Data Protection Notice and Privacy Statement
1. Data Protection
AXA recognises that protecting personal information, including sensitive personal information, is very important to you and that you have an interest in how we collect, use and share such information. AXA, as Data Controller, invites you to review this Data Protection Notice and Privacy Statement, which outlines how we use and protect your information. Rest assured that AXA will use every effort to protect your personal data and we will not sell your personal information to any third party companies. Furthermore, all personal data we gather will be processed in accordance with all data protection laws and principles and in compliance with any code(s) of practice issued by the Office of the Data Protection Commissioner.
References to "AXA" and "we" mean AXA Holdings Ireland Limited and its subsidiaries, including AXA Insurance dac, and any associated companies from time to time. The information that you provide to AXA will be held on a computer, computer database, e-mail, imaged documents, paper files, telephone recording, CCTV footage, letter and/or in any other way.
You have the right to access the personal data holds about you by AXA by sending a written request to the Compliance Department, AXA Insurance dac, Wolfe Tone House, Wolfe Tone Street, Dublin 1 together with payment of a fee of €6.35 / £5.00. You also have the right to require AXA to correct any inaccuracies in the information we hold about you. It may take up to 40 days (from the date of receipt of the completed request) to process your request. The 40 days will not start until we receive a completed request from you (or your authorised representative).
If you require any further information in relation to the contents of this Data Protection Notice and Privacy Statement or any use of your personal or sensitive data, please call us at +353 (0)1 4711812 email us at compliance@axa.ie or write to us at: Compliance department, AXA Insurance dac, Wolfe Tone House, Wolfe Tone Street, Dublin 1.
2. Consent
By taking a fleet car rental you explicitly consent to the processing of your personal or sensitive data as set out in this Data Protection Notice and Privacy Statement.
Where we require personal or sensitive data relating to persons other than you it is important that you have their consent to the processing by AXA of such personal or sensitive data as set out in this document. We shall not disclose personal information without the consent of the individual to whom it relates except in limited circumstances as permitted or required by law.
3. Collection
The personal data we require about you will be gathered and stored as set out in this Data Protection Notice and Privacy Statement. Such gathering and storing will be carried out either directly, by AXA staff or via the various AXA websites, or indirectly, through one of our service providers.
When gathering personal data, AXA or our service providers (as the case may be) may:
- obtain personal information directly from you
- obtain personal information from third parties involved in an incident in which you are involved, including (without limitation) other drivers, passengers of your or any other vehicle, pedestrians, witnesses (whether independent or otherwise), other insurance companies, solicitors representing any third party (whether in civil or (where applicable) criminal proceedings), any other expert appointed by a third party, any person at any relevant case, trial, inquest or any other hearing, or any other relevant person involved in the claims process;
- carry out searches (whether online via websites with publicly available information or various industry specific websites), through various media outlets (including, without limitation, television or radio) or otherwise (including, without limitation, State and/or industry registries)); and/or
- from the Gardaí (in very limited circumstances).
We may request details about you under the contract of insurance regarding your or their health, any medical conditions which may affect your ability to drive and/or the commission of, alleged commission of or conviction for any relevant offence by you under the contract of insurance. If AXA asks you in the course of dealing with a claim or at any other time, please do not send us the results of any genetic tests carried out on you or such other person.
4. Use of Information
AXA will use the information it gathers:
- to verify the information we receive;
- to administer and process any products/services,
- to manage and investigate any claim made by or against you under the policy of insurance;
- to carry out market research and statistical analysis;
- to market other AXA products from time to time (where you have consented to same);
- for staff training, performance reviews and discipline and the review and improvement of AXA's processes and systems;
- for the detection and prevention of fraud and to assist the Gardaí, or any other authorised investigatory branch of the State, with any inquiries or investigations;
- to manage and investigate any complaints;
- for reinsurance and (where necessary) AXA Group reporting purposes;
- for compliance with regulatory, legal and tax laws and regulations; and/or
- as otherwise set out in this Data Protection Notice and Privacy Statement or any other data protection notice, policy booklet or other policy document provided to you by AXA
Where we use automated decision making which produces legal effects for you or otherwise significantly affect you, we will enable you to make representations in relation to the decision in question.
In certain limited circumstances, we or a service provider may be required to transmit your personal data outside the European Economic Area (including, without limitation, to the USA). If this is required we will ensure that such transmission is carried out in accordance with data protection law.
By supplying a vehicle registration number AXA will conduct a search of third party databases (including, without limitation, the National Vehicle File, Insurance–Link, verisk Ireland Limited and the Claims and Underwriting Exchange Register which will return information relating to you and your vehicle, including (without limitation) previous claims, vehicle write off history, NCT/MOT, vehicle modifications and vehicle taxation and import status as part of your normal quotation process.
The National Vehicle File is a database containing details of all registered vehicles in the Republic of Ireland. The database is maintained and supported by the Department of Transport, Tourism and Sport and is central to the processing of motor tax in Ireland.
5. Sharing of Information
Where we choose to have certain services provided by carefully selected third parties, we do so in accordance with the applicable law and we take precautions regarding the practices employed by the service provider to ensure your personal information is kept securely.
In such circumstances we may share your personal data, including sensitive personal data (such as data relating to your health or any relevant criminal convictions), with agents, service providers or expert witnesses (including but not limited to motor repairers, motor engineers, car hire companies, loss adjustors, tradesmen, solicitors/barristers, medical practitioners, various specialist claims investigation service providers, translators (if required), research companies, etc.) or private investigators appointed by us or our agents.
Where a claimant is making a claim against you for which AXA is providing an indemnity, AXA shall be entitled, where we feel it is necessary, to release such information to the claimant, their solicitor or such other appropriate representative of the claimant to allow them to make an application to the Injuries Board or to issue legal proceedings. Such information shall generally (but not exclusively) be limited to your name, address and vehicle registration number and the name and address of any relevant people who are insured under the policy of insurance.
6. Specific Service Providers
In addition to the information set out above, we would also like to draw your attention to some additional information relating to a number of the services we use which involve the sharing of your personal data:
Penalty Point Information
AXA may access accurate data from the Department of Transport, Tourism and Sport in the Republic of Ireland and regarding the driver under the contract of insurance. By requesting a fleet car rental you consent to AXA using your driving licence number for the purpose of determining your eligibility to be covered under the policy of insurance and to contact the Department of Transport, Tourism and Sport. Such searches may be carried out in an automated manner.
Insurance-Link in Republic of Ireland
What is Insurance-Link?
The Insurance-Link database has been created by the Irish Insurance Federation and the self-insured claims task force to assist their members in the detection and defence of exaggerated and fraudulent claims. It contains details of claims made by individuals against insurance policy holders or directly against self-insured members of the service. It is run by Verisk, Unit 15, Trinity Technology and Enterprise Campus, Pearse Street, Dublin 2. Information (including further contact details for Verisk Ireland Limited) on Insurance-Link is available on www.inslink.ie.
How does AXA use the Insurance-Link database?
When you obtain fleet car rental, we will check the details you have supplied with the Insurance-Link database. Where a claim is made against the policy, we will pass details of the claim (including name, address, date of birth and the type of injuries or losses suffered) to the Insurance-Link database. This information is available to other insurance companies through the Insurance-Link database.
Prior to fleet car rental and where any claims are made by or against you, we will also check the Insurance-Link database for information on any previous claims made by you and, if applicable, any third party claimants. In the event that we find any undisclosed claims we will then contact the relevant insurance company to obtain details of such claims.
7. Communication with customers
It is envisaged that we may contact you from time to time in relation to various aspects of your dealings with AXA. This contact will relate to the purposes set out in or referred to in this Data Protection Notice and Privacy Statement and may include (without limitation):
- in connection with a claim or complaint;
- to conduct customer surveys (where you have consented to such contact).
Other than at your request, we will not make calls to you before 9am or later than 9pm Monday to Saturday, or at all on Sundays, bank holidays/public holidays.
8. Telephone recording
We may record or monitor telephone calls (for the duration of the call) in order to ensure accuracy in the communication of instructions to us, to facilitate staff training, for the prevention of fraud, for management of complaints and to improve customer satisfaction. Our recordings shall be and remain the sole property of AXA.