Privacy Notice

Privacy Notice

Thank you for choosing 1st Central. This website notice provides a summary of how we will use your personal data when you interact with us, regardless of which products you purchase or whether you interact with us online, through mobile applications, or by other means. It covers our main processing activities. If you would like to view our full notices, which provide a detailed overview of our processing for our products, you can download them here:

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  Motor insurance privacy notice 
  
  
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  Home insurance privacy notice 
  
  

How does 1st Central using my information actually impact me?

When we process your information it can have an impact on you, for example:

• When we view your credit score it will leave a footprint on your credit report, which may be visible by you and others
• We will record defaulted payments on your credit report which can be seen by other financial companies who view your record
• We provide information to industry databases which can be seen by other insurance companies
• We pass information onto third parties who provide us, and you, with insurance services. Information will only be sent to third parties who should have it and you will be informed which third parties are involved
• We will collect locational data about you through our website and mobile applications which can be used to profile you
• We will make wholly automated decisions with profiling to determine insurance risk, premium finance and fraud.

We will always try to limit any impact on you, but we consider our processing necessary to be able to provide our products and services. If you’d like to discuss this or have any questions you can contact our Data Protection Officer at any time. 

Who are you giving your information to?

You're providing your information to:

• First Central Underwriting Limited: underwrites your 1st Central insurance policy
• First Central Insurance Management: handles the day-to-day administration of your 1st Central insurance policy, as well as any claims you may make, and acts on behalf of other insurers providing you with ancillary products such as breakdown and legal expenses cover. Those insurers have their own privacy notices and we’d recommend you review these in addition to this notice.

What information do we collect?

We collect the following information:

Personal information
Your name, address, date of birth, telephone number, email, vehicle details, home details, previous claims history, demographic information, user or device IDs and IP address.

Sensitive personal information
Information related to health e.g. personal injury from previous claims or medical conditions that affect your license and any motoring convictions.

Payment information
When you purchase a policy with us we'll collect your card and/ or bank details.  

Behavioural and locational information
We will collect behavioural and locational information when you use our website and mobile applications.  This information can include device usage, precise GPS co-ordinates and other locational information, diagnostics information, driving and lifestyle behaviours such as speeding, acceleration, braking and cornering along with other contextual information.  

Information you give to us on behalf of others
The information you provide us about other people e.g. named drivers or relatives on your insurance.

When needed we collect information from other sources e.g. when you have a claim we'll speak to the DVLA to confirm your license information. We'll also obtain information from industry and fraud databases, publicly accessible sources such as social media or the government as well as other insurance companies.

How will we use your information?

We'll use the information you provide us to:

Give you a quote for insurance
Whether you come directly to us or through an aggregator we'll process your information, evaluate the risk to be covered and match the premium in order to provide you with an accurate quote.
We use the information you provide to make automated decisions about you (this means without any human intervention). This applies to measuring your suitability for our finance product and for us to offer you a quote.

Policy administration and renewal
This includes:

• Setting up your policy
• Providing customer care
• Providing premium and payment options, including completing affordability checks
• Setting up credit agreements to collect and receive payments
• Handling any complaints

Claims handling
We'll process your information to manage any insurance or reinsurance claims that may arise and to defend any legal claims that are made against you. This can include using locational data to provide supporting services.

Marketing
At the point of purchase, we collect your marketing preferences so you can choose what information you’d like to receive from us. If you’d like to change your preferences, you can do so at any time in your Your Account or by emailing marketing@1stcentral.co.uk.  

Products
Your information will be used to ensure that the products we’re providing are suitable and provide the right level of service. This includes obtaining your feedback and monitoring the quality of the services our teams provide. We want to continuously improve what we do, so we use this information to better understand the needs you have through research and statistical analysis to target our products accordingly.

Fraud prevention and detection
We are committed to preventing and detecting fraud for the benefit of you, us and the insurance market. We process information you provide, or we receive from fraud databases, our partners, our applications, and systems and will share information with law enforcement where necessary.

Decision making
When deciding whether to offer insurance, renewals or premium finance products we make decisions through automated means without human intervention – this includes profiling you. This is done based on the product you are purchasing.  Take a look at our 'What affects your price' page to learn more.

Online behaviour
We monitor how people interact with our website and any applications so we can make improvements to its functionality and improve and personalise experience. 

Other purposes
Your information will be used to help us meet our legal and regulatory obligations, as well as to help us model our business and analyse the insurance market.
We don’t undertake any activities that you wouldn’t reasonably expect, but if you want to know more about this and the rights you have, see the ‘Your rights’ section. 

How will we share your information?

In order to provide you with our services, we need to share your information with other people. Our promise to you is that we won’t sell your information to anyone, and everyone we pass your information on to will protect it to the same level we do.
We share information with:

Other companies in our group
Information will be shared amongst the First Central Group of companies’ in order to provide your insurance and services described. You can find out more about our parent company on the First Central Group website.

Credit reference agencies
When we assess the payment options most appropriate for you and to validate your identity, we conduct a search through a credit reference agency. A record of the check will be held by the credit reference agency who place a footprint of ‘insurance search’ on your credit file. This footprint will not alter your credit score. We'll continue to exchange information to check your credit status and suitability for other products we may offer, when you make changes to your existing policy and at renewal.
 

Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records may also be taken into account during credit checks. Please see the CRAIN notices of Experian and Transunion for more information about their processing.
 
If you're paying by Direct Debit, we may give details of your accounts and how you manage them to credit reference agencies, including records of outstanding debt. This information may be supplied to other organisations to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for 6 years after they're closed, whether settled by you or defaulted. For more information on how credit reference agencies handle your information click here.

Fraud prevention agencies
If fraud is identified or suspected, details may be passed to fraud prevention agencies who will use this information to prevent fraud and money laundering and to verify your identity. If fraud is detected you could be refused certain services, finance or employment. Law enforcement agencies can also access this information. We are members of the national fraud database, CIFAS and other industry recognised databases. 

Industry databases
All insurers have to pass information on to the Claims and Underwriting Exchange Register run and the Motor Insurance Anti-Fraud and Theft Register. When we deal with your request for insurance in the event of any incident or claim, or at time of renewal, we'll search these databases to help us check the information provided and to prevent fraudulent claims.
 
Information relating to your insurance will also be added to the Motor Insurance Database (MID) managed by the Motor Insurers’ Bureau (MIB). MID and the data stored on it may be used by certain statutory and/or authorised bodies including the Police, the DVLA, the DVLNI and the Insurance Fraud Bureau.

Our legal panel
We have a panel of solicitors who are instructed to handle your personal injury, credit hire or vehicle claims. We'll let you know who we’ve provided your information to.

Our claims repair and recovery network
In the unfortunate event that you’re involved in an accident or need to claim for your property we'll pass on your details to members of our claims network, who will investigate the circumstances, and support you to get back on track.

Other outsourced organisations
We sometimes ask that other organisations carry out activities on our behalf including claims handling, marketing and advertising, debt recovery, research, and development providers. 

Investors or purchasers of the business
If we're sold to another person or organisation or transfer our responsibilities to another or where investors require information. If this happens you will receive written notice. 

Our product partners
This will include trusted partners who provide our ancillary products such as hire cars, credit hire, legal expenses, excess protect, personal accident and breakdown products. The policy wordings for each of these products tell you about there processing and how to contact them. 

Reinsurance panel
Where necessary we'll pass limited amounts of personal information to our reinsurance panel for the purposes of insurance and claims administration. You will never receive communications from our reinsurance panel.

Debt recovery  
If your policy is in default we use debt recovery agents to help us recover any outstanding balances. This can include tracing you and helping us to pursue legal recovery. 

Mobile applications
We will use mobile application stores to enable our customers to access and download mobile applications we launch for our products. We partner with developers and suppliers of mobile applications towards this aim. When you download a mobile application, it will collect and share data with these providers. The data we collect on mobile applications is important to making functionality work. 

Research, Insight, and Improvement
We process personal data for our own interests with the aim of improving our products and your experience. We recognise that this processing is not visible to you. We never use the personal data to directly impact you, where we can we minimise the data, or use aggregated, anonymised or otherwise protected information to achieve these aims. 

How will we communicate with you?

We’re an online company and will use your email address to send you important information about your quote, policy, renewal and claims. We also send SMS updates and will call you if we need to speak to you urgently.
 


If you need to call us we ask you to identify yourself. Please be aware that we do record some of our calls for training, insight and monitoring purposes. You can also contact us online using webchat, whatsapp and social media.  
 


If we contact you and can’t get through, we'll leave a voicemail. We have guidelines for what can and can’t be left in a voicemail, but if you’d prefer us not to leave a message just let us know.  

Security
Our customers are at the heart of the services we provide therefore the security of your information is very important to us. We’ve put in place organisational and technical measures to protect your information from unauthorised access, use and loss. We have policies to safeguard your privacy and will continually monitor our measures and update our approach as new technology becomes available.
 


Site security

We ask all customers to provide a password to help us protect your information. This password is used to access your policy information and documents online. If you’ve forgotten your password or email address, you can retrieve them on the Account Recovery page.
 


To protect your information, we use the industry standard Secure Sockets Layer (SSL) 128-bit encryption technology to ensure that all your personal and transactional information is encrypted before transmission.
 


Depending on your browser you should see a closed lock or unbroken key in the bottom left-hand corner or in the URL bar to signify that SSL is active and you’re in a secure area of our site.
 


Security of third party sites

We can’t be responsible for the privacy policies and practices of other websites, even if you access them using links from our website, so we recommend that you check the privacy policy of each site you visit.
 


Internet communications

It’s worth remembering that communications over the internet, such as emails aren’t secure unless they’ve been encrypted. This is the nature of the internet, so it's best not to send anything you consider confidential without additional projections. We can’t accept responsibility for any unauthorised access or loss of personal information that’s beyond our control.
 


Storing your data

The information we hold about you is encrypted and stored securely in private dedicated server environments. Some of the information we store about your behaviour on our site is collected via analytics packages and is stored on secure servers outside of the EU.
 


If your information does need to be transferred or stored outside of the EU we ensure that it’s done so securely and in compliance with all applicable laws.
 


We follow industry practices and standards when handling financial information and don’t directly store your card payment information. We‘ve introduced masking of your payment information on the telephone and our colleagues will only ever confirm the last four digits of any card number.

How long will we keep your information?

We retain your information for as long as it’s needed for us to meet our legal and regulatory obligations. For most customers this will be seven years, at which point we'll take steps to erase or anonymise the information. If you have a claim during your time as a customer of 1st Central, that time period will be longer to ensure that we can defend any future insurance claims. This will be relevant where an accident has happened abroad or involves children. Anonymised, aggregated or pseudonymised data can be retained for 25 years for statistical purposes. 

Your rights

In line with the Data Protection Act you have certain rights:

The right of information
You have the right to be provided a notice about how we use your information. This is the shortened version of our full notice. You can download the full notice at the top of the page.

The right of access to your information
Log in to Your Account, a lot of the information we hold is stored in here. You can also request to see the information we hold about you. Please put in writing your name, address and policy number and tell us what information you’d like. We have 30 days to respond to your request.

The right to have information corrected
If you see that any of the information, we hold about you is incorrect you can ask us to update it. We have 30 days to respond to your request.

The right to object or restrict certain processing
You can request that we stop marketing to you at any time on your customer portal. For everything else you can write to the Data Protection Officer. We'll respond to requests within 48 hours.

The right of data portability
You can obtain a reusable copy of the information you provided us within your customer portal This can then be used for your own purposes. We aim to provide the portable data within five days of your request, but we do have 30 days. 
You can make any of the above requests to our Data Protection Officer by emailing  DPO@1stcentral.co.uk. Alternatively, you can write to: Data Protection Officer, First Central Insurance Management, Capital House, 1-5 Perrymount Road, Haywards Heath, West Sussex, RH16 3SY. Please include your name, address and policy number, along with the details of your request.

Unhappy with what we’re doing?

If you’re unhappy with the way we’ve processed your information you can raise a complaint in the same way as you do on your policy. We'll follow our complaints procedure and review your concerns.  If you remain unhappy following our response you can escalate your complaint to the Information Commissioners Office at https://ico.org.uk.

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