Privacy Policy

Last updated: May 22, 2023

MPL Claims Management Limited ("we" or "us") respect your privacy and are committed to protecting your personal data. This privacy policy describes our policies and procedures on the collection, use and disclosure of your information when you use or are involved with our Services and tells you about your privacy rights and how the law protects you.

This privacy policy applies to the following types of individual, whose personal data we collect and use (which we refer to as “you”):

Individuals who contact us through our website;
Users of our Claims Data Access Portal (“cDap Portal”) – in particular, individuals at insurance brokers, fleet managers and policy holders; and
Individuals whose data is uploaded to the cDap Portal by our insurance broker contacts, fleet managers and policy holders – in particular, individuals who have been involved in an insurance claim (claimants and defendants) and relevant points of contact at insurers.

This privacy policy contains the following information:

INTERPRETATIONS AND DEFINITIONS
INFORMATION ABOUT THE CDAP PORTAL AND DETAILS OF OUR DPO
THE DATA WE COLLECT ABOUT YOU AND HOW IT IS COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
MISCELLANEOUS
SCHEDULE: COOKIES POLICY

1. INTERPRETATION AND DEFINITIONS
For the purposes of this privacy policy the following definitions shall apply:

Account	means a unique account created for users of our cDap Portal to access our Services or parts of our Services;
cDap Portal	means MPL Claims’ ‘Claim Data Access Portal’ which can be accessed at: https://mpl-technology.co.uk/portal
Cookies	means small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses;
Device	means any device that can access the Services such as a computer, a cell phone or a digital tablet;
Personal Data	means any information that relates to an identified or identifiable individual;
Services	means the services provided through the cDap Portal and/or our Website;
Service Provider	means any natural or legal person who processes the data on our behalf. It refers to third-party companies or individuals employed by us to facilitate the Services, to provide the Services on our behalf, to perform services related to the Services or to assist us in analysing how the Services are used;
Usage Data	refers to data collected automatically, either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit); and
Website	refers to MPL Claims’ website, accessible at https://www.mplclaims.com/

2. INFORMATION ABOUT THE CDAP PORTAL AND DETAILS OF OUR DPO

CDAP Portal

This privacy policy aims to give you information on how MPL Claims Management Limited collects and processes your Personal Data through your use of this Website, and any data processed by the cDap Portal.

The cDap Portal enables Users of the cDap portal to do the following: Contacts at insurance broker customers, fleet managers and policy holders can report claims directly to us; and have ‘read-only’ access to view a restricted version of the relevant claim data.

If you create an account on the cDap Portal you will be asked for a “Name” and a “Password” which will be used to identify you. We will also create a “session” cookie to track your login status, capture your IP address and your “user agent” information as a way to authenticate you. Please see our Cookies Policy contained in the Schedule below for more detail in relation to our use of cookies.

We use your Personal Data to provide and improve the Services. By using the Services, you agree to the collection and use of information in accordance with this privacy policy.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

DPO Contact Details

You have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name: Kevin Linder

Email address: DPO@ergospecialty.co.uk

Postal address: MPL Claims Management Limited, The Octagon, 27 Middleborough, Colchester, CO1 1TG;

Telephone number: 01206 646 328

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

3. THE DATA WE COLLECT ABOUT YOU AND HOW IT IS COLLECTED Types of Data Collected Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). While using our Services, we may collect, or ask you to provide us with, certain personally identifiable information about you, which we summarise as follows:

Type of Individual	Type of Personal Data Collected	Examples
Claimant / Defendant	Identity Data	first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
Claimant	Contact Data	billing address, delivery address, email address and telephone numbers
Policy holder	Financial Data	bank account and payment card details
cDap users at insurance broker customers	Transaction Data	details about payments to and from you and other details of products and services you have purchased from us
All cDap users	Usage Data	internet protocol (IP) address, your login data, browser type and version, operating system and platform.
All cDap users	Profile Data	Your email address and password.
cDap users at insurance broker customers, points of contact at insurers	Business Contact Details	Email address.

Tracking Technologies and Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. For more information about the cookies we use, please see the schedule to this privacy policy.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data when the law allows us to.

We have set out in the table below a summary of all the ways we use your Personal Data, and which of the lawful bases under the UK GDPR we rely upon for each type of use. We have also identified what our legitimate interests are where appropriate.

Please contact our DPO if you need further specific details about the lawful bases we are relying on to process your Personal Data.

Type of Individual	Type of Personal Data Collected	Purpose/Activity	Lawful basis for processing including basis of legitimate interest
All cDap users	Identity Data	To register you as a user of the cDap Portal.	Necessary for our legitimate interests – to provide the cDap portal
All cDap users	Contact Data	To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy updates or informative (b) Notifying you about the functionalities or Services, including security updates (c) Managing your requests to us	Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services)
All cDap user	Usage Data	To administer and protect our business, the cDap Portal and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
cDap users at insurance broker customers	Profile Data	To use data analytics to: (a) identify usage trends (b) evaluate and improve our system and your experience (c) improve our customer relationships and experiences	Necessary for our legitimate interests (to define types of customers for our Services, to keep our Website updated and relevant, to develop our business
Points of contact at insurers	Business Contact Details	To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which held by us about our Services users is among the assets transferred.	Necessary for our legitimate interests – in particular for the continued growth and evolution of our business. If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different privacy policy.
All cDap users and other data subjects	All data above	For general purposes in relation to providing the Services, including to share with the recipients listed in section 5 below.	Necessary for our legitimate interests – in order to provide the cDap Portal and for the legitimate interests below in section 5.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your Personal Data with the parties set out below (and in accordance with the below legitimate interests where relevant) for the purposes set out in the table in section 4 of this privacy policy:

With Service Providers: We may share your Personal Data with Service Providers to monitor and analyse the use of our Services.
For business transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.
With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy policy. Affiliates include our parent company (Ergo UK Specialty) and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
With business partners - we may share your information with our business partners to offer you certain products, services or promotions.
With other users: when you share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With your consent: we may disclose your Personal Data for any other purpose with your consent.
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

We may disclose your Personal Data in the good faith belief that such action is necessary to:

comply with a legal obligation;
protect and defend our rights or property;
prevent or investigate possible wrongdoing in connection with the Service;
protect the personal safety of Users of the Services or the public; and/or
protect against legal liability

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions and under the terms of a contract which includes detailed obligations on them to protect your data and only use it for the purposes of performing their services to us.

6. INTERNATIONAL TRANSFERS

We do not transfer your Personal Data outside the UK. Your information, including Personal Data, is processed at our operating offices, the address for which is set out above. We use Amazon Web Services to host our data, in particular using their UK data centres.

7. DATA SECURITY

The security of your Personal Data is important to us, but please be aware that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially reasonable efforts to protect your Personal Data, we cannot guarantee its absolute security.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Our Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information. An individual has the right to withdraw their consent at any time.

8. DATA RETENTION We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. The relevant data retention periods are set out below. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Our retention periods are as follows:

A retention period for Personal Data commences once the Personal Data ceases to be ‘live’ e.g. a contract ends.
Liability Records	12 Years
Underwriting Records with an Employers Liability Element	60 Years
Other General Insurance Records	7 Years
Complaints Records (Complaints Files)	5 Years following resolution
Complaints Records (MI and Root Cause Data)	10 Years following resolution
Claims Records (Claims Files)	5 Years following full and final settlement
Claims Records (Claims records and Bordereaux)	10 Years following full and final settlement
Client Records	10 Years
Accounting Records	10 Years
Audit Records 10 Years	10 Years

We will securely destroy all information of a confidential or sensitive nature on paper and electronic media when it is no longer required. This ensures compliance with the Data Protection laws and the duty of confidentiality we owe to our employees, clients and customers.

9. YOUR LEGAL RIGHTS

You have certain rights under data protection laws in relation to your Personal Data as follows:

Request access to your Personal Data.
Request correction of your Personal Data.
Request erasure of your Personal Data.
Object to processing of your Personal Data.
Request restriction of processing your Personal Data.
Request transfer of your Personal Data to another data controller.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us using the DPO details above. Not all of these rights are absolute (e.g. the right to erasure, right to object only apply in certain circumstances) – we will assess your request, acknowledge it promptly.

No Fee Usually Required

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month (unless a different timescale applies under UK data protection law). Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. MISCELLANEOUS

Links to Other Websites

Our Services may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on this page.

We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the "Last updated" date at the top of this privacy policy.

You are advised to review this privacy policy periodically for any changes. Changes to this privacy policy are effective when they are posted on this page.

Schedule

Cookies Policy

Tracking Technologies and Cookies
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

We use Cookies and similar tracking technologies to track the activity on the cDap Portal and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our Services. The technologies we use may include:

* Cookies or Browser Cookies. A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Services. Unless you have adjusted your browser setting so that it will refuse Cookies, our Services may use Cookies.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser. Learn more about cookies on the ICO website.

We use both Session and Persistent Cookies for the purposes set out below:

* Necessary / Essential Cookies

Type: Session Cookies

Administered by: us

Purpose: These Cookies are essential to provide you with services available through the cDap Portal and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the Services that you have asked for cannot be provided, and we only use these Cookies to provide you with those Services.

* Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: us

Purpose: These Cookies identify if users have accepted the use of cookies on the cDap Portal.

* Functionality Cookies

Type: Persistent Cookies

Administered by: us

Purpose: These Cookies allow us to remember choices you make when you use the cDap Portal, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences
every time you use the cDap Portal.