At Cornish Mutual (Our, We, Us), we understand the importance of maintaining the security and privacy of your personal information. This policy explains how we collect information, what we do with it and what controls you have over your personal information when interacting with Cornish Mutual.

 

Your Privacy

Cornish Mutual take our duty to process your personal information very seriously.

We may change this document from time to time to reflect the latest view of what we do with your information. Please check back frequently; you will be able to see if changes have been made by the date it was last updated at the end of the document.

Refer to the sections below for more details on how and why we use your personal information.

 

When you subscribe to our Newsletter

When subscribing to our newsletter, we ask only for your email address. You will remain on the mailing list until you withdraw your consent by unsubscribing. You can unsubscribe at any time, either by using the unsubscribe option in any of our newsletters or by emailing askus@cornishmutual.co.uk.

 

When you contact us via email

When you make an enquiry via email, the information in the email will only be used to respond to your request or question. We try to respond to email queries as promptly as possible and we will retain the email in line with our retention policies.

 

When you contact us by phone

Cornish Mutual may record all incoming and outgoing phone calls for training and monitoring purposes. If you make payment over the telephone, the call recordings will be paused whilst your payment card details are provided, so we do not record your payment information.

 

When you contact us for a quote

When you ask for a quote from us, we will collect personal and other information in order to be able to respond to your request. Depending on the type of insurance or service that is being quoted for, the information requested may include personal information about other individuals who would be included on the policy as well as information about any insurance history that would be applicable to the proposal for the new policy.

 

When you become a Member by taking out insurance or another product

When you become a Member, we will process your personal information to be able to provide member services, support and information. If you need to make a claim on an insurance policy or wish to make amendments, we will ask for information to be able to facilitate this and find out what has happened. This may include collecting personal information about relevant third parties, which may include minors.

We will automatically provide you with news and updates on our products and services by post, telephone, SMS, email or other electronic means. You may choose to unsubscribe at any time.

 

When you apply for a Bursary

Cornish Mutual offers various bursaries. Each bursary can be used for specific purposes only which will be provided at the time of application. Each bursary has an application process and how your personal information will be processed and stored will be explained as part of the application process. Any successful applicants may be asked to consent to having their photo used in publicity information regarding the Bursary.  

 

Annual General Meeting Communications

As a mutual organisation owned by our Members, it is part of good governance that we advise our Members of the items to be discussed at the Annual General Meeting (AGM) and invite Members to attend or vote on resolutions or issues about how the organisation is run. While you are a Member, you will therefore receive our AGM pack on an annual basis and your contact details will automatically be added to the distribution list for the duration of your Membership. If you provide us with an email address we will send this information to you by email. If you only provide us with a postal address we will use this address for AGM communications.

 

When you take part in research or surveys

Occasionally, we ask for feedback on your interaction with the website, our services and your membership experience. We will usually use a Market Research Agency to undertake the research and gather your responses which may include your name and contact details in case we need to contact you to follow up on your answers. We may provide the Market Research Agency with contact information about members in order to facilitate the research – You can find out more in the sharing your information section.

 

When you enter a prize draw or competition

Occasionally, we may run a prize draw or competition. We will be clear at the time about the terms and conditions of the draw and will not publicly disclose the name of any winners unless we have their consent to do so.

 

Events and Shows

As part of our community engagement and to reach new prospective members and engage with current members, we attend events and shows in the region. We love to meet you at these events but we may be unable to address specific concerns about policies and insurance at the events. If you provide contact information during an event or show, we will only use this for the purpose for which it was collected.

 

Publicly Available Information

In order to reach a wider group of people, we may also collect personal information about people who are not currently Members. We will gather this information from publicly available sources such as websites, public lists or advertisements or by approaching people directly at our events or shows. When you no longer wish to hear from us, you can let us know by unsubscribing via the communication or emailing askus@cornishmutual.co.uk.

 

Links to other websites

To be able to provide you with additional information or services, we occasionally provide links to websites outside of cornishmutual.co.uk. We suggest that you review the privacy policies for any third-party websites you visit as we cannot accept any liability for the way they manage your personal information.

 

The information we need

Cornish Mutual is what’s known as the ‘data controller’ of the personal information you provide to us. Your relationship with us determines how much information we collect from you. We will only ever collect the information needed to provide you with advice and services.

We will be very clear with you about the reason for collecting information and how we intend to use, share and store that information at the point we collect it.

 

Collecting your personal information

We collect personal information about you. The information we collect will depend on your relationship with us but may include:

• names (your name and the names of any other insured persons)
• email address
• postal address
• telephone number
• date of birth
• information you may provide to us by filling in forms (such as proposal forms or claim forms) or by telephoning us
• photographs
• copies of correspondence with you
• details of products you buy from us and
• details of your visits to our website.

Generally we collect the above information directly from you.

We also collect information from other sources which may include:

• social media profiles
• third party databases available to the industry or the public e.g Companies House etc
• firms, loss adjusters and/or suppliers appointed in the process of handling a claim

 

When your personal information changes

If your personal details change, please help us to keep your information up to date by notifying us in writing at Cornish Mutual, CMA House, Newham Road, Newham, Truro, TR1 2SU, by telephoning 01872 277151 or emailing us at askus@cornishmutual.co.uk.

 

Special Category Information

Some of the personal information we ask you for may be Special Category Information as defined by data protection legislation (such as information about your health, criminal convictions, or union membership). We will not use special category personal information about you or others except for the specific purpose for which you provide it and to provide the services described in your policy documents, such as in claims resolution where it may be necessary to pass this information on to legal advisors or medical experts.

 

Children and Minors

The Cornish Mutual website is not intended for anyone under 18.

As a general rule, we do not issue insurance contracts for minors (under 18’s) so we do not hold personal information about minors. The only times when we may collect personal information about minors would be for drivers under the age of 18 where the information is needed for the insurance contract to perform, or where this is advised as part of an insurance claim where it is beneficial to the minor for us to collect that information and where we have a legitimate interest in holding that information.

We may collect information about minors if we run a competition and we keep contact details in order to draw a winner. If we use any photos of a minor we will always seek consent from an adult with responsibility for the child. If we hold the personal information for the competition, as soon as the result is announced we destroy these records, unless we have asked for specific consent to retain the data.

 

Lawful Basis for processing

Cornish Mutual need to have a lawful basis in place to process your personal information. In the table below we set out different circumstances where we process your personal information and the lawful basis we rely on.

 

Personal information collected as part of this Event	Lawful Basis
Signing up for our newsletter (Non-Member)	Consent
Signing up for our newsletter (Member)	Legitimate Interests
Recording Phone Calls	Legitimate Interests
Obtaining a quote	Contract
Taking out a policy, associated correspondence including claims and amendments	Contract
Defending legal claims	Legal Requirement
Taking part in a survey	Consent
Taking part in a prize draw or competition	Consent
Visiting the website	Consent
Annual General Meeting Correspondence	Contract
Applying for a bursary	Consent
Market Research Purposes (sharing Member contact information with the Market Research provider)	Legitimate Interests
Your completion of the Market Research study	Consent
Facebook Adverts - lookalike audiences	Legitimate Interests

 

Where is your information stored?

Wherever possible, all the personal information we process is processed within the UK or European Economic Area (EEA).  

If we have to transfer your personal information outside of the UK or EEA, we do our best to make sure a similar degree of security of personal information by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal information the same protection it has in Europe.

 

If you fail to provide the information requested

If you fail to provide the information requested where we need the personal information for either legal or accounting purposes or to fulfil our contract with you, we will not be able to provide you with an insurance product. We will notify you that you are required to provide the missing information and give you a further reminder to ensure that the information is provided as part of your insurance contract.  

 

Sharing your personal information

In order to provide you with quotes, services and additional support we may need to share your personal information with other organisations. To provide you with a full range of services, we may be required to share your information with other underwriters, reinsurers, loss adjusters, solicitors or suppliers. We may need to disclose some of your information and that of others named on the policy to credit reference or fraud prevention agencies, regulators or law enforcement agencies where we are required to do so by law.  

We may use third parties to help run events, such as our AGM and training activities. To ensure that all potential attendees are notified of the event, your contact information may be securely shared.

To gain feedback on our services and products, we may provide your name and contact information to a Market Research Agency to facilitate feedback from current or past members. You can request that you are not included in the research at any time.

 

Fraud Prevention and Anti-Money Laundering Requirements

To prevent and detect fraud we may at any time:

• Share information with other organisations and public bodies including the police although we only do so in compliance with data protection legislation.
• Check and/or file details with fraud prevention agencies and databases and if we are given false or inaccurate information and we identify fraud, we will record this.

We and other organisations may also use and search other agencies and databases from the UK and other countries to:

• Help make decisions about the provision and administration of insurance, credit and related services for you and members of your household.
• Trace debtors or beneficiaries, recover debt, prevent fraud, and to manage your insurance policies.
• Check your identity to prevent money laundering, unless you provide us with other satisfactory proof of identity.

We and other organisations may also access and use this information to prevent fraud and money laundering, for example when:

• Checking applications for, and managing credit and other facilities and recovering debt.
• Checking insurance proposals and claims.

Law enforcement agencies may also access and use this information. We, and other organisations that may access and use information recorded by fraud prevention agencies, may do so from other countries.

We can provide the names and addresses of the agencies we use if you would like a copy of your information held by them.

 

Financial Sanctions

We will use information about you and that of others named on your policy to ensure compliance with financial sanctions in effect in the UK and internationally. This will include the checking of your information against the HM Treasury list of financial sanctions targets as well as other publicly available sanctions lists. Your information and that of others named on the policy may be shared with HM Treasury and other international regulators where appropriate. You may also be contacted in order to provide further details to ensure compliance with Financial Sanctions requirements.

 

Motor Insurers’ Bureau

We work in partnership with the Motor Insurers’ Bureau (MIB) and associated not-for-profit companies who provide several services on behalf of the insurance industry. At every stage of your insurance journey, the MIB will be processing your personal information and more details about this can be found via their website www.mib.org.uk. Set out below are brief details of the sorts of activity the MIB undertake:

• Checking your driving licence number against the DVLA driver database to obtain driving licence data (including driving conviction data) to help calculate your insurance quote and prevent fraud
• Checking your “No Claims Bonus” entitlement and claims history
• Prevent, detect and investigate fraud and other crime, including, by carrying out fraud checks
• Maintain databases of
  • Insured vehicles (Motor Insurance & policy Data or Motor Insurance Database)
  • Vehicles which are stolen or not legally permitted on the road (Vehicle Salvage & Theft Data or MIAFTR)
  • Motor, personal injury and home claims (CUE)
  • Employers’ Liability Insurance Policies (Employers’ Liability Database)
• Managing insurance claims relating to untraced and uninsured drivers in the UK and abroad
• Working with law enforcement to prevent uninsured vehicles being used on the roads
• Supporting insurance claims processes.

It is vital that the MIB holds the correct registration number for the insured vehicle. It is our responsibility to update your policy to the MIB unless you have a motor trade policy. We fully comply with the agreements in place with the MIB to update your details within seven days; however, it is important that you check your policy documents to ensure that the registration number is recorded correctly.

If the registration number is incorrectly shown on the MIB you are at risk of having your car seized by the Police. You can check that your correct registration number is shown on the Motor Insurance Database at www.askMID.com.

If the registration number is not shown correctly on your policy documents, or you cannot find your car on the MID, please contact us immediately.

 

Other circumstances when we may share your information

There are rare circumstances when we may need to share your information, for example, where we are obliged to by law, for purposes of national security, taxation or criminal investigations. We will never sell or rent your personal information to other organisations.

 

Retaining your information

As Cornish Mutual is a regulated company, we are required to retain information for regulatory and legislative purposes. The time period we retain your personal information for will differ depending on the nature of the personal information and what we do with it. We hold your information only as long as necessary for each reason that we use it and to meet our obligations to you.

 

Securing your information

We have put in place security measures to prevent your personal information from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We ensure that only those employees and partners, who need access to your personal information as part of their business role, are given access. They will only process your personal data on our instructions and our contracts ensure that the information is kept confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we need to.

 

What are your rights?

You have a number of rights about how the personal information you provide can be used. These are:

• Transparency over how we use your personal information (right to be informed).
• The ability to request a copy of the information we hold about you, which will be provided to you within one month (right of access).
• Update or amend the information we hold about you if it is wrong (right of rectification).
• Ask us to stop using your information (right to restrict processing).
• Ask us to remove your personal information from our records (right to be 'forgotten').
• Object to the processing of your information for marketing purposes (right to object).
• Obtain and reuse your personal information for your own purposes (right to data portability).
• Not be subject to a decision when it is based on automated processing (automated decision making and profiling).

If you wish to exercise any of your rights, please contact us at Cornish Mutual on 01872 277151 or askus@cornishmutual.co.uk or by writing to CMA House, Newham Road, Truro TR1 2SU.

If you would like to know more about your rights under data protection law, you can find out more at the Information Commissioner’s Office website.

 

Complaints

If you wish to raise a complaint on how we have handled your personal information, please contact us by telephoning 01872 277151, emailing us at askus@cornishmutual.co.uk or in writing to CMA House, Newham Road, Truro TR1 2SU so that we may investigate the matter. If following our investigation you are not satisfied with our response or believe we are not processing your personal information in accordance with the law you can complain the Information Commissioner’s Office (ICO) by telephoning 0303 123 1113 or using the website www.ico.org.uk.

 

How to contact us

If you wish to talk through anything in our privacy policy, find out more about your rights or obtain a copy of the information we hold about you, please contact us by emailing askus@cornishmutual.co.uk and we will be happy to help.

 

About Us

Cornish Mutual (Cornish Mutual Assurance Company Limited) is registered with the Information Commissioner’s Office as a Data Controller. Our registration number is Z6694948.

The Cornish Mutual Assurance Co. Ltd. is a company registered in England and Wales, registered company number 78768, whose registered office is CMA House, Newham Road, Newham, Truro, TR1 2SU United Kingdom.

Cornish Mutual is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.

 

Last updated: April 2024