1.    POLICY STATEMENT

1.1. This policy is designed to provide information on how we deal with the privacy of applicants who apply to any job or member of the Innovation Group for a job and the personal data we hold about them during the recruitment process. For a full list of our group companies see the appendix (which we update from time to time).

2.    OBJECTIVES

2.1. To provide you with details of what information we may collect about you and to give you confidence in how we will use this information both internally and externally; and

2.2. To comply with legal requirements including privacy laws.

3.    THE LEGISLATION

3.1. The UK General Data Protection Regulation (“UK GDPR”) and Data Protection Act 2018 (“DPA 2018”) regulates the way in which “personal data” (i.e. information about you) is processed.
3.2. For ease of reference in this policy, the UK GDPR and DPA 2018, along with other relevant data privacy legislation, will be referred to collectively as “Data Protection Legislation”.

4.    ABOUT THIS DOCUMENT

4.1. Innovation Group (referred to as “we”, “us”, “our”) takes your privacy seriously. We are fully committed to protecting your personal data. We will process and collect personal data and special categories of personal data about you. We recognise:

• our responsibility to keep any data about you safe and secure at all times; and
• the need to treat that data in an appropriate and lawful manner, in accordance with applicable Data Protection Legislation

4.2. We will only process your personal data and special categories of personal data in accordance with Data Protection Legislation and we will adhere to the principles (as applicable) contained in the Data Protection Legislation.
4.3. The purpose of this policy is to provide you with information regarding the types of personal data and special categories of personal data that we hold and process about you and why.
4.4. Processing includes collecting, viewing, transferring, using, holding, storing, recording and destroying your personal data and special categories of personal data.
4.5. This policy is subject to change and any change to this policy or the appendix will be notified under Revision History.

5.    WHAT DO ‘PERSONAL DATA’ AND SPECIAL CATEGORIES OF PERSONAL DATA’ MEAN?

5.1. ‘Personal data” under the GDPR includes information relating to a living person, who can be identified directly or indirectly by such information (e.g. name, ID number, location data, an online identifier, one or more factors specific to the physical, physiological, genetic, mental, economic or social identity of that person).
5.2. “Special categories of personal data” under the GDPR relates to personal information about you of a more private nature and means genetic data, biometric data, data concerning a person’s sex life or orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and health.
5.3. The personal data and special categories of personal data about you held and processed by us may be held in manual or automated/electronic filing systems.

6.    WHAT DO WE DO WITH YOUR PERSONAL DATA AND ON WHAT LEGAL BASIS?

6.1. We use the personal data you provide to us to process your job application. The legal grounds for processing can be summarised as follows:
6.2. To comply with our legal obligations. This includes the following information:

6.2.1. eligibility to work in the UK as required by immigration laws, such as residency and work permit status, nationality, passport and visa documentation;
6.2.2. formal identification documentation to verify your identity, such as a passport or driving licence;
6.2.3. legal disputes involving you, or other employees, workers and contractors, in order to comply with the court process and court orders;
6.2.4. the results of any pre-employment checks carried out, to meet our contractual obligations to our clients and/or regulatory obligations;
6.2.5. DVLA checks to validate driving licence information if the job role you apply for involves you driving company vehicles; and
6.2.6. relating to the occurrence, investigation or prevention of fraud.

6.3. To pursue our legitimate interests as a business. This includes the following information:

6.3.1. your contact details such as your name, address, telephone number and personal email address which will be used to communicate with you in relation to the recruitment process;
6.3.2. your CV and any education history and employment records, professional qualifications and certifications in order for us to consider your suitability for a job vacancy you are applying for;
6.3.3. any interview notes made by us following an interview with you, in order to assess your suitability for the job role you are applying for;
6.3.4. pay and benefit discussions with you to help determine whether a job offer may be made to you;
6.3.5. voicemails, emails, correspondence, your cv, and other communications created, stored or transmitted by you on or to our computer or communications equipment in order to progress the application through the recruitment process;
6.3.6. CCTV in communal and public lobby areas to ensure security, business efficiencies, the protection of company property and for health and safety reasons; and
6.3.7. network and information security in order for us to take steps to protect your information against loss, theft or unauthorised access.

6.4. Where you have consented for us to do so. This includes:
6.4.1. retaining your CV beyond the period set out in our data retention policy if you are unsuccessful in that application, for the purposes of future role vacancies within the company (or Group Companies).

7.    WHAT DO WE DO WITH YOUR SPECIAL CATEGORIES OF PERSONAL DATA AND ON WHAT LEGAL BASIS?

7.1. We process your special categories of personal data for different reasons. These are summarised below.
7.2. To enable you and us to perform our respective obligations or exercise our respective rights in respect of employment and social security and social protection law. This includes the following:

7.2.1. equal opportunities monitoring information (for example race, ethnic origin, sex or religious information). Any such information is used in an anonymised form for statistical purposes only and is not used in relation to your application for employment with us; and
7.2.2. health information to assess and/or to comply with our obligations under employment, equal opportunities and health and safety legislation (for example a requirement to make reasonable adjustments to the recruitment process with you).

7.3. To establish, defend or exercise legal claims in an employment tribunal or any other court of law.
Recruitment

8.    DISCLOSURE AND BARRING SERVICE (DBS CHECKS)

8.1. We may process personal data to carry out DBS/CCJ checks (including criminal convictions):

8.1.1. to meet our obligations in employment, social security and social protection law and where necessary for a particular role within the business; or
8.1.2. where it is necessary for reasons of substantial public interest and to prevent or detect unlawful acts, to protect against dishonesty or to ensure the health and safety of our customers.
8.1.3. in order to assess your suitability for the role;

9.    OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL DATA

9.1. We may share your personal data internally for the purposes set out above to HR employees involved in the recruitment process and/or line managers in the business who are involved in the recruitment process for the job role(s) you are applying.
9.2. We may share your personal data and special categories of personal data with other companies within Innovation Group (as detailed in the Appendix). They may use your personal data for making decisions relating to recruitment.
9.3. We may share your personal data with the following in order to comply with our legal obligations:

9.3.1. Home Office for immigration purposes; and
9.3.2. any other organisation in order to comply with any legal or regulatory obligation or request.

9.4. When we use third party suppliers or providers, we only disclose to them any personal information that is necessary for them to provide their service. We have a contract in place that requires them to keep you information secure and not to use it other than in accordance with our specific instructions.

10.    RECEIVING YOUR PERSONAL DATA

10.1. We may obtain personal data and/or special categories of personal data about you from third party sources, such as recruitment agencies, job boards, recruitment assessment centres, referees and occupational health professionals. Where we receive such information from these third parties, we will only use it in accordance with this policy. In some cases, they will be acting as a controller of your information and therefore we advise you to read their privacy policy.

11.    AUTOMATED DECISION MAKING AND PROFILING

11.1. We do not currently make decisions about you using automated means. We will notify you in writing if this position changes.

12.    WHERE DO WE STORE YOUR PERSONAL DATA OR SPECIAL CATEGORIES OF PERSONAL DATA?

12.1. Your personal data and special categories of personal data is stored electronically on our secure servers which are located within the European Economic Area (“EEA”). Your personal data and special categories of personal data may also be stored in hard copy form and if so, it will be kept in access-restricted, locked filing cabinets.
12.2. We may transfer the personal data we collect about you to the South African branch of our Group Company (“IGBS”), responsible for our recruitment process.
12.3. There is not an adequacy decision by the European Commission in respect of South Africa. This means that South Africa is not deemed to provide an adequate level of protection for your personal data.
12.4. However, to ensure that your personal data does receive an adequate level of protection we have put in place appropriate measures to ensure that your personal data is treated by IGBS in a way that is consistent with and which respects Data Protection Legislation including imposing contractual obligations on IGBS.

13.    HOW LONG DO WE KEEP YOUR PERSONAL DATA?

13.1. We keep your personal data and special categories of personal data for as long as is necessary to fulfil our legal obligations.
13.2. If you are offered and you accept a job with us, your personal information will be transferred to a personnel file. Your data will be held in accordance with our Workforce Privacy Policy, a copy of which will be made available to you if your application is successful.
13.3. If you are unsuccessful in your application for a job with us, your personal data will be destroyed in accordance with the retention policy for unsuccessful applicants under which we will destroy your personal data no later than 6 months after determination that your application has been unsuccessful, unless you consent to a longer period.

14.    YOUR DUTIES

14.1. Please ensure that the information that we hold about you is accurate and up to date by keeping us informed of any changes to your personal data by emailing ukrecruitment@innovation.group.

15.    YOUR RIGHTS

15.1. Under Data Protection Legislation, you have certain rights as a “data subject”.
15.2. You may make a formal request for access to personal data and/or special categories of personal data that we hold about you at any time. This is known as a Subject Access Request (“SAR”). A SAR can be made orally or in writing and we must respond within one month.
15.3. You also have other rights under Data Protection Legislation including:

15.3.1. to have your personal data corrected where it is inaccurate;
15.3.2. to have your personal data erased where it is no longer required. Provided that we do not have any continuing lawful reason to continue processing your personal data, we will make reasonable efforts to comply with your request;
15.3.3. to request your personal data be transferred to another person;
15.3.4. to restrict the processing of your personal data where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings;
15.3.5. to object to the processing of your personal data, particularly where we rely on “legitimate business interests” as a lawful reason for the processing of your data. We have a duty to investigate the matter within a reasonable time and take action where this is warranted. Except for the purposes for which we are sure we can continue to process your personal data, we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data;
15.3.6. to withdraw consent to processing (where we rely on this as a lawful basis for processing). If you withdraw your consent, our use of your personal data before you withdraw is still lawful; and
15.3.7. to receive a copy of certain personal data in a portable format; and
15.3.8. to complain to a supervisory body – if you are concerned about the way we have processed your personal data, you may complain to your data protection regulatory body. In the UK this is the Information Commissioner’s Office (“ICO”) – www.ico.org.uk.

15.4. Where we intend to process your personal data for a purpose other than as set out in this policy, we will provide you with information about the purpose prior to processing your personal data.
15.5. The way we process your personal data and the legal basis on which we rely to process it may affect the extent to which these rights apply. If you would like to exercise any of these rights, please address them in writing to ukrecruitment@innovation.group.

16.    CONTACTS

16.1. If you have any questions about any matter relating to data protection or the personal data and/or special categories of personal data that we process about you, please contact the data privacy team GDPR@innovation.group or write to us at Group Legal, Bembridge House, 1300 Parkway, Solent Business Park, Whiteley, Hampshire, PO15 7AE.

APPENDIX

Innovation Group employing entities (UK):

EMaC Limited

Innovation Property (UK) Limited

Motorcare Services Limited

The Innovation Group (EMEA) Limited

The Warwick Partnership Limited

Gender pay gap report 2024

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Gender pay gap report 2023

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Gender pay gap report 2022

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Gender pay gap report 2021

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Gender pay gap report 2020

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Gender pay gap report 2019

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Gender pay gap report 2018

Download PDF

Modern slavery statement

Download PDF

Modern slavery policy

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Tax strategy

Download PDF

ESG policy statement

Download PDF

This notice is currently under review

1.    NOTICE STATEMENT

This notice is designed to provide information on how we deal with the privacy of job applicants who apply any member of the Innovation Group for a job and the personal data we hold about them during the recruitment process. For a full list of our group companies see the appendix (which we update from time to time).

2.    OBJECTIVES

To provide you with details of what information we may collect about you and to give you confidence in how we will use this information both internally and externally; and

To comply with legal requirements including privacy laws.

3.    THE LEGISLATION

The General Data Protection Regulation 2016 (“GDPR”) regulates the way in which “personal data” (i.e. information about you) is processed.

For ease of reference in this notice, the GDPR, along with other relevant data privacy legislation, will be referred to collectively as “Data Protection Legislation”.

4.    ABOUT THIS DOCUMENT

Innovation Group (referred to as “we”, “us”, “our”) takes your privacy seriously. We are fully committed to protecting your personal data. We will process and collect personal data and special categories of personal data about you. We recognise:

• our responsibility to keep any data about you safe and secure at all times; and
• the need to treat that data in an appropriate and lawful manner, in accordance with applicable Data Protection Legislation.

We will only process your personal data and special categories of personal data in accordance with Data Protection Legislation and we will adhere to the principles (as applicable) contained in the Data Protection Legislation.

The purpose of this notice is to provide you with information regarding the types of personal data and special categories of personal data that we hold and process about you and why.

Processing includes collecting, viewing, transferring, using, holding, storing, recording and destroying your personal data and special categories of personal data.

This notice is subject to change and any change to this notice or the appendix will be notified under Revision History.

5.    WHAT DO ‘PERSONAL DATA’ AND SPECIAL CATEGORIES OF PERSONAL DATA’ MEAN?

‘Personal data” under the GDPR includes information relating to a living person, who can be identified directly or indirectly by such information (e.g. name, ID number, location data, an online identifier, one or more factors specific to the physical, physiological, genetic, mental, economic or social identity of that person).

“Special categories of personal data” under the GDPR relates to personal information  about you of a more private nature and means genetic data, biometric data, data concerning a person’s sex life or orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and health.

The personal data and special categories of personal data about you held and processed by us may be held in manual or automated/electronic filing systems.

6.    WHAT DO WE DO WITH YOUR PERSONAL DATA AND ON WHAT LEGAL BASIS?

We use the personal data you provide to us to process your job application.  The legal grounds for processing can be summarised as follows:

To comply with our legal obligations. This includes the following information:

• eligibility to work in the UK as required by immigration laws, such as residency and work permit status, nationality, passport and visa documentation;
• formal identification documentation to verify your identity, such as a passport or driving licence;
• legal disputes involving you, or other employees, workers and contractors, in order to comply with the court process and court orders;
• DVLA checks to validate driving licence information if the job role you apply for involves you driving company vehicles; and
• relating to the occurrence, investigation or prevention of fraud.

To pursue our legitimate interests as a business. This includes the following information:

• your contact details such as your name, address, telephone number and personal email address which will be used to communicate with you in relation to the recruitment process;
• your cv and any education history and employment records, professional qualifications and certifications in order for us to consider your suitability for a job vacancy you are applying for;
• any interview notes made by us following an interview with you, in order to assess your suitability for the job role you are applying for;
• County Court judgment checks, in order to assess your suitability for the role;
• pay and benefit discussions with you to help determine whether a job offer may be made to you;
• the results of any pre-employment checks carried out, to meet our contractual obligations to our clients and/or regulatory obligations;
• voicemails, emails, correspondence, your cv, and other communications created, stored or transmitted by you on or to our computer or communications equipment in order to progress the application through the recruitment process;
• CCTV in communal and public lobby areas to ensure security, business efficiencies, the protection of company property and for health and safety reasons; and
• network and information security in order for us to take steps to protect your information against loss, theft or unauthorised access.

Where you have consented for us to do so. This includes:

• retaining your CV beyond the period set out in our data retention notice if you are unsuccessful in that application, for the purposes of future role vacancies within the company (or Group Companies).

7.    WHAT DO WE DO WITH YOUR SPECIAL CATEGORIES OF PERSONAL DATA AND ON WHAT LEGAL BASIS?

We process your special categories of personal data for different reasons. These are summarised below.

To enable you and us to perform our respective obligations or exercise out respective rights in respect of employment and social security and social protection law. This includes the following:

• equal opportunities monitoring information (for example race, ethnic origin, sex or religious information). Any such information is used in an anonymised form for statistical purposes only and is not used in relation to your application for employment with us; and
• health information to assess and/or to comply with our obligations under employment, equal opportunities and health and safety legislation (for example a requirement to make reasonable adjustments to the recruitment process with you).

To establish, defend or exercise legal claims in an employment tribunal or any other court of law.

8.    DISCLOSURE AND BARRING SERVICE (DBS CHECKS)

We may process personal data to carry out DBS checks (including criminal convictions):

• to meet our obligations in employment, social security and social protection law and where necessary for a particular role within the business; or
• where it is necessary for reasons of substantial public interest and to prevent or detect unlawful acts, to protect against dishonesty or to ensure the health and safety of our customers.

9.    OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL DATA

We may share your personal data internally for the purposes set out above to HR employees involved in the recruitment process and/or line managers in the business who are involved in the recruitment process for the job role(s) you are applying.

We may share your personal data and special categories of personal data with other companies within Innovation Group. They may use your personal data for making decisions relating to recruitment.

We may share your personal data and special categories of personal data with third parties, agents, subcontractors and other organisations, as listed below, for the purposes of providing services to us or directly to you on our behalf:

• occupational health providers;
• financial product providers;
• pension providers;
• insurance providers;
• employee benefits providers; and
• providers of legal services, including our in house legal team.

We may share your personal data with the following in order to comply with our legal obligations:

• Home Office for immigration purposes; and
• any other organisation in order to comply with any legal or regulatory obligation or request.

When we use third party suppliers or providers, we only disclose to them any personal information that is necessary for them to provide their service. We have a contract in place that requires them to keep you information secure and not to use it other than in accordance with our specific instructions.

10.    RECEIVING YOUR PERSONAL DATA

We may obtain personal data and/or special categories of personal data about you from third party sources, such as recruitment agencies, job boards, recruitment assessment centres, referees and occupational health professionals.  Where we receive such information from these third parties, we will only use it in accordance with this notice. In some cases, they will be acting as a controller of your information and therefore we advise you to read their privacy notice.

11.    AUTOMATED DECISION MAKING AND PROFILING

We do not currently make decisions about you using automated means. We will notify you in writing if this position changes.

12.    WHERE DO WE STORE YOUR PERSONAL DATA OR SPECIAL CATEGORIES OF PERSONAL DATA?

Your personal data and special categories of personal data is stored electronically on our secure servers which are located within the European Economic Area (“EEA”).  Your personal data and special categories of personal data may also be stored in hard copy form and if so, it will be kept in access-restricted, locked filing cabinets.

We may transfer the personal data we collect about you to the South African branch of our Group Company (“IGBS”), responsible for our recruitment process.

There is not an adequacy decision by the European Commission in respect of South Africa. This means that South Africa is not deemed to provide an adequate level of protection for your personal data.

However, to ensure that your personal data does receive an adequate level of protection we have put in place appropriate measures to ensure that your personal data is treated by IGBS in a way that is consistent with and which respects Data Protection Legislation including imposing contractual obligations on IGBS.

13.    HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We keep your personal data and special categories of personal data for as long as is necessary to fulfil our legal obligations.

If you are offered and you accept a job with us, your personal information will be transferred to a personnel file. Your data will be held in accordance with our Workforce Privacy Notice, a copy of which will be made available to you if your application is successful.

If you are unsuccessful in your application for a job with us, your personal data will be be destroyed in accordance with  the retention notice for unsuccessful applicants under which we will destroy your personal data no later than 6 months after determination that your application has been unsuccessful, unless you consent to a longer period.

14.    YOUR DUTIES

Please ensure that the information that we hold about you is accurate and up to date by keeping us informed of any changes to your personal data by emailing ukrecruitment@innovation.group.

15.    YOUR RIGHTS

Under Data Protection Legislation, you have certain rights as a “data subject”.

You may make a formal request for access to personal data and/or special categories of personal data that we hold about you at any time.  This is known as a Subject Access Request (“SAR”).  A SAR can be made orally or in writing and we must respond within one month.

You also have other rights under Data Protection Legislation including:

• to have your personal data corrected where it is inaccurate;
• to have your personal data erased where it is no longer required. Provided that we do not have any continuing lawful reason to continue processing your personal data, we will make reasonable efforts to comply with your request;
• to request your personal data be transferred to another person;
• to restrict the processing of your personal data where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings;
• to object to the processing of your personal data, particularly where we rely on “legitimate business interests” as a lawful reason for the processing of your data. We have a duty to investigate the matter within a reasonable time and take action where this is warranted. Except for the purposes for which we are sure we can continue to process your personal data, we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data;
• to withdraw consent to processing (where we rely on this as a lawful basis for processing). If you withdraw your consent, our use of your personal data before you withdraw is still lawful; and
• to receive a copy of certain personal data in a portable format; and
• to complain to a supervisory body – if you are concerned about the way we have processed your personal data, you may complain to your data protection regulatory In the UK this is the Information Commissioner’s Office (“ICO”) – www.ico.org.uk.

Where we intend to process your personal data for a purpose other than as set out in this notice, we will provide you with information about the purpose prior to processing your personal data.

The way we process your personal data and the legal basis on which we rely to process it may affect the extent to which these rights apply. If you would like to exercise any of these rights, please address them in writing to ukrecruitment@innovation.group.

16.    CONTACTS

If you have any questions about any matter relating to data protection or the personal data and/or special categories of personal data that we process about you, please contact the DPO and grouplegal@innovation.group or write to us at Group Legal, Bembridge House, 1300 Parkway, Solent Business Park, Whiteley, Hampshire, PO15 7AE.

APPENDIX

Innovation Group employing entities (UK)

1Insurer Limited

EMaC Limited

Innovation Fleet Services Limited

Innovation Property (UK) Limited

Motorcare Services Limited

The Innovation Group (EMEA) Limited

This policy is currently under review.

1.    PRIVACY STATEMENT

The Innovation Group Limited and its Group Companies (“Innovation”) manage critical incidents in the car and home on behalf of the world’s leading insurers, brokers and fleet managers, together with warranty and service plan provision for many automotive manufacturers globally. As a result of the services it provides Innovation may have a requirement to process personal information about you. Innovation is fully committed to protecting your personal information and recognises its responsibility to keep any information about you safe and secure at all times. Innovation will only process personal data in accordance with current and applicable data protection legislation (including the General Data Protection Regulation 2016 (“GDPR”)).

2.    OBJECTIVES

This privacy notice explains the following:

• The type of information we may collect about you whether through Innovation’s websites or through other means such as services that we offer, claims that we are dealing with, telephone calls, emails, as well as claims investigations, witness statements, employment records or other third party connections in our business dealings with you;
• How the information about you is used;
• When we may use your details to contact you;
• Whether your information will be shared with anyone else;
• Legitimate grounds of processing your information;
• Your right of erasure; and
• Your right to request the information we hold about you

3.    WHAT INFORMATION DO WE COLLECT ABOUT YOU

In order to provide our group services we may need to collect certain personal data about you. The data processed will depend on your relationship with us (such as client policy holder, third party policy holder, witness, claimant, website user, appointed representative or other person relating to our business). We may obtain personal data about you from: insurers; car dealerships (warranty); garages (repairs); contractors (property repairs); medical experts (if personal injury) or from yourself in a telephone conversation, email or letter.

Personal information collected about you and your dependants may include:

• General information – such as your name, address, email address, telephone numbers, marital status, date of birth, policy and claim information, date of claim, vehicle registration numbers, videos and photographs (may include neighbouring properties or other vehicles).
• Identification Information – such as national insurance number, passport details, driving licence etc.
• Financial Information – such as bank details, credit history, credit score & other financial information
• Medical and health status – such as injuries sustained, medical conditions and customer circumstances (e.g. elderly or vulnerable) etc.
• Other sensitive information – in some rare instances we may receive some sensitive information about your religious beliefs, political opinions, trade union membership, family medical history, physical or mental health conditions, sexual orientation, biometric or genetic data, criminal record, civil litigation history in the process of preventing and investigating fraud. We may also obtain sensitive information if you voluntarily provide it to us though the course of business that we carry out.
• Telephone recordings & CCTV footage – telephone calls with you will often be recorded under regulatory and/or contractual obligations with the data controller and to assist in the investigation and prevention of fraud. In some circumstances calls may be recorded for the purposes of training. If you do not wish us to use your recording for training purposes you have the right to object to this type of processing. If you visit our premises you may also be recorded by CCTV cameras in communal areas.

The data we collect will only be relevant to the service you require and by submitting these details to us you enable us to process your information to perform our obligations under a contract or to enable us to carry out this service for you efficiently and effectively.

4.    HOW WILL WE USE THE INFORMATION?

We will only use your information for the purposes of the business we carry out with you or on behalf of our clients. This may include:

• Contacting you to provide updates and collect further information as part of our business with you;
• Provide a service to you;
• Make decisions regarding your insurance and assistance services such as claim assessment, processing and settling, managing disputes etc;
• Provide an improved service to you through use of call monitoring and recorded phone calls. Please note you retain the right to opt out of your call being recorded for the purposes of training, but calls will still be recorded for record keeping, and prevention or detection of crimes;
• Complaint handling;
• Investigate and prevent fraud and money laundering; and
• Employment.

5.    WHERE DO WE STORE YOUR INFORMATION / PERSONAL DATA?

Personal information is stored in secured servers and storage systems.  This is done within region where possible. We also use third party cloud providers to support us in providing our services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. Each data centre has appropriate technical and operational measures in place to ensure the security of your personal data at all times.

6.    DO WE SHARE YOUR INFORMATION / PERSONAL DATA?

Innovation will only share your personal information with third parties where it is necessary to enable us to provide a service to you and may include:

• Our Group Companies – Innovation consists of a group of companies offering   business process services and software solutions to the insurance, fleet, automotive and property industries. As a result Innovation may need to share your information with our group entities for the purpose of internal administration and to provide the best possible service to you. Please note that some of our group companies are located outside of the European Economic Area (EEA) in countries such as: United States of America, Canada, India, Pakistan, and South Africa. Before we share any of your information with one our group companies located outside of the EEA we ensure there are relevant protections in place which include intra-group agreements and EU model clauses which govern the transfer of such data. Our group companies share the same ethos in connection with privacy and will treat the data as if they were located within the EEA.
• Our Service Partners – In order to provide a service to you we may use other service providers such as repairers, contractors, recovery agents, external engineers, lawyers, rental companies, claim investigators, construction consultants, and other outsourced service providers that may need to assist us with our business. If we need to share your information with our service partners or third party service providers we will ensure they are carefully selected and appropriate measures are in place to ensure your personal data is handled correctly at all times.
• Other third parties – We may share personal information with other third parties such as fire, police, ambulance services, credit reference agencies, fraud prevention agencies and any other third party that may be involved in an incident or a claim that we are dealing with. We may also share your personal information with third parties such as Microsoft, WordPress and Hubspot for purposes of administering queries you raise through contact detail submission forms on our website. 
• Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person 
• Legal basis for processing personal information (EEA visitors only) If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.   However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.  In some cases, we may also have a legal obligation to collect personal information from you. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).   

  Similarly, we may collect and use your personal information in reliance on our legitimate interests (or those of any third party). 

7.    YOUR RIGHTS

We will take appropriate steps to ensure that your information is safe and secure at all times. This will include physical security to our offices, technical security of our IT systems and ensuring that any paperwork we hold about you is stored securely.

We will always process your personal data fairly and lawfully and for the specified purpose of our business dealings or in connection with our contractual obligations with our clients that you may be under a contract with.

We will ensure that the personal data that we hold is relevant, not excessive and will not be held any longer than is necessary and in line with Innovations retention policy. An example of the typical period of time we may hold onto your personal data is 7 years following our last dealing with you.  This is in line with The Limitation Act 1980 and market practice. However, there may be times where we need to hold onto certain personal information longer.  If this is the case we will ensure that we have a legitimate processing ground for this.

You have the right to request a copy of the information we hold about you under a Data Subject Access Request (“DSAR”). In order for Innovation to comply with your DSAR if we are the data controller we will provide a response to you within 30 days. If Innovation are the data processor and we are only processing your information on behalf of one of our clients under a contract, we may have to refer your request to them.  They may ask for our assistance in obtaining the relevant information you have requested. We will notify you of this once we have transferred your request, or you may hear directly from the data controller if we are unable to contact you directly.

If you believe that any of the information that we hold about you is incorrect, or out of date, you have the right to request that we amend your details accordingly. We may have to ask you some security questions in order to do this and may require evidence relating to the change of details where necessary.

You have the right to be forgotten (commonly referred to as “erasure rights”). You are able to make this type of request in any manner, but we would suggest that this request is made in writing wherever possible. There may be some instances where we are unable to comply with your request, for example: if you owe Innovation money under a contract; if you have made a claim which Innovation are or have previously dealt with then we will need to hold onto your information for at least 7 years or any other length of time that has been stipulated to us when we are acting on behalf of another party you are contracted with.

You have the right to request that processing is restricted where for example you contest that the data we hold is inaccurate or where you believe the processing is unlawful. You have the right to receive personal data about you in a machine readable format and to give that data to another controller. You have the right to object to the processing of your personal data where our processing is based on legitimate interest or public interest.

You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing please email unsubscribe@innovation.group. 

Occasionally Innovation may want to use your personal data for a different purpose than it was originally provided. If Innovation want to do this we require your specific and informed consent. We may need to contact you via telephone, email or post in order to obtain your consent and if you choose not to opt in Innovation endeavour not to contact you again relating to this matter unless it is in the normal course of business.

8.    OTHER INFORMATION WE MAY COLLECT

Internet Browser: most websites collect certain analytical data to help them understand browsing habits of users. This may include collection of IP address, operating system type, geographic area of user, time of use, type of browser, pages visited and many more. This information is only used to monitor site usage levels and trends.

Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you use a website. Cookies are then sent back to the originating website on each subsequent visit, or any other website that recognises the cookie. Cookies are used to try and improve your browsing experience by remembering your preferences, letting you navigate more efficiently and can also help to ensure that any advert you see online are more relevant to you and your interests. In order to see our full cookies policy please click here or visit https://www.innovation.group/cookie-policy.

9.    THIRD PARTY WEBSITES

Our websites may contain links to third party websites which are outside our control and are not covered by this privacy notice. For use of these websites please refer to the privacy policy on the third party website.

Please note that the inclusion of a link on our websites does not imply our endorsement of that site or the policies that are contained within it.

10.        RESPONSIBILITIES

The Board of Directors of The Innovation Group Limited (the “Board”) has overall responsibility for this notice, and for reviewing the effectiveness of actions taken in response to breaches raised under this policy.

The Board shall review this notice from a legal and operational perspective at least once a year.

This notice is designed to guide external customers and their policyholders, clients and website users with regard to what information we may collect about you during our business dealings and how and where we store your information.

This policy will also be reviewed by Group Legal on a regular basis.

11.        REPORTING BREACHES

In order for Innovation to deal with any breaches of this notice effectively, and should any employee, third party, client, website users and customers or their policy holders become aware of any potential or actual breach of this notice, please notify Innovation on GDPR@innovation.group so that we may fully investigate the breach and resolve any causes found.

12.        GENERAL

In respect of GDPR Innovation are data controllers when it comes to our employees, and any data where we decide the method and means of processing. For all other types of data Innovation are a data processor which means our processing of your data is controlled by a third party that you are under a contract with.

The Innovation Group contact details are:

Group Legal, The Innovation Group Limited, Bembridge House, 1300 Parkway, Solent Business    Park, Whiteley, Fareham, Hampshire, PO15 7AE.

Innovation has appointed a Data Protection Officer (DPO) who can be contacted by email at GDPR@innovation.group. You have the right to lodge a complaint with the data protection supervisory authority. For Innovation the lead authority is the UK’s Information Commissioner’s Office (ICO).

This policy is currently under review.

Terms and conditions of use

Introduction

These terms and conditions apply between you, the User of this Website (including any sub-domains, unless expressly excluded by their own terms and conditions), and The Innovation Group, the owner and operator of this Website. Please read these terms and conditions carefully, as they affect your legal rights. Your agreement to comply with and be bound by these terms and conditions is deemed to occur upon your first use of the Website. If you do not agree to be bound by these terms and conditions, you should stop using the Website immediately.

In these terms and conditions, User or Users means any third party that accesses the Website and is not either (i) employed by The Innovation Group and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to The Innovation Group and accessing the Website in connection with the provision of such services.

Intellectual property and acceptable use

1. All Content included on the Website, unless uploaded by Users, is the property of The Innovation Group, our affiliates or other relevant third parties. In these terms and conditions, Content means any text, graphics, images, audio, video, software, data compilations, page layout, underlying code and software and any other form of information capable of being stored in a computer that appears on or forms part of this Website, including any such content uploaded by Users. By continuing to use the Website you acknowledge that such Content is protected by copyright, trademarks, database rights and other intellectual property rights. Nothing on this site shall be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark, logo or service mark displayed on the site without the owner’s prior written permission
2. You may, for your own personal, non-commercial use only, do the following:
   1. retrieve, display and view the Content on a computer screen
3. You must not otherwise reproduce, modify, copy, distribute or use for commercial purposes any Content without the written permission of The Innovation Group.

Prohibited use

1. You may not use the Website for any of the following purposes:
   1. in any way which causes, or may cause, damage to the Website or interferes with any other person’s use or enjoyment of the Website;
   2. in any way which is harmful, unlawful, illegal, abusive, harassing, threatening or otherwise objectionable or in breach of any applicable law, regulation, governmental order;
   3. making, transmitting or storing electronic copies of Content protected by copyright without the permission of the owner.

Links to other websites

1. This Website may contain links to other sites. Unless expressly stated, these sites are not under the control of The Innovation Group or that of our affiliates.
2. We assume no responsibility for the content of such Websites and disclaim liability for any and all forms of loss or damage arising out of the use of them.
3. The inclusion of a link to another site on this Website does not imply any endorsement of the sites themselves or of those in control of them.

Privacy Policy and Cookies Policy

1. Use of the Website is also governed by our Privacy Policy and Cookies Policy, which are incorporated into these terms and conditions by this reference. To view the Privacy Policy and Cookies Policy, please click on the following: https://www.innovation.group/privacy-policy and https://www.innovation.group/cookie-policy.

Availability of the Website and disclaimers

1. Any online facilities, tools, services or information that The Innovation Group makes available through the Website (the Service) is provided “as is” and on an “as available” basis. We give no warranty that the Service will be free of defects and/or faults. To the maximum extent permitted by the law, we provide no warranties (express or implied) of fitness for a particular purpose, accuracy of information, compatibility and satisfactory quality. The Innovation Group is under no obligation to update information on the Website.
2. Whilst The Innovation Group uses reasonable endeavours to ensure that the Website is secure and free of errors, viruses and other malware, we give no warranty or guarantee in that regard and all Users take responsibility for their own security, that of their personal details and their computers.
3. The Innovation Group accepts no liability for any disruption or non-availability of the Website.
4. The Innovation Group reserves the right to alter, suspend or discontinue any part (or the whole of) the Website including, but not limited to, any products and/or services available. These terms and conditions shall continue to apply to any modified version of the Website unless it is expressly stated otherwise.

Limitation of liability

1. Nothing in these terms and conditions will: (a) limit or exclude our or your liability for death or personal injury resulting from our or your negligence, as applicable; (b) limit or exclude our or your liability for fraud or fraudulent misrepresentation; or (c) limit or exclude any of our or your liabilities in any way that is not permitted under applicable law.
2. We will not be liable to you in respect of any losses arising out of events beyond our reasonable control.
3. To the maximum extent permitted by law, The Innovation Group accepts no liability for any of the following:
   1. any business losses, such as loss of profits, income, revenue, anticipated savings, business, contracts, goodwill or commercial opportunities;
   2. loss or corruption of any data, database or software;
   3. any special, indirect or consequential loss or damage.

General

1. You may not transfer any of your rights under these terms and conditions to any other person. We may transfer our rights under these terms and conditions where we reasonably believe your rights will not be affected.
2. These terms and conditions may be varied by us from time to time. Such revised terms will apply to the Website from the date of publication. Users should check the terms and conditions regularly to ensure familiarity with the then current version.
3. These terms and conditions together with the Privacy Policy and Cookies Policy contain the whole agreement between the parties relating to its subject matter and supersede all prior discussions, arrangements or agreements that might have taken place in relation to the terms and conditions.
4. The Contracts (Rights of Third Parties) Act 1999 shall not apply to these terms and conditions and no third party will have any right to enforce or rely on any provision of these terms and conditions.
5. If any court or competent authority finds that any provision of these terms and conditions (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of these terms and conditions will not be affected.
6. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
7. These terms and conditions will be governed by and interpreted according to English law. All disputes arising under these terms and conditions will be subject to the exclusive jurisdiction of the English courts.

The Innovation Group details

1. The Innovation Group is a company incorporated in England and Wales with registered number 03256771 whose registered address is Bembridge House, 1300 Parkway, Whiteley, Hampshire PO15 7AE and it operates the Website https://www.innovation.group. The registered VAT number is 765 3677 89.

You can contact The Innovation Group by email on info@uk.innovation-group.com.