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AED Group Fair Processing & Privacy Notice

In compliance with the UK’s General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA), this Privacy Notice (the “Notice”) tells you what to expect AED Group to do with your personal information during the provision of our claim services.

The notice relates to the following AED Group Companies:

AED Adjusting
AEDes First Surveying Services
AED Connect
Equine First
Pet First

These Companies (“we”, “our”, or “us”; also known as the “Data Controller”), are based at Faversham House, Wirral International Business Park, Old Hall Road, Bromborough, CH62 3NX.

This notice is for Data Subjects ("you") who, directly or indirectly, use our services - typically, Policyholders and Third Party Claimants- and outlines our approach to the privacy and fair processing of the personal information (“data”) we need to collect, hold and otherwise process during the provision of our claim services, details of which can be viewed via our website (www.theaedgroup.com).

What information we collect, use, and why

To provide and improve products and services for clients

We collect or use the following information to provide and improve products and services for clients:

• Names and contact details
  
• Addresses
  
• Gender
  
• Occupation
• Date of birth
• Marital status
• Third party information (such as family members or other relevant parties)
• Health information (such as medical records or health conditions)
• Criminal records data (including driving or other convictions)
• Information relating to compliments or complaints
• Audio recordings (e.g. recording and monitoring telephone calls for training, regulatory compliance, quality evaluation and verification of information provided and received)
• Records of meetings and decisions
• Website user information
• Health information

Data relating to unspent criminal convictions, including motoring offences, is processed to validate your insurance cover. Further details in respect of the processing of such information can be found in our Criminal Convictions and Offences Data Policy, a copy of which can be made available on request.

To comply with legal requirements

• Name
• Contact information
• Criminal offence data

To deal with queries, complaints or claims

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Address
• Call recordings
• Witness statements and contact details
• Photographs
• Relevant information from previous investigations
• Information relating to health and safety (including incident investigation details and reports and accident book records)
• Correspondence
• Health information

To operate our website

We collect or use the following personal information from visitors to our website:

• Data- as volunteered by you
• Other identifiable data- which does not refer to a specific individual and is used for purposes such as improving our services or customising our website according to individual interests

Our website may use “Cookies” (a small file which asks permission to be placed on your computer), and if you agree to this being added the Cookie helps us to analyse web traffic and tailor the site to your personal needs, helping us to provide a better website by enabling us to monitor which pages you find useful and which you do not.

A Cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us, and you can choose to accept or decline Cookies.

Most web browsers automatically accept Cookies, but you can usually modify your browser setting to decline Cookies if you prefer but this may prevent you from taking full advantage of our web site.

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
• Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

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

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

• Contract – we must collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.
• Legal obligation – we must collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • our legitimate interest to do so in assisting our clients with the performance of an Insurance Contract.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Contract – we must collect or use the information so we can enter into or carry out a contract with you. All your data protection rights may apply except the right to object.
• Legal obligation – we must collect or use your information so we can comply with the law. All your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • our legitimate interest to do so in assisting our clients with the performance of an Insurance Contract.

Our lawful bases for collecting or using personal information from visitors to our website are:

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • our legitimate interest to do so in assisting our clients with the performance of an Insurance Contract.

Where we get personal information from

• Directly from you
• Legal bodies or professionals (such as courts, solicitors, medical experts, insurance brokers)
• Publicly available sources
• Suppliers and service providers
• Other Third parties (depending on the nature of the service we are providing) including:
  • Our Clients- the claim documentation which they supply to assist us in the handling of claims
  • Third Party Claimants
  • Witnesses with material information about an accident or incident we are investigating
  • Other Insurance Companies and/or Counter-Fraud Registers when we are verifying insurance or claims history
  • The Police, law enforcement agencies, or recognised Governing and Regulatory bodies

Data Security

We are committed to ensuring that Your Data is secure and have put in place suitable organisational and technical measures to safeguard and secure all information we hold, including physical, electronic (aligned with the Government’s Cyber Essentials Plus Scheme) and procedural safeguards appropriate to the sensitivity of the information we process.

Data Sharing

Aligned with our Data Protection Policy and Procedures, we may share Your Data with the following parties for the purposes set out above:

• Other financial or fraud investigation authorities
• Insurance companies, brokers or other intermediaries
• Professional or legal advisors
• Regulatory authorities
• External auditors
• Organisations we’re legally obliged to share personal information with
• Suppliers and service providers
• Professional consultants
• Third parties:
  • Persons acting on your behalf who are named on your insurance policy, or who have been authorised by you to act on your behalf, e.g. family members, or Loss Assessors.
  • Data Processors- Moneypenny- who provide an out of hours call answering service and will collect a limited amount of personal information sufficient to enable us to provide an emergency response outside of normal office hours.

We will not sell, distribute or lease Your Data to Third Parties for marketing purposes.

Retention of Your Data

The UK’s General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA) are not prescriptive regarding retention periods for different categories of data; other than to say that we should not retain data for longer than necessary.

Unless contractual, industry, or regulatory standards dictate otherwise, your data will be retained in accordance with the UK Statute of Limitations, as outlined in the following Data Retention table:

When Your Data is no longer needed it will be securely destroyed and/or erased.

Contact

Any questions you may have about this notice, or requests to exercise any of your rights, should be directed to our Chief Operations Officer, who can be contacted by writing to:

• The Chief Operations Officer, AED Group, Faversham House, Wirral International Business Park, Old Hall Road, Bromborough, CH62 3NX; or
• info@theaedgroup.com

Complaints

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details above.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint