RSA Law Privacy & Cookie Notice

Contents

1. Introduction

2. Who are we?

3. What information do we hold about you?

4. Where do we collect information we hold about you?

5. Why do we collect your personal information and what is the legal basis for doing so?

6. Who will we share your personal information with?

7. How long will we keep your information?

8. Will you be contacted for marketing purposes?

9. What are your rights over the personal information that is held by RSA

10. Law?

11. Cookies

12. Our Privacy Notice

13. How you can make a complaint

1. Introduction

Your privacy is important to us and we are committed to keeping it protected. We have created this Privacy Notice which will explain how we use the information we collect about you and how you can exercise your data protection rights in accordance with data protection laws.

2. Who are we?

“RSA Law” is the name and brand under which RSA Law Limited provide legal and other services to our clients. In this Privacy Notice, references to “we” “us” “our” mean RSA Law Limited, a subsidiary of Royal & Sun Alliance Insurance Limited. We also provide legal services in partnership with other companies.

3. What information do we hold about you?

The personal information we hold about you will often come directly from you when you visit our website, consult with us for the purpose of our provision of legal services to you, or as a result of communications with you or one of our clients. This information may include the following:

Your personal details (for example, your name, date of birth and gender)
Your contact details (for example, your postal address, phone number and email address)
Payment/financial details (for example, direct debit or card payments)
Information about motoring offences and criminal convictions
Information relating to your health (for example, when we are representing you in a claim for personal injury)
Details about the items which are the subject of claims in which we represent you.
Information from your digital devices, such as IP address, where the device is located (for example the UK), use of websites (usually via cookies), the type of device being used, operating system and how you interact with us

In submitting information to us, you may provide us with equivalent or substantially similar information relating to other individuals, such as (but not limited to) family members or joint policy holders. You agree that you will bring this Privacy Notice to the attention of such individuals at the earliest possible opportunity, as it details how their information will be used by us.

We may need to share your personal information with other selected companies who assist us in the provision of our legal services to you, we may also need to collect additional information about them which can include special categories of personal data (e.g. injury and health data). We may also need to share information about you with the representatives of other people involved in any claim in which we represent you to administer the claim, or to commence recovery action against them on your behalf.

4. Where do we collect information we hold about you?

Where possible, we’ll collect your personal information directly from you. However, on occasion we may collect or receive details about you from other people or companies. For example:

Joint policy holders
Insurance brokers
Where an individual has applied for an insurance product where you are an eligible beneficiary (e.g. a family member) and we provide services under that insurance product
Where it was supplied to us by your insurance company from whom you purchased an insurance product or service that is provided by us in partnership with other companies
Insurance related sources (e.g. Motor Insurance Database, Claims and Underwriting Exchange and fraud prevention databases).
Organisations which assist with claims handling, for example suppliers or medical professionals and hospitals
Publicly available sources, such as social media profiles, media stories and online registers
Third party organisations who provide information for marketing purposes

We request those third parties providing us with information to comply with data protection laws and act in a transparent manner in respect of any such disclosures.

We may record telephone calls with you for the following purposes including but not limited to:

maintain an accurate record of our conversation in respect of a dispute, or an enquiry from our regulators;
check for mistakes and to train staff;
prevent, detect, investigate and prosecute fraud and financial crime; and
for use in the exercise, establishment and defence of a legal claim.

Sometimes, calls may not be recorded if:

there’s a technical fault with the telephony system;
a call handler is using equipment which does not let calls be recorded; or
you’ve been transferred to a different line.

5. Why do we collect your personal information and what is the legal basis for doing so?

In the provision of our services to you, we need your personal information to understand your needs and to deliver legal representation and advice to you. We must have a legal basis (lawful reason) before we are allowed to use your personal information in the manner described in this Privacy Notice. In most cases, the legal basis will be one of the following:

Performance of contract: We need to use your personal information in order to provide you with the legal services pursuant to the contract between you and us and to perform our obligations under it.
Consent: In some limited circumstances, we may need your permission or consent to use personal information about you.
Necessity to establish, exercise or defend a legal claim: If you, or we, bring a legal claim (e.g. a court action) against the other, we may use your information in either establishing our position, or defending ourselves in relation to that legal claim.
Compliance with a legal obligation: Where laws or regulations require us to use your personal information in certain ways.
Legitimate Interests: We will also process your personal information where this processing is in our "legitimate interests". When relying on this condition, we are required to carry out a balancing test of our interests in using your personal information (for example, carrying out market research, protecting ourselves from being used as a vehicle for fraud, developing new products and services, etc), against the interests you have as a citizen and the rights you have under data protection legislation. The outcome of this balancing test will determine whether we can use your personal information in the ways described in this Privacy Notice. We will always act reasonably and give full and proper consideration to your interests in carrying out this balancing test.

The table below sets out what we use your personal information for and our legal basis for doing so.

What we use your information for	The legal basis for doing so
The provision of our legal services to you.	Necessary for the performance of our contractual obligations to you Legitimate Interests
The processing of payment information including the use of credit checks with credit reference agencies for fraud prevention purposes and regulatory obligations to identify our clients.	Necessary for the performance of our contractual obligations to you Legal obligation Legitimate Interests
To personalise the marketing messages delivered to you about our products, services, news and offers. We may share some information (in a secure format) with social media companies so that they can match this to information they already hold. This does not allow us access to your accounts or provide us with any confidential information relating to your accounts. It allows us to provide you with appropriate marketing advertisements via these social media channels. If you do not want us to share this information with social media companies for this purpose, you can tell us not to.	Consent Legitimate Interests
To develop and improve our products, services and pricing including market research and statistical analysis	Legitimate Interests
Share information with relevant industry bodies such as the Solicitors Regulation Authority, external companies/organisations to help prevent and detect fraud/financial crime, and where necessary verify information you have submitted (e.g. the DVLA, the Motor Insurance Database, credit reference agencies and criminal conviction checks.)	Necessary for the performance of our contractual obligations to you Legal obligation Legitimate Interests
For the purpose of debt recovery	Legitimate Interests
To comply with all necessary legal and regulatory requirements that apply to us, and co-operate with regulators and law enforcement organisations	Legal obligation Legitimate Interests
To provide training, development and security, for example the recording or live monitoring of calls.	Legitimate Interests

6. Who will we share your personal information with?

We will keep your personal information confidential at all times and only process it in accordance with this Privacy Notice. We will share your information with our employees and contractors for the purpose of providing our service to you and for exercising our legitimate interests.

We do not disclose your information outside of RSA Law except:

Where we need to check the information you gave to us with a third party organisation (e.g. credit reference agencies);
Where we are required or permitted to do so by law or relevant regulatory authority (e.g. financial crime/sanction screening, fraud detection/prevention);
In the event that we may be taken over, or sell any business or assets, in which case we will disclose your personal information to the prospective buyer of such business or assets. They will only be able to use the data for the same purposes for which it was originally provided;
As required to enforce our contract with you;
As required in order to give effect to contractual arrangements we have in place with any insurance company, insurance broker and/or intermediary through which you have arranged legal expenses which fund our provision of legal services to you, including where we provide services in partnership with other companies;
With our third-party service/assistance providers (including hosting/storage providers, research agencies, technology suppliers etc.);
With our insurers (and brokers of insurers) in connection with the normal operation of our business;
With our suppliers (including medical reporting organisations, accountants, and accident management companies, etc.) for the purpose of providing you with services pursuant to our contract; and
Social media companies (in a secure format) so they can display messages to you about our products and services, or to make sure you do not get irrelevant messages (for example, we will we not show messages about products / services you already have).
In the event that we may be taken over, or sell any business or assets, in which case we will disclose your personal information to the prospective buyer of such business or assets. They will only be able to use the data for the same purposes for which it was originally provided.

Sometimes your personal information may be sent to other parties outside of the UK and the European Economic Area (EEA) in connection with the purposes set out above. We will take all reasonable steps to ensure that your personal information is treated securely and in accordance with this Privacy Notice, and in doing so may rely on certain "transfer mechanisms" such as the standard contractual clauses approved by the European Commission and the UK Information Commissioner’s Office. If you would like further information please contact us.

7. How long will we keep your information?

We will retain your personal information for as long as we have a relationship with you. Once our relationship has ended (for example, your policy has expired, your application is declined or you do not go ahead with a quotation) we will only retain your personal data for as long as is necessary to satisfy any legal, accounting or reporting obligations, or as necessary to resolve disputes.

To assist with the determination of the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes we process your personal information for and whether we can achieve those purposes through other means.

In addition, your personal information will be retained under one or more of the following:

To maintain business records for analysis, auditing or for a limited period of time, using some of your personal information to improve the products or services we provide.
For as long as your personal information is required to allow us to conduct fraud and/or criminal checks and investigations.
To deal with any future complaints about the products and services we provide
For as long as is required by statutory authorities to meet our obligations for accounting, legal, tax and regulatory purposes.
For as long as is required to defend or take legal action.

In general, we will retain your personal information for a period of 7 years from the date of the termination of our business relationship.

8. Will you be contacted for marketing purposes?

We will only contact you for marketing purposes if you have previously agreed. This could be via any channel we hold contact information for you. Where that’s the case:

We will let you know about offers and services we think you’ll like and any special offers available to you as an existing customer. Where appropriate these messages may be personalised using information you have previously provided us.
We will only contact you for marketing purposes if we collected your information directly or when authorised and instructed by a third-party acting on your behalf.
We may use the information which we collect about you to show you relevant advertising on third-party websites (e.g. Facebook or Google). This could involve showing you an advertising message where through the use of cookies, we know you have browsed our products and services. If you don’t want to be shown targeted online advertising messages from us, you can change the advertising setting on some third-party sites and some browsers to block our adverts.
In some circumstances we may share some of your information (in a secure format) with social media companies so that they can match this to information they already hold to display messages to you about our products and services.

You can ask us at any point to stop sending you marketing, and request that your personal information is not processed for the purposes of marketing.

9. What are your rights over the information that is held by us?

We understand that your personal information is important to you, therefore, in accordance with your rights under data protection laws, you may request that we:

Provide a copy of the personal information we hold about you. This is known as the right of subject access and is an entitlement to a copy of the information only, you are not entitled to documents.
Delete your personal information. This is known as the right of erasure. Please note, we may not be able to comply with this request in full where, for example, you are still an RSA Law customer and the information is required to fulfil the conditions of our contract with you.
Give you (or a third party) an electronic copy of the personal information you have given us. This is known as the right of data portability. We would provide the information in a commonly used electronic format.
Restrict how we use your personal information under the following circumstances:
a. If you believe that the information we hold about you is inaccurate, or;

b. If you believe that our processing activities are unlawful but you do not want your information to be deleted.

c. Where we no longer need to use your information for the purposes set out in this Privacy Notice, but it is required for the establishment, exercise or defence of a legal claim.

d. Where you have made an objection to us (in accordance with point 5 below), pending the outcome of any assessment we make regarding your objection.
Enable you to object to the ways in which we are using your personal information, under the following circumstances
a. Where we believe it is in the public interest to use your information in a particular way, but you disagree.

b. Where we have told you we are using your data for our legitimate business interests and you believe we shouldn’t be (e.g. you were in the background of a promotional video but you did not agree to be in it).

For points a and b above, we will stop using your information unless we can reasonably demonstrate legitimate grounds for continuing to use it in the manner you are objecting to.

Correct any personal information we hold. Please contact us if any information is incorrect, or any of your personal information has changed.

For certain limited uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. Please note in some cases we may not be able to provide services to you if you withdraw your consent.

If you would like to request any of the above, please contact us via our email address crt.halifax@uk.rsagroup.com or write to us at:
The Data Protection Officer
RSA Law
Bowling Mill
Dean Clough Industrial Park
Halifax
HX3 5WA

To ensure that we do not disclose your personal information to someone who is not entitled to it, when you are making the request we may ask you to provide us with:

Your name;
Address(es);
Date of birth;
Any policy IDs, claim numbers, or reference numbers that you have along with;
A copy of your photo identification, such as your photocard driving licence or passport; and
A copy of a utility bill showing your name and address dated within 3 months of your request.

If you appoint a third party to act on your behalf, for example, a friend or a solicitor, we will ask them to provide your signed authority for them to act on your behalf AND the identity information and documents listed above.

All rights requests are free of charge, although in exceptional circumstances for certain rights, such as access, we reserve the right to charge a reasonable administrative fee.

Wherever possible, we will respond within one month from receipt of the request, but if we don’t, we will notify you of anticipated timelines ahead of the one month deadline together with brief explanation as to why we are unable to respond within the initial one month deadline.Please note that simply submitting a request doesn’t necessarily mean we will be able to fulfil it in full on every occasion – we are sometimes bound by law which can prevent us fulfilling some requests in their entirety, but when this is the case we will explain this to you in our response.

10. Cookies

Our website uses cookies and similar technologies (hereafter referred to as ‘cookies’), which are usually small text files. The cookies used on this website are deemed to be strictly necessary within the meaning of relevant privacy legislation.

Strictly Necessary cookies are fundamental to the running of this website and cannot be switched off on our site, they ensure that the website works correctly and in a secure manner. Without these cookies, services you’ve asked for cannot be provided. Other essential cookies are considered strictly necessary on the basis that they enable the transmission of communications over a network. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

As we only use strictly necessary and communications cookies on this website, we are not required to gain your consent to place these on your device.

11. Our Privacy Notice

If you have any queries regarding our Privacy Notice, please contact us at the address below and we will be happy to discuss any query with you. Our Privacy Notice will be updated from time to time, so please check it each time you submit personal information to us.

The Data Protection Officer
RSA Law
Bowling Mill
Dean Clough Industrial Park
Halifax
HX3 5WA

You may also email us at crt.halifax@uk.rsagroup.com.

12. How you can make a complaint

If you wish to raise a complaint on how we have handled your personal information, please send an email to our Customer Relations Team using their email address crt.halifax@uk.rsagroup.com or

write to us using the address below
RSA Law
Customer Relations Team
PO BOX 255
Wymondham
NR18 8DP

If you are dissatisfied with our response to your complaint, you have the right to refer your complaint to the Information Commissioner’s Office. You can do this by accessing their website https://ico.org.uk/ or by calling their helpline on 0303 123 1113, or writing to them at the address below. You also have the right to seek a judicial remedy.

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

You also have the right to contact the Financial Ombudsman Service, free of charge, but you must do so within six months of the date of our decision letter. If you do not refer your complaint in time, the Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances. For example, if the Ombudsman believes that the delay was as a result of exceptional circumstances.

Version Control

Version	Date	By	Amendment
1.0	October 2020	Emma Crisp & Kurt Rowe	Redrafted for 2020
1.1	December 2020	Emma Crisp & Kurt Rowe	Included wording relating to the introduction of Luxembourg as our Representative within the EU within section 2.
1.2	June 2021	Emma Crisp	Amends due to RSA becoming a subsidiary of Intact