Last updated: May 22, 2023
1. INTERPRETATION AND DEFINITIONS
|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
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.
DPO Contact Details
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.
|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.|
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:
(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.
|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 disclose your Personal Data in the good faith belief that such action is necessary to:
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.
|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|
9. YOUR LEGAL RIGHTS
You have certain rights under data protection laws in relation to your Personal Data as follows:
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.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Tracking Technologies and 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
* 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.