At Phoenix we’re committed to maintaining the trust and confidence of our customers
Our Privacy Policy explains when and why we collect personal information about our customers, how we use it, the conditions under which we may share it with others and how we keep it secure. It also explains how you can obtain details of the information we hold about you, and the choices you have about how we use that information. 
Who are Phoenix and what do we do?

The Phoenix Group is one of the UK’s largest providers of insurance services. Our customers are at the heart of what we do. Our aim is to improve returns for our customers and deliver value to our shareholders. We understand that you expect and deserve excellent service from us at all times and we use third party specialist suppliers to help us deliver those services to you.

The Phoenix Group has grown through acquisition, merger and disposal since the business started in 1782. We have listed below the Companies within the Phoenix Group who will process your personal information. 

The Life Businesses responsible for the products and services we provide to you are

Phoenix Life Limited

Phoenix Life Limited Irish Branch

Phoenix Life Assurance Limited

Abbey Life Assurance Company Limited

The main operating companies who deliver services to the Life Businesses are

Pearl Group Management Services Limited

Pearl Group Services Limited

The additional operating and group companies are

PA(GI) Limited

SunLife Limited

Phoenix Unit Trust Managers Limited

Pearl Trustees Limited

Alba Life Trustees Limited

London Life Trustees Limited

Phoenix SCP Trustees Limited

Phoenix ER1 Limited

Phoenix Customer Care Limited

Phoenix ER3 Limited

Phoenix Pensions Trustee Services Limited

Phoenix ER4 Limited

Scottish Mutual Pension Funds Investment Limited

Phoenix SCP Pension Trustees Limited

Pearl Customer Care Limited

Century Trustee Services Limited

Phoenix Wealth Services Limited

Phoenix Wealth Trustee Services Limited

What information do we collect?

The personal information we collect about you will depend on the products and services you use. We have set out below examples of the types of information we may collect about you. We may receive this information from: 

  • you (including the devices that you use to contact us); 
  • third parties such as your solicitor or a credit reference agency;
  • the research organisations we use or information that is publicly available; and
  • as part of the purchase, sale or merger or proposed purchase, sale or merger of new business. 

Where you provide information about other people (such as joint applicants) we expect you to be responsible for ensuring that they know we are using their personal information in accordance with this Privacy Policy and that you have obtained their consent.

We may ask you for, or you may voluntarily provide, sensitive information such as health information. We may collect this information when you purchase health insurance policies from us - in which case it will only be used with your consent, unless the law permits us to use such information without your consent.  If you provide us with details of your health to help us to understand your specific circumstances, we will use it make appropriate adjustments to the products and services we offer based on the information you provide.

Sensitive information will only be used with your consent, unless the law permits us to use such information without your consent.

 

Information we may collect

Examples of personal information we may collect

 

Basic personal details

 

- Name

- Date of birth

- Gender

- Marital status

- Contact details

- National insurance number

 

 

Proof of identity

 

 

 

- Passport

- Utility bill

- Birth certificate

- Marriage certificate

 

 

Family details regarding

 

 

 

- Spouse

- Partner

- Joint applicant

- Next of kin

- Dependants

- Designated beneficiary or trustee

 

Financial information

 

- Income

- Expenditure

- Credit and bank details

 

 

Professional advisers’ details

 

 

- Financial advisers

- Solicitors

- Estate agents

 

 

Employment details

 

 

 

- Length of service

- Salary

- Tax details

- Places and types of work carried out

 

 

Health

 

 

- Physical

- Mental

- Family

- Medical history

- GP details

- Other medical practitioners details

 

 

Claim

 

- Details of the claim and why you are making it

 

Information from devices you use

 

 

- IP address (internet protocol address)

- Cookies (small text files placed on our computer when you visit a webpage). Please see our Cookies Policy on our website for more information

 

 

Other

 

- Any other information you give to us

 

Information we may collect from research organisations, publicly available information or as part of the purchase, sale or merger of new business

Examples of personal information we may collect

 

Preferences and interests

 

- Your preferences and interests when you tell us what they are or when we deduce them from what we know about you

- Information you provide to us when entering prize draws, competitions or participate in our customer research surveys

 

 

Demographic information

 

-Address

-Postcode

 

How we use your information

We use your information to

Examples

 

Administer your policy

 

- Assessing and processing your application

- Responding to your enquiries

- Managing and administering your product

- Dealing with claims

- Carrying out credit reference checks

- Carrying out arrears and debt collection

- Managing our relationship with you (for example, tracing you when we’ve lost touch to reunite you with the benefits of your product)

- Responding to any complaints you make

 

 

Meet legal and regulatory obligations

 

- Anything we are required or permitted to do to meet our regulatory responsibilities

- Legal and good governance obligations

- Obligations we have in relation to the prevention and detection of crime (including fraud, money laundering and obligations to check sanction lists)

 

 

Improve our business

 

- Marketing - please see the ‘Marketing and profilingsection below

- Improving our products and services

- Maintaining service quality (calls to our customer services may be monitored and/or recorded for authentication, security, quality and training purposes)

- To profile our customer base and help us develop offers, products and services to provide you with the best customer experience. Please see the ‘Marketing and profiling section below for more information

- Contacting you to invite you to form part of our customer panel or research groups regarding our products, services or customer satisfaction surveys (you may be contacted by third parties on our behalf)

- Research (for example, customer research) often conducted by a third party on our behalf

- Corporate reporting

- Analysis (for example, statistical analysis and customer profiling)

- In the event of a sale of all or any part of our business we may have to pass your personal information to another party in a transaction where it is not possible to separate it from information we need to pass to them. We will only do this where there is not a viable alternative

Service communications
We will send you service communications such as information about your product and administrative messages. For example, we may remind you about your policy benefits. You will not be able to opt-out of receiving these essential service communications.
Marketing and Profiling

We may market to you by post and telephone. Please see the information below about this. We will only send you marketing messages by email, texts and other electronic means if we have your permission. You may receive marketing:

  • direct from us;
  • from a third party on our behalf about a product or service that we think may be of interest to you; or
  • from a third party about their products or services that we think may be of interest to you.

If you do not want to receive marketing from us by post or telephone, or if you have changed your mind about receiving marketing by email, texts and other electronic means please let us know by contacting our Customer Services Team. Our contact details can be located in the Contact us section on our website.

We group and organise our customer information to help us develop offers, products and services to provide you with the best customer experience; this is known as profiling. We use third party services and information to do this. For example, we may profile customers to see if they prefer using our website for information about products and services. If they do, we contact those customers to let them know about any new online services we are offering. We do not use profiling to make decisions about you which have legal or other significant effects.

If you do not want us to profile you in this way please contact our Customer Services Team. Our contact details can be located in the ‘Contact us’ section on our website.

Automated decisions

We make certain decisions based solely on automated use of your personal information which may have legal or similarly significant effects on you in the context of:

  • Carrying out credit reference checks – On the basis of your personal information, we will perform a check to determine whether you are likely to be able to meet your obligations to us in any contract you enter into. This is necessary for us to enter into any contract with you. If you do not meet the standards required by the check, we will not be able to conclude a contract with you.
  • Complying with our obligations related to fraud and money laundering – We analyse patterns of transactions and claims to determine whether particular transactions or claims may be fraudulent. This is necessary for us to comply with our legal obligations. We may block transactions or reject claims, if they are considered suspicious and may be required to report it to the regulatory authorities.
  • PPI remediation decisions – If you make a complaint about PPI, and we determine that redress is due, we will use an automated calculator to analyse your transactions to determine the level of redress.

Please contact us if you would like further information about these activities.

Legal basis for using your information
We will only collect, use and share your information where we have a valid reason to do so under the data protection legislation. We have four main reasons for using your information as shown below.

1. Contract – We have a contract with you to deliver a product and service to you. In order to perform and administer that contract we need certain information from you; for example, your contact details.

2. Legal basis – In some circumstances we are permitted by law to process your information. For example, the law recognises that processing data for insurance purposes is in the substantial public interest. We also need certain information from you in order to meet our legal obligations, such as proof of identity. This enables us to meet our fraud and anti-money laundering obligations.

3. To meet our legitimate interests in order to protect our business – We may use your information for our, or a third party’s legitimate business interests provided that we are open with you about this. Our business interests are to improve and develop the products and services within our business. For example, we may market products and services to you which we think will be of interest to you. A third party’s interests may be the improvement of the insurance sector such as a central fraud information base. When we process personal information to meet our legitimate business interests we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

4. Consent – There may be times where we need to obtain your explicit consent to collect and use your personal information (for example, when we process health information that we obtain from you, or when we need your consent to send you marketing messages by email, text and other electronic means). If we ask for your consent to process your personal information, you have the right to withdraw your consent at any time. Please see the section on ‘Your rights’ further in this page for more information.
 
Who do we share information with?

We share your information with

Why we share it

 

Phoenix Group Companies

 

 

We use more than one company in our group to deliver our products and services to you. We may share your data with other Phoenix group companies as part of our commitment to offer you financial products and services that may be of interest to you.

 

Service providers

 

We use third party companies to provide services so we can administer your policy and deliver a service to you. For example, providers of customer service, policy administration, IT systems and software that hold or analyse your information and carry out searches that help us trace you if we lose touch.

 

Reinsurers – a reinsurer is another insurer who takes on the risk of when and how much we have to pay customers on their policy. Like other insurers we use reinsurers to help us manage our risk.

 

Reinsurers help us manage our risk and so they need to see information about the policies they are reinsuring.

 

Anyone you ask us to share your information with.

 

If you ask us to share your information, for example with a trustee or professional adviser, we may check with you to confirm that the person asking for information on your behalf has your permission.

 

Regulatory, government and industry bodies such as:

- HM Revenue & Customs

- Home Office

- Land Registry

- Fraud Prevention Organisations

- Other insurers

- Guarantors

- Credit reference agencies

- Law enforcement bodies

 

To comply with our legal and regulatory obligations, this may include acting in accordance with best practice.

 

Affinity partners (third parties who provide products or services which either we do not provide or which are different from our own).

 

We share your data with carefully selected affinity partners as part of our commitment to offer you financial products and services that may be of interest to you.

 

Customer research partners

 

We conduct customer research to understand what our customers think about the products and services we provide.

Sometimes we use third parties to undertake the research on our behalf. If you are contacted for research purposes we will be clear about the purposes of the research, how any information you provide will be used, who will have access to it and how long it will be kept. We will obtain your consent before we start the research.

 

Professional advisers

 

We use professional advisers to provide services to us, for example legal advice, accountancy services and consultancy services.

 

Courts and those involved in any legal process

 

If a court requires us to disclose your information or if it needs to be disclosed as part of a legal process.

 

Anyone in the future who may buy or merge with our business

 

If we merge with another company or if we are sold then we will need to share your information with the other party.

 In the event of a sale of any part of our business we may have to pass your personal information to another party in a transaction where it is not possible to separate it from the information we need to pass to them. We will only do this where there is not a viable alternative.

 

Where do we send your information?

We operate primarily in the United Kingdom.  However, sometimes the information that we collect from you may be viewed from, transferred to, or stored, outside the European Economic Area (EEA).

We ensure that we put in place appropriate safeguards when we allow your information to be processed outside the EEA. Please contact our Data Protection Officer using the details shown at the end of this document if you would like more information on the appropriate safeguards we have in place.

What if you don’t provide personal information?

We try not to ask you for personal information that we don’t need. If you do not provide certain information we may not be able to provide our service to you. For example, if you don’t provide the information requested on a claim form we may not be able to process your claim. We will try to make clear what information we really need and what information would help us but which is not essential. If you don’t want to provide certain information but are not sure of the impact that it will have on the service please get in touch. Our contact details can be located in theContact ussection on our website.

Your rights

We have explained below your rights, but to keep things simple we have not included all the circumstances or conditions which apply to them. If you would like to exercise these rights please contact our Customer Services Team. Our contact details can be located in the ‘Contact us’ section on our website.  If for any reason the right is limited or doesn’t apply we will explain to you why this is the case.

Stop using my information – If you don’t want us to use your information for our business interests you can ask us to stop and we will do so unless there is an important reason why we need to continue using it.

Stop marketing – You can ask us not to send you marketing messages.

Access – You have the right to ask for a copy of the information that we hold about you and this will usually be provided free of charge. For your security, we will take reasonable steps to confirm your identity before providing you with any personal information we may hold about you.

Transfers – You can request that we transfer information we hold about you to you or a third party in electronic form.

Remove my information – In certain circumstances you can ask us to stop using or holding your information. If we can delete your information we will, but sometimes we have to maintain records for legal reasons. If we cannot comply with your request then we will contact you and explain why. If you ask us to stop using your information we will still keep it, but we will not do anything with it.

Consent – If you have given consent for us to use your information then you have the right to withdraw your consent at any time. The Phoenix Data Protection Officer, will be able to explain to you the consequences of withdrawing consent, and the implications for the continuation of the product or policy that you have with us.

If we have shared the personal information in question with another company (including another company within the Phoenix Group), we will also let them know that you have asked us to stop using or retaining your information unless it is impossible or difficult to do so.

How to update your information

It is important that the information we hold about you is accurate and up to date. Please let us know if your information changes, or the information we hold about you is incorrect. You can ask our Customer Services Team to update or correct your information free of charge.

If we have disclosed the personal information in question to another company (including another company within the Phoenix Group), we will also let them know about the changes unless it is impossible or difficult to do so.

How long do we keep your information?

We will keep your information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

  • maintain business records for analysis and/or audit purposes;
  • comply with record retention requirements under the law;
  • defend or bring any existing or potential legal claims; and
  • deal with any complaints regarding our products or services.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the information.

If you require additional information on our data retention policies please contact our Data Protection Officer.

We may send you marketing messages about our services for up to 2 years after your policy ends, unless you have opted-out of receiving marketing messages from us.

Changing our Privacy Notice

We may change this Privacy Policy from time to time to keep it up to date, or to comply with legal requirements. Any changes we make in the future will be posted on the Privacy Policy section of our website and, where necessary, notified to you.

Phoenix Data Protection Officer contact details

If you would like to contact the Phoenix Data Protection Officer directly in relation to this Privacy Policy please use the following details:

The Phoenix Data Protection Officer

Address:

Phoenix Data Protection Officer
1 Wythall Green Way
Wythall
Birmingham
B47 6WG

Telephone:

UK: 020 3735 0577 (Calls cost no more than a national rate call to 01 or 03 numbers and are included in inclusive minutes and discount schemes in the same way.)

Outside the UK: +44 (0) 20 3735 0577 (Please check the cost with your telephone provider.) 

Please note lines are open between 9.00am and 5.00pm, Monday to Friday.

Email: DataProtection@thephoenixgroup.com

Complaints

If you are unhappy with any aspect of the service we provide, please let us know by contacting our Customer Service Team.

You have the right to complain to the Information Commissioner whose contact details can be located on their website: www.ico.org.uk/global/contact-us

Download our privacy policy
If you would like to print a copy of our Privacy Policy you can download the full version, available here.

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