At Cornish Mutual (Our, We, Us), we respect your privacy and are committed to protecting 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.
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 are browsing our website, we have cookies in place to ensure that the website works well and provides information on how you navigate the site and the pages you visit. You will be given the option to agree to these cookies when you visit the website. Cookies are small files which ask permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. A cookie does not give us access to your computer or any information about you, other than the data you choose to share with us.
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 firstname.lastname@example.org. We use a third-party provider to deliver our newsletter and gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter.
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 but it can take the team up to 2 days to respond to email queries especially at busy times, so please be patient with us. If your email relates to a policy or claim, it can take 5 working days to respond and we will retain the email as part of our policy communications 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. The information you discuss over the phone may be recorded and retained for a period of 2 years. 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 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.
As part of its Future Farming Programme, Cornish Mutual offers four bursaries of £500 to students studying an agriculture-based level 1, 2 or 3 course. The money can be used towards course-related costs such as buying PPE and funding transport or covering additional qualifications. There is an application process for these bursaries. When you apply for a bursary, the information provided will be used to assess your application against the bursary criteria. Successful applicants will be presented with an award and £500 and will 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 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.
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 current members, we may 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 with a view to providing a quotation. 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. Following our initial contact if we do not immediately provide you with a quotation, we will ask for your consent to store your data for future contact.
In order 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.
Facebook Adverts (Sponsored Posts)
Occasionally we run Facebook Adverts to promote the visibility of our services. When you click on our advert you are consenting to finding out more about us. Facebook collects various types of information on its users, including demographic information, location, interests, and behaviours. When we set up a Facebook advertising campaign, we have access to this data and can use it to target our ads to relevant audiences.
Our Facebook Adverts allows us to find out more about the actions of users after they are redirected to our website. It also allows us to measure the efficiency of our Facebook adverts for statistical and market research purposes. Using this information allows us to improve our advertising for a better experience for our users and provide you with further advertising on Facebook and the use of Custom Audiences. You can find out more about this and withdraw your consent here: https://www.facebook.com/ads/website_custom_audiences/
We may create a lookalike audience as part of our Facebook advertising with the aim of engaging new members. A lookalike audience requires that we provide email addresses of current members and then Facebook looks for similar individuals to show adverts to. If you do not wish your email address to be used for Facebook lookalike audiences, please email us at email@example.com.
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.
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
- 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 firstname.lastname@example.org.
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 also 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
Signing up for our newsletter (Non-Member)
Signing up for our newsletter (Member)
Recording Phone Calls
Obtaining a quote
Taking out a policy, associated correspondence including claims and amendments
Defending legal claims
Taking part in a survey
Taking part in a prize draw or competition
Visiting the website
Annual General Meeting Correspondence
Market Research Purposes (sharing Member contact information with the Market Research provider)
Your completion of the Market Research study
Facebook Adverts - lookalike audiences
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.
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 shared.
To gain feedback on our services and products, we may pass 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 these 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.
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 Insurance Database
Where the insurance we provide is for a motor vehicle, the information relating to your policy will be added to the Motor Insurance Database (MID) managed by the Motor Insurers’ Bureau (MIB). The MID and the data stored on it may be used by certain statutory and/or authorised bodies including the Police, the DVLA, the DVANI, the Insurance Fraud Bureau and other bodies permitted by law for purposes not limited to but including:
- Electronic Licensing (Tax Discs),
- Continuous Insurance Enforcement,
- Law enforcement (prevention, detection, apprehension and/or prosecution of offenders),
- The provision of government services and/or other services aimed at reducing the level and incidence of uninsured driving.
If you are involved in a road traffic accident (either in the UK, the EEA or certain other territories), insurers and/or the MIB may search the MID to obtain relevant information.
Individuals (including his or her appointed representatives) pursuing a claim in respect of a road traffic accident (including citizens of other countries) may also obtain relevant information which is held on the MID.
It is vital that the MID holds the correct registration number. It is our responsibility to update your policy to the MID unless you have a motor trade. 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 MID you are at risk of having your car seized by the Police. You can check that your correct registration number is shown on the MID 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.
We hold your information only as long as necessary for each reason that we use it.
For example, your email address on our subscriber list will be held whilst you are a subscriber.
For expired insurance policies, the information related to the policy is retained for 21 years from the date the policy lapsed.
We retain personal information on any Employers Liability policies for 60 years as we may need to find a record of your insurance policy if there is a future claim made against you and we have a legitimate business interest in being able to look back at claims experience and any notes made when you were a Member if you request to become a Member again.
We retain personal information on closed property claims for 3 years and liability claims for 21 years because of statutory limitation periods.
If we collect personal information about Non-Members/Prospects, we will only retain this information for a period of 2 years unless you give us consent to keep it for longer. You can withdraw this consent at any time by contacting us.
We delete records of telephone calls after 2 years.
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 email@example.com 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 Commissioners Office website.
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 firstname.lastname@example.org 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.
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 2023