What information do we collect?
The personal information we collect about you will vary depending on the financial product and/or service we provide to you. We collect personal information about you which may include:
- name, date of birth, gender, marital status, contact details (including address), and National Insurance details;
- proof of identity;
- details of your spouse or partner, a joint applicant, next of kin, dependants, designated beneficiaries or trustees;
- financial information (including income, expenditure, credit and bank details);
- details of your professional advisers (including financial adviser(s), solicitors and estate agents);
- employment details, including length of service, salary and tax details, place(s) and type of work undertaken;
- details of your physical and mental health (and, where relevant, the health of your family) and medical history;
- details of your GP or other relevant medical consultants;
- details of the circumstances which give rise to a potential claim (which will include information we collect from third parties to verify such details); and
- any information you choose to give us from time to time.
We may collect the personal information listed above from third parties, for example:
- where the third party (e.g. your employer, a financial institution, your financial adviser or your landlord) holds that information;
- to verify the information you have provided;
- for credit reference checking, identity checking, fraud and crime prevention services;
- if you make a complaint, details of that complaint and relevant information from the regulator you have complained to; and
information we need to meet our legal and regulatory obligations.
This notice also applies to any personal information you give us about anyone else. If you disclose personal information about someone else, you must ensure you have their permission to do so and that they understand the information set out in this notice.
What do we use your information for?
We use your personal information:
- to respond to your enquiries about financial products and/or services;
- to assess and process your application(s) for financial products;
- to provide you with information about products and/or services (unless you tell us not to, see below for more details) and for advertising, public relations and business development in connection with our customers;
- to manage and administer your financial products and/or services, claims and our wider relationship with you;
- for credit reference checks, arrears and debt collection;
- for research (including market research), anonymisation and analysis (including statistical analysis and customer profiling);
- as otherwise legally required or lawfully permitted under the Data Protection Act 1998, including meeting our regulatory, legal and good governance obligations;
- for the prevention or detection of crime (including fraud); and
- as otherwise notified to you by us from time to time.
Who may we share your information with?
We may share your information with:
- our administrators, service providers and reinsurers for the day to day provision of our financial products and/or services;
- service providers, other insurers, guarantors, government and industry bodies; for example HMRC, Land registry, ABI, regulatory authorities, fraud and crime prevention organisations, credit reference agencies and law enforcement agencies;
- other Phoenix Group companies for the purposes set out in this notice;
- any companies or people that we might in the future sell, or consider selling, our business or part of our business to;
- third parties who operate services to allow you to review, evaluate and obtain financial products and/or services and who allow us and you to search for policies and assets;
- any trustees of your policy; and
- anyone you ask to act on your behalf.
Our administrators, service providers and reinsurers may also share your information in the ways set out above in order to meet their regulatory and legal obligations.
Where we send your information
We operate primarily in the United Kingdom. However, sometimes we will process your personal information in other countries including those outside of the European Economic Area. Where this happens, we take care to ensure that this processing is carried out by organisations on terms which safeguard the security of your personal information.
You have the right to ask:
- what information we hold about you. If you would like details of the information we hold about you, just contact us. We may make a small charge for this service;
- for any inaccuracies in the information we hold about you to be corrected;
- that we stop using any information we hold about you where it may cause you substantial distress or harm; and
- if you would prefer not to receive marketing information from us or selected third parties, please contact us using the details provided.
The Phoenix Group companies referred to in this notice are:
- AXA Wealth Limited
- AXA Wealth Services Limited
- AXA Trustee Services Limited
- AXA Sun Life Direct Limited
- Pearl Group Management Services Limited
- Alba Life Trustees Limited
- Britannic Group Services Limited
- Phoenix Customer Care Limited
- Phoenix Pensions Trustee Services Limited
- Scottish Mutual Pension Funds Investment Limited
- National Provident Life Limited
- Britannic Money Investment Services Limited
- London Life Trustees Limited
- Pearl Group Services Limited
- Pearl Life Services Limited
- Phoenix SCP Pension Trustees Limited
- Phoenix SCP Trustees Limited
- Phoenix Life Pension Trust Limited
- Phoenix Life Limited
- Pearl Group Holdings (No 1) Limited
- Phoenix Unit Trust Managers Limited
- Pearl Customer Care Limited