Fair Processing Notice

The privacy and security of your personal data (the 'Data') is important to us. This Fair Processing Notice (the 'FPN') explains who will have access to your Data, what information is collected, how and why it will be used, who we share your Data with, the amount of time we hold your Data for, the security we use to protect your Data and your rights as a Data Subject.

The privacy and security of your information is important to us. This notice explains who we are, the types of information we hold, how we use it, who we share it with and how long we keep it. It also informs you of certain rights you have regarding your personal information under current data protection law. The terms used in this Fair Processing Notice relate to the Information Commissioner's Office guidance.

Definitions

"You", "Your", "User" or "Users" means the policyholder, claimant, joint policyholder, or authorised representative that uses this website to submit Personal Data and information about themselves and their pet, in order to submit a claim to CLAIMSORTED LTD.

"Our", "Us" or "We" means CLAIMSORTED LTD, that operates and owns this website.

Who are We?

CLAIMSORTED is the Data Processor that has been contracted to handle and manage your RSPCA Pet Insurance Claim on behalf of COVEA INSURANCE and URIS GROUP LIMITED. CLAIMSORTED are the owner and operator of this website.

URIS GROUP LIMITED is the Data Controller of the Personal Data you provide to Us and is registered with the Information Commissioner's Office for the products and services we provide to you. You can contact URIS GROUP for general data protection queries by email to DataProtection@urisgroup.co.uk or in writing to The Data Protection Officer, First Floor Office Suite, Premier House, Carolina Court, Lakeside, Doncaster, South Yorkshire, DN4 5RA. Please advise us of as much detail as possible to help us comply with your request.

Personal Data and information We collect

As part of the Early Notification of Loss journey on the website, we will collect the following personal data:

• First Name, Surname, full postal address, occupation, mobile and/or fixed line phone number, email address, date of birth and bank account details.

Under the Data Protection Act 2018 and UK GDPR, only personal data and health information about Data Subjects (living individuals) is covered and the Data Protection legislation does not have a provision for animals.

We may also need to collect additional details of risks related to Your claim, enquiry or product and payment details (including bank account number and sort code) which We need to offer and provide the service or product or deal with a claim.

We only collect and process special category data where it is critical for the delivery of a product or service and without which the product or service cannot be provided. We will therefore not seek explicit consent to process this information as the processing is legitimised by its criticality to the service provision. If you object to use of this information, then we will be unable to offer you the product or service requested.

How and Why we use your Personal Data

We will use your personal data to meet our contractual obligations to process and assess your claim:

• to evaluate the claims under the terms and conditions of the RSPCA Pet insurance policy;
• to verify your identity when you contact us to discuss your claim;
• to contact you by email or phone during the assessment of your claim to request additional information to help us process and assess your claim;
• to pay your claim, if it is successful; and
• to collect any excess on your policy, if your claim is successful.

Use of Personal Data for Outbound phone calls

• We make outbound phone calls for a variety of reasons relating to many of our products or services (for example, to update you on the progress of a claim or to discuss renewal of your insurance contract).
• We are fully committed to the regulations set out by Ofcom and follow strict processes to ensure we comply with them. To ensure confidentiality and security of the information we hold, we may need to request personal information and ask security questions to satisfy ourselves that you are who you say you are.

Use of Anonymised Data

• We may aggregate information and statistics on website usage and collected or for developing new and existing products and services, and we may also provide this information to third parties. These statistics will not include any information that can be used to identify any individual.

Who we Share your Personal Data with

• To help us prevent financial crime, Your Personal Data may be submitted to fraud prevention agencies and other organisations where your records may be searched, including the Claims and Underwriting Exchange (CUE) and Comply Advantage, for the purpose of sanctions checks.
• To help with dealing with complaints, Your Personal Data may be shared with the Financial Conduct Authority (FCA), the Financial Ombudsman Service (FOS) and Law Enforcement bodies, such as the Police.
• To make a payment under your claim, we will share your data with Vitesse (www.vitesse.io).
• To meet contractual obligations of the joint Data Controllers of the RSPCA Pet Insurance Policy that has been underwritten by COVEA INSURANCE and administered by URIS GROUP LIMITED. The obligations include claims processing, underwriting, pricing purposes, payment processing or to maintain management information for analysis.
• This may also include conducting a search with a credit reference bureau or contacting other firms involved in financial management regarding payment.
• We may also share Your Personal Data and details of the Claim with an authorised representative who You have authorised to deal with the claim on Your behalf.

Securing your personal information

We implement industry-standard security measures to protect Personal Data. These measures include physical, procedural, and technical safeguards such as encryption, access controls, and secure data storage.

However, despite our best efforts, no security system is impenetrable, and we cannot guarantee the absolute protection of your Personal Data from unauthorised access, disclosure, alteration, or destruction.

We advise you to take precautions to protect your Personal Data, such as using strong passwords and avoiding sharing your login information.

If we provide information to a third party, we will require it and any of its agents and/or suppliers to take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Fair Processing Notice.

How long do we keep your information for?

We will not keep your personal information longer than is necessary for the legitimate purpose of which it was provided, unless we are required by law or have other legitimate reasons to keep it for longer (for example if necessary for any legal proceedings or for handling of a complaint).

We will normally keep Personal Data for no more than 7 years from the date you made a claim. In certain cases, we will keep your information for longer, particularly where a product includes liability insurances or types of insurance for which a claim could potentially be made by you or a third party at a future date, even after your contract with us has ended.

Your Individual Rights

Under the Data Protection Act 2018 (DPA), you have specific rights that you can exercise regarding Personal Data that We hold about you. You can exercise these rights at any time, free of charge, by contacting us using the details provided below.

The Right of Access

You have the right to request a copy of all Personal Data that We hold about You and to enable you to check that we are processing it lawfully. The Right of Access is also known as a Data Subject Access Request (DSAR).

The Right to Rectification

You have the right to ask us to correct Personal Data which you think is inaccurate. You have the right to ask us to add Personal Data or information which you think is incomplete.

The Right to be Forgotten

You have the right to request that your Personal Data is erased from Our information systems in certain circumstances, such as when the data is no longer necessary for the purpose it was collected.

However, in respect of Insurance, this is not an absolute right and it does not apply if you have made a claim or have an insurance policy that has been in force for longer than 14 days. We cannot erase data that we are legally required to retain with financial regulations, for fraud prevention or handle complaints.

The Right to Restrict Processing

You have the right to ask us to restrict the processing of your Personal Data in certain circumstances. For example, you can ask us to pause the use of your data while we verify its accuracy, or if you object to our use of it and we are verifying our legal grounds.

The Right to Data Portability

You have the right to ask that we transfer the Personal Data that you have provided to Us to another organisation or to you, using a structured commonly used file format, such as Comma Separated Variable. This applies where our processing is based on your Consent or the performance of a contract.

The Right To Object

You have the right to object to processing based on our legitimate interests, unless we can demonstrate compelling legitimate grounds that override your rights and freedoms.

Rights related to Automated Decision Making and Profiling

We may use automated decision making in processing your Personal Data, uploaded documents and claims information for handling claims. This includes the use of Artificial Intelligence to execute simple rule-based repetitive tasks, such as eligibility checks, uploaded document verification, fraud detection and making recommendations on simple claims.

All claims decisions are made by human claims adjusters.

You have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects on you. You have the right to request a manual review of the accuracy of an automated decision, which you are unhappy with.

The Right To Withdraw Consent

Where we rely on your explicit consent to process your personal data (for example, for marketing cookies or electronic marketing communications), you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of any processing carried out before you withdrew your consent.

How to Exercise your Rights

If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights in this section, or if you think that we have breached data protection regulation, then you have the right to complain to the Information Commissioner's Office ("ICO").

Please email our Data Protection Team at DataProtection@urisgroup.co.uk or in writing to:

URIS GROUP LIMITED, The Data Protection Officer, First Floor Office Suite, Premier House, Carolina Court, Lakeside, Doncaster, South Yorkshire, DN4 5RA.

How to Make a Complaint

We are committed to handling your personal data in a way that is fair, transparent, and in accordance with the law. If you are unhappy with how we have handled your data, this process outlines how you can make a complaint.

If you have a complaint about how your data has been handled, please contact our Complaints Department. This allows us to investigate and resolve the issue as quickly as possible.

Email: complaints@urisgroup.co.uk

Post: 1st Floor, Premier House, Carolina Court, Doncaster, DN4 5RA

Phone: 0344 854 2072

When you contact us, please provide as much detail as possible about your complaint. This will help us to understand the issue and investigate it thoroughly.

What to Expect From Us

We will acknowledge receipt of your complaint within three working days. We will then investigate your complaint and provide you with a full response within 30 calendar days.

Throughout the process, we will:

• Keep you informed of our progress.
• Request any additional information we may need from you in a timely and proportionate manner.
• Provide you with a clear and comprehensive outcome of our investigation.

If You Remain Unhappy

If you are not satisfied with the outcome of your complaint, or if you feel we have not handled it appropriately, you have the right to complain to the Information Commissioner's Office (ICO). The ICO is the UK's independent regulator for data protection and information rights.

You can contact the ICO in the following ways:

Email: icocasework@ico.org.uk

Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Phone: 0303 123 1113 or 01625 545 745

For more information about the ICO and their complaints process, you can visit their website at ico.org.uk.