think might be of interest (marketing purposes)
• Recovering debt (this may include carrying out credit checks - see further details below)
• Claims management (in relation to policies you hold with us or via a third party which are managed by us)
• Complaints management (if you are not happy with the service we have provided you)
• Business management and planning, including quality, testing, training, accounting, auditing purposes and market research
• Running events and/or competitions
• To produce and consider management information internally.

Where we have your consent

• Providing you with information about our products and services based upon any preferences you may have expressed and/or which we think might be of interest (marketing purposes). Please note that you have the right to withdraw consent - please see ‘Your Rights and Duties’ section below.

Change of our use

• We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so
• Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

What happens if you fail to provide data?

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into (or are proposing to enter into) with you or we may be prevented from complying with our legal obligations (such as detecting or investigating fraud) and so we may be required to decline an application or claim.

How we use particularly sensitive personal data

Special categories of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

• With your explicit consent
• Where it is in the substantial public interest and in line with our data protection policy
• Less commonly, we may process this type of information where it’s needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you’re not capable of giving your consent, or where you have already made the information public.

We may approach you for your approval to allow us to process certain particularly sensitive data. If we do so, we’ll provide you with full details of the information that we’d like and the reason we need it. Without this approval, in some circumstances, you may not be able to benefit from some of our services.

Information about criminal convictions

• We’ll only collect this type of information if it’s necessary given the nature of the service we’re providing you with or the nature of the product you wish to purchase from us. And where we’re legally able to do so, for example, to assess and provide you with a quote for various insurance products and as part of our fraud prevention checks
• Less commonly, we may use information relating to criminal convictions where it’s necessary in relation to legal claims, where it’s necessary to protect your interests (or someone else's interests) and you’re not capable of giving your consent, or where you’ve already made the information public.

Automated decision making, fraud prevention and credit referencing

What is automated decision making?

Automated decision making takes place when an electronic system uses personal information to make a decision without human intervention. We’re allowed to use automated decision-making in the following circumstances:

• Where it’s necessary for entering into or to perform the contract with you and appropriate measures are in place to safeguard your rights
• In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights and freedoms and legitimate interests
• If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest and we must also put in place appropriate measures to safeguard your rights, freedoms and legitimate interests.

As part of the processing of your personal data, decisions may be made by automated means, by putting your information into a system and calculated using automatic processes. 

We may make automated decisions about you in the following situations:

• Where you pose a fraud or money laundering risk e.g. if: our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers or is inconsistent with your previous submissions; or
• You appear to have deliberately hidden your true identity and/or you have provided false or inaccurate information
• When deciding your premium for insurance products and assessing applications - for example depending on the type of insurance product you apply for our processing of your personal and/or sensitive information may be used to assess the price and determine whether there are any exclusions that need to be applied to the policy.

The results of these checks may affect the type of products and services we can offer you.

Your rights

You have rights in relation to automated decision-making. If you want to know more, you can contact our Data Protection Officer (details at the end of this privacy notice).  If we can’t carry out the checks outlined above, it may not be possible for us to offer certain services or products to you.

Fraud prevention agencies

When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering. We also do this to verify your identity to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you’ve requested.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the products, services and/or financing you’ve requested, or we may stop providing existing services to you.

We, and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details below.

Fraud prevention agencies can hold your personal data for different periods of time, and if you’re considered to pose a fraud or money laundering risk, your data can be held for up to ten years and may result in others refusing to provide products, services, financing or employment to you.

Where we share personal data about you with TransUnion, it will process that personal data in compliance with its Fair Processing notice, a copy of which can be found on the TransUnion website. 

Credit scoring and credit reference agencies

Where we use credit scoring, this means existing and historic data about you may be used to determine your creditworthiness and your ability to make future payments. This allows us to make responsible lending decisions.

The identities of the Credit Reference Agencies, and the ways in which they use and share personal information, are explained in more detail on the Experian website. 

A credit reference check will add to your record details of our searches and your application. This record (but not our name) will be seen by other organisations when you apply for credit in the future. A large number of applications within a short period of time could affect your ability to obtain credit.

We will carry out 'credit searches' on individuals in the following circumstances:

• Where you apply for credit in your own name (including as 'sole traders' and as 'partners' in partnerships)
• Where you personally guarantee the credit agreements of companies
• If you default on your credit agreements
• When you ask for a quote, at renewal and sometimes if you change your cover in order to offer a monthly credit payment option. This may include a quotation search from a credit reference agency (CRA). This will appear on your credit report and will be visible to other credit providers. It will be clear it's a quotation and not a credit application by you.
  

Who do we share your personal data with?

We will share your data with third parties, including third-party service providers and other entities in the Wesleyan Group of Companies. We require third parties to respect the security of your data and to treat it in accordance with the law. If you are a joint applicant or you have a joint product or policy, we may disclose your information where necessary to other joint applicants.

We may transfer or disclose your personal data to the following categories of recipients:

• Other members of the Wesleyan Group of Companies as part of our regular reporting activities on company performance, in the context of a business re-organisation, possible sale or group restructuring exercise, for system maintenance support and hosting of data or to help us identify products and services which may be of interest to you
• Third-party service providers (including IT suppliers, auditors, marketing agencies, market researchers, document management providers and underwriting services)
• Other third parties who are associated with the supply of products and services in relation to the contract we hold with you, e.g. third-party providers/lenders who form part of our panel(s). If you would like further information on these third parties, please contact our Data Protection Officer (see contact details below).
• Our regulators (Financial Conduct Authority (FCA), Prudential Regulatory Authority (PRA), Information Commissioners Office (ICO)) and the Financial Ombudsman Service (FOS)
• Government agencies or law enforcement
• Fraud prevention agencies and credit reference agencies
• Motor Insurance Information Centre
• Third parties as part of any possible sale or restructuring of our Group of Companies.

Car insurance policy

If you hold a car insurance policy your details will be added to the Motor Insurance Database (MID), run by the Motor Insurers Information Centre (MIIC). MID data may be used by the DVLA and DVLNI for the purpose of Electronic Vehicle Licensing and by the Police for the purposes of establishing whether a driver's use of the vehicle is likely to be covered by a car insurance policy and/or for preventing and detecting crime.

If you’re involved in an accident (in the UK or abroad) other UK insurers, the Motor Insurer's Bureau and MIIC may search the MID to ascertain relevant policy information. Persons with a valid claim in respect of a road traffic accident (including citizens of other countries) may also obtain relevant information which is held on the MID.

You can find out more about this from your insurer or by visiting the MIB website.

You should show this statement regarding MIIC to anyone insured to drive the vehicle covered under the policy. A credit reference check will add to your record details of our searches and your application. This record (but not our name) will be seen by other organisations when you apply for credit in the future. A large number of applications within a short period of time could affect your ability to obtain credit.

Why do we need to share your personal information with third parties?

We may share your personal information with third parties where required by law, where it is necessary to administer the contracts we, or a third party may, have with you, where we have another legitimate interest in doing so or where you have asked us to pass your data to a third party e.g. lawyers, other mortgage providers etc. We also share personal data for crime and fraud prevention, credit reference and the apprehension and prosecution of offenders.

Where do we process and store your information or transfer it?

We generally process your information through servers in the UK and EEA. Occasionally there may be circumstances where we are required to transfer your personal information to countries outside the European Economic Area (EEA). 
To ensure that your personal information does receive an adequate level of protection we have put in place model clauses to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

If you require further information about this protective measure you can request it from our Data Protection Officer.

What data security measures do we apply?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we’re legally required to do so. 

To read about how we protect your information, please  visit our security page.

How long do we keep your data?

We’ll only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We typically keep records for up to 10 years from the end of our relationship with you. In some circumstances we may be required to retain for longer periods such as, if there is legal action, a dispute or a requirement of a particular product.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your rights and duties

Your duty to inform us of changes

The personal information we hold about you must be accurate and current. Please keep us informed if your personal information changes during your relationship with us. You can do this by using our contact us facilities. 

If you wish to update your marketing preferences at any time, you can do so by contacting us at marketingpreferences@wesleyan.co.uk or by completing the  marketing preferences opt out form.

Your rights in connection with your personal information

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 allows you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
• Request erasure of your personal information. This lets you ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below)
• Object to processing of your personal information where we 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 we are processing your personal information for direct marketing purposes
• Request the restriction of processing of your personal information. This lets you ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for us processing it
• Request the transfer of your personal information to another party
• Right to Withdraw Consent - In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer. Once we’ve received notification that you’ve withdrawn your consent, we’ll no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

How to exercise your rights

• If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our data protection officer using the details below.
• No fee usually required - You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances
• What we may need from you - We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Data Protection Officer

We’ve appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact our DPO. While we hope you can discuss issues with the DPO, you also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice

We keep this notice under regular review. We may change this notice from time to time by updating this page in order to reflect change in the law and/or our privacy practices. The date at the top of this notice will be updated accordingly and we encourage you to check this from time to time for any updates or changes. 

We may email you to let you know about any changes to this notice or the processing of your information.
 
If you have any questions about this privacy notice, please contact the Data Protection Officer on 0121 200 3003 or by email at privacy@wesleyan.co.uk.