Controllers:

IQUW Syndicate Management Limited, 30 Fenchurch Street, London EC3M 3BD

IQUW Syndicate Services Limited, 30 Fenchurch Street, London EC3M 3BD

IQUW Administration Services Limited, 30 Fenchurch Street, London EC3M 3BD

Data Protection Officer: Anthony Davies, dpo@iquw.com

About Us

One or more of IQUW Syndicate Management Limited, IQUW Syndicate Services Limited and IQUW Administration Services Limited (“we”, “us” or “our”) act as data controllers for your personal information. We are part of the Starr group of companies. Starr is the global marketing name for the insurance and travel assistance companies of Starr International Company, Inc. and investment business of C. V. Starr & Co., Inc. and their subsidiaries.

Our registered office is at 30 Fenchurch Street, London EC3M 3BD.

Syndicate 218 offers a broad range of specialist motor insurance products under the ERS brand to personal lines and commercial market segments in the United Kingdom. For more information, click here: (https://www.ers.com/about-us]

This privacy policy expands on the Data Protection Notice included in our ERS policy documents. It describes the way in which we use your personal information and provides details of your rights. It contains essential information so please make sure you read it carefully. We may update this notice from time to time.

Introduction to the Insurance Market

Insurance involves the use and sharing of personal data between different participants in the insurance market, such as insurers, brokers, and reinsurers. The London Insurance Market has produced a Core Uses Information Notice which explains how personal data is used and shared through the insurance lifecycle. Our use of personal data is consistent with this notice. We recommend that you read it alongside this privacy notice.

View the current version of the notice:

https://lmg.london/wp-content/uploads/2024/05/Lloyds-Core-Uses-Notice-Document-28-05-24.pdf

Who does this Privacy Policy apply to?

This privacy policy describes how we manage personal information about the following people in relation to ERS insurance policies:

• People who request a quote, either directly or via a broker
• Insurance policyholders
• Named drivers and others covered by an ERS insurance policy.
• Beneficiaries of an ERS insurance policy (where applicable)
• People who make a claim against one of our policyholders
• Witnesses and other third parties whose information we may receive.
• People who participate in ERS marketing promotions
• Users of the ers.com website

We process personal information in line with the UK’s Data Protection laws and other relevant laws that apply.

The personal information we may collect about you.

Types of Personal Data	Details
Individual details	Name, address (including proof of address), other contact details such as email and phone numbers, gender*, marital status, date and place of birth, nationality, employment status, job title, image, details of family members including their relationship to you. *This is used for identification purposes, demographic analysis, modelling and forecasting only
Identification details	National insurance number, passport number, driving licence number, other relevant licences.
Financial information	Bank account and/or payment details, income, and other financial information.
Risk details	Information to assess risk and provide insurance quotes, including data relating to your health, disabilities, and criminal convictions (including motoring offences).
Policy information	Information about the quotes you receive and policies you take out
Telematics (if you use this technology)	Driving behaviour, location, frequency of vehicle use, time of use, mileage.
Credit and anti-fraud information	Credit history, credit score, sanctions, and criminal offences, including information received from external databases about you.
Previous and current claims	Information about previous and current claims (including under other insurance policies) which may include data relating to your health, disabilities, criminal convictions (including motoring offences) and in some cases surveillance reports; dashcam recordings where this technology is used; includes information about you from external databases and information collected from publicly available sources of information, including social media
Special categories of personal data	Information about health (including information about injuries sustained as a result of a motor vehicle incident), disability, criminal convictions (including motoring offences).
Technical data (if you use the ers.com website)	Your device and internet connection details such as IP address

Where we collect your personal information

We may collect personal information about you from:

• You
• Your broker
• Our policyholder
• Your family members
• Your employer or their representative
• Other companies in the insurance market, including providers of black box (telematics) services.
• Credit reference agencies.
• Anti-fraud databases, claims registers, sanctions list, court judgment, and similar databases.
• Government agencies such as the DVLA (to check licence and vehicle information) and HMRC.
• The publicly available electoral register
• In the event of a claim, third parties including the other party to the claim, witnesses, experts, loss adjusters, legal advisers, and claims handlers.
• Other publicly available sources of information including social media.
• Cookies and similar technology – These are set on your device by us and our trusted partners. For further information please refer to our Cookies Policy.

How we use and disclose your personal information

Below is a summary of the various stages of the insurance relationship. Further details about how we use and disclose your personal information are set out in the subsequent sections of this privacy policy.

Quotation/Inception:

• Setting you up as a client or beneficiary, including fraud, sanctions, credit, and anti-money laundering checks
• Evaluating the risks to be covered and matching to appropriate policy/premium.
• Payment of premium where the insured/policyholder is an individual.

Policy administration:

• Client care, including communicating with you and sending you updates.
• Payments to and from individuals.

Telematics:

• Determining driving behaviour and driving patterns.
• Developing flexible telematics rating models.

Claims Processing:

• Managing insurance and reinsurance claims
• Defending or prosecuting legal claims
• Investigating or prosecuting fraud
• Safeguarding the rights and wellbeing of any children involved

Renewals:

• Contacting the insured/policyholder to renew the insurance policy.
• Evaluating the risks to be covered and matching to appropriate policy/ premium.
• Payment of premium where the insured/policyholder is an individual.

Other purposes outside of the insurance lifecycle but necessary for the provision of insurance throughout the insurance lifecycle period:

• Complying with our legal or regulatory obligations
• General risk modelling and testing
• Transferring books of business, company sales & reorganisations
• The purchase by ERS of reinsurance coverage and reinsurance claims. This relates to large losses only.

Disclosing and sharing your information:

To assess and administer your insurance contract, or to handle any claims, we may need to share personal information such as your name, address, date of birth and, where relevant, information about medical conditions or criminal convictions.

This information may be shared with organisations including credit reference agencies, anti‑fraud databases, other insurers and underwriters, and group companies that provide administrative or support services.

Where a claim is made, information may also be shared with external claims handlers, loss adjusters, courts, legal advisers, other expert advisers, and third parties involved in the claim.

For reinsurance purposes, information may be shared with reinsurance brokers, reinsurers, and legal advisers. Further details about these disclosures are set out below.

Information about your health, disabilities and criminal convictions is treated as more sensitive under data protection laws and is given extra protection. We will only share this type of information where it is necessary to administer your insurance contract, handle claims, prevent or detect fraud, or for reinsurance purposes.

Accepting and Administering Your Policy

If you pay your premiums via a credit facility, we may share your information with credit reference agencies and other companies for use in credit decisions, to prevent fraud and to find people who owe money. We share information with other insurers, certain government organisations, and other authorised organisations. We may verify driving licence and vehicle information with the DVLA and may check No Claims records against an external database.

If you ask us to transfer your policy to another broker, we will disclose details of your policy (including any other people covered by the policy), any claims made and any other related information to the new broker at your request.

Insurance underwriting

We look at the possible risk in relation to your prospective policy (or anyone else involved in the policy) so that we can:

• Consider whether to accept a risk.
• Make decisions about providing and dealing with insurance and other related services for you and members of your household.
• Set price levels for your policy.
• Confirm your identity to prevent money laundering; and
• Check the claims history for you or any person or property likely to be involved in the policy or a claim at any time. We may do this:

1. When you apply for or change your insurance.
2. If there is an accident or a claim; or
3. At the time you renew the policy.

Profiling

We use personal information to help calculate insurance premiums and assess risk. This may involve comparing your information with industry averages and using it to help improve how risks are assessed. This is known as profiling.

Where relevant, profiling may include the use of sensitive information, such as health details or motoring convictions.

Some decisions, such as whether we can offer cover or how much the premium will be, may be made automatically without staff involvement. These are called automated decisions.

Automated decision making of insurance products based upon your personal data falls under Article 22 of the UK GDPR, and we carry out this activity due to it being necessary for the entry into or performance of a contract. We rely on the information you provide to your broker, and you can discuss the outcome of any automated decisions with your broker. See Your Rights below for further information.

Motor Insurers Bureau (MIB)

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

• Checking your driving licence number against the DVLA driver database to obtain driving licence data (including driving conviction data) to help calculate your insurance quote and prevent fraud.
• Checking your ‘No Claims Bonus’ entitlement and claims history.
• Prevent, detect, and investigate fraud and other crime, including, by carrying out fraud checks.
• Maintaining databases of Insured vehicles (Motor Insurance Policy Database or Motor Insurance Database/MID)

1. Vehicles which are stolen or not legally permitted on the road (Vehicle Salvage & Theft Data or MIAFTR)
2. Motor, personal injury, and home claims (CUE)
3. Employers’ Liability Insurance Policies (Employers’ Liability Database)

• Managing insurance claims relating to untraced and uninsured drivers in the UK and abroad
• Working with law enforcement to prevent uninsured vehicles being used on the roads.
• Supporting insurance claims processes

You can find out more about how the MIB uses personal information here: www.mib.org.uk/privacy-and-cookie-policy/

Managing claims

If you make a claim, we may need to release information to another person or organisation involved in that claim. This includes, but is not restricted to, your broker, your legal representative, others involved in the incident, their insurer, their solicitor, or representative and medical teams, authorised repairers, the police, or other investigators. We may have to investigate your current claim and your claim and conviction history. This may involve external claims handlers, loss adjusters, legal and other expert advisers. We might also share your information with survey organisations to obtain feedback on the service we provide to you.

Under the conditions of your policy, you must tell us about any incident (such as an accident or theft) which may or may not result in a claim. When you tell us about an incident, we will pass information relating to it to centrally managed claims registers which are operated on behalf of the insurance industry.

Call Recording

You should note that some telephone calls may be recorded or monitored, either by us, for example calls to or from our claims department, customer services team, and underwriting department, or on our behalf by our third-party suppliers. Call recording and monitoring may be conducted for the following purposes:

• training and quality control.
• as evidence of conversations; and/or
• for the prevention or detection of crime (e.g., fraudulent claims).
• Enhance broker/commercial relationships (including meeting attendance).

Preventing or detecting fraud and other criminal offences

We may check your information against a range of registers and databases to make sure it is complete and accurate. We may also use publicly available information, including social media, where necessary to verify claims and help prevent, detect, or investigate fraud.

Your information may be shared with organisations such as law enforcement agencies, legal advisers, investigators, public bodies, and other relevant organisations for these purposes.

If we identify inaccurate information or suspect fraud, we will take appropriate action. Where fraud is confirmed, information may be shared with fraud prevention agencies, including industry databases such as the Claims and Underwriting Exchange (CUE), the Motor Insurance Anti‑Fraud and Theft Register (MIAFTR) and the Insurance Fraud Register (IFR

Law enforcement agencies may access and use this information.

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

• Checking details on applications for credit and credit related or other facilities.
• Managing credit and credit related accounts or facilities.
• Recovering debt.
• Checking details on proposals and claims for all types of insurance.
• Checking details of job applicants and employees.

Details of the registers, databases, and fraud prevention agencies we use may be requested from the Starr ERS Syndicate Holdings Limited, 30 Fenchurch Street, London EC3M 3BD.

Cheat line.

To protect our policyholders, we are members of the Insurance Fraud Bureau (IFB). If you suspect insurance fraud is being committed, you can call them on their confidential cheat line on 0800 422 0421.

Consent and the Legal Basis for Processing Your Personal Information

Most of the personal information you provide is needed so we can assess your request for insurance, enter into an insurance contract with you, and administer that contract. We process this information because it is necessary to take steps at your request before entering into a contract and to perform our contract with you.

Some personal information is also processed for fraud prevention purposes. This processing is carried out where it is necessary to comply with our legal obligations and where it is necessary for our legitimate interests and those of the wider insurance market in preventing and detecting fraud, as described above.

If we need your consent to use any specific information, we will make that clear at the time we collect the information from you. You are free to withhold your consent or withdraw it at any time, but if you do so it may impact upon our ability to provide insurance or pay claims.

Further details about the legal basis for our processing of personal information, and the disclosures we may make, can be found in the Appendix below.

Suppliers

Like most organisations, ERS uses a variety of companies to provide services on our behalf. We enter contracts with those service providers to make sure they protect your personal information using appropriate security measures and we prohibit them from using your personal data other than as instructed by us.

Below is a list of service providers and other third parties that have access to personal information to help service policies and subsequent claims:

Third Parties	Reason
Brokers	Brokers are the interface between ERS and policyholders. They provide information to ERS about policyholders, named drivers and other relevant individuals and we may share information with them about quotations, policies, and any claims. Some of our brokers are in Jersey, Guernsey, and/or Isle of Man.
Suppliers who monitor broker performance	Any supplier or third-party relationship linked to brokers’ performance. This includes suppliers involved in monitoring brokers, attending broker meetings and / or capturing audit information related to brokers e.g. Relata.
Insurance Software Houses	Software houses operate a trading platform which brokers can use to obtain quotations and insurance premiums for policies underwritten by insurers such as ERS.
Fraud Organisations	We share data with fraud organisations to meet our regulatory requirements and to protect ERS, our policyholders and claimants. This includes various providers used to support pricing decisions.
Claims Investigators	Where additional information is required in relation to a reported or alleged incident, we may instruct claims investigators to conduct additional services such as interviews, reports and evidence review to validate the information presented. They need access to personal details to conduct a thorough investigation.
Out of Hours Suppliers	These are contracted parties to manage claims notification and indemnity enquiries outside of the ERS normal operating hours. They may have remote access to ERS Policy and Claims systems.
Claims Suppliers (Repairers, Engineers, Salvage Agents, Loss Adjusters, etc.)	These providers service claims as outlined in the insurance policy. The third party will need access to personal details to allow the claim to be reviewed and concluded.
Motor Insurance Bureau (MIB)	Motor Insurers have a regulatory requirement to submit some personal information about policyholders to the Motor Insurance Database (MID).
Administrative Support	ERS employs third party suppliers to manage inbound and outbound correspondence (i.e., scanning, referencing post, cheque processing, printing, and postal services) and other administrative tasks.
Document Management	Document storage, tape storage, document destruction.
Professional Advisers	Legal advisers, accountants, auditors, project managers and other professional advisers.
IT and Related Providers	Software licenses/subscriptions, outsourced infrastructure support, ERS insurance systems, payment platform providers, telephony infrastructure and recordings.
Facilities	Cleaning and security services.
Reinsurance Brokers	Reinsurance Brokers are the interface between ERS and reinsurers. We may share information with them regarding ERS’ policy summary data and large losses specifically when dealing with reinsurance claims.
Reinsurers	Reinsurers provide reinsurance cover to ERS to protect against material losses. This practice of spreading risk is standard practice in the insurance market. They are provided with information regarding ERS’ policy summary data only and large losses specifically when dealing with reinsurance claims.

International Transfers

Some of the organisations we work with, including service providers, are based outside the UK. Some service providers are based in the USA. As a result, your personal information may be processed outside the UK and the European Economic Area. We take sharing of data seriously and, in all cases, we make sure your information is properly protected.

If you travel outside the UK, it may also be necessary to transfer your information to or from other countries in order to administer your insurance or handle claims. For example, this may be required to provide recovery, or repatriation services if your vehicle breaks down or you are involved in an accident abroad.

Whenever we transfer personal information outside the United Kingdom, we ensure that appropriate safeguards are in place to protect it. This includes transferring information to countries that are recognised as providing an adequate level of protection, or using approved contractual safeguards, such as standard contractual clauses, or other recognised mechanisms that provide equivalent protection.

Other Uses and Disclosures

In addition to the disclosures described elsewhere in this privacy policy, we may also disclose your personal information in the following circumstances: (i) if required by law; (ii) in connection with a reorganisation, sale or transfer of all or any part of our business; (iii) if we believe that the disclosure is necessary to enforce or apply the terms of our contracts or otherwise to exercise or defend our rights; (iv) in order to comply with a judicial proceeding, court order or other legal obligation, or a regulatory or government inquiry.

We may also use your personal information if you take part in our marketing promotions, to administer the promotion and to deliver any prizes. This will cover any personal information obtained via your broker. In addition, we may use your personal information to send you marketing (see Your Rights below).

Data Security

We have appropriate security measures in place to protect your personal information. These measures are designed to prevent your information from being lost, misused, accessed without permission, altered, or disclosed.

Access to your personal information is limited to employees, agents, contractors and other third parties who need it for business purposes. They are only permitted to use your information in line with our instructions and are subject to strict confidentiality obligations.

We also have procedures in place to manage any suspected data security incidents. Where required by law, we will notify you and the relevant regulator if a personal data breach occurs.

Retention

We will keep your personal information only for as long as it is needed for the purposes for which it was collected. This includes retaining information while there is a possibility that you or we may need to bring or respond to a legal claim relating to your insurance, or where we are required to keep it to meet legal or regulatory obligations.

Different types of information are kept for different periods, depending on the nature of the insurance, any claims made, and our legal requirements. For example, information relating to a child may need to be kept for longer periods, for example where legal time limits apply. If you would like more information about how long we keep your information, you can contact us using the details set out below.

We may keep information in an anonymised form for longer periods so that it can be used for analysis, research, and modelling purposes.

Your Rights

Under data protection laws, you have a number of rights in relation to your personal information. These include the right to:

• Access your information – to ask for a copy of the personal information we hold about you (subject to certain legal exemptions).
• Correct your information – to have inaccurate information corrected or incomplete information updated.
• Have your information erased – to ask us to delete your personal information in certain circumstances.
• Restrict how we use your information – to ask us to limit how your personal information is used in certain situations.
• Object to how we use your information – to object to processing carried out on the basis of our legitimate interests, including profiling, in certain circumstances.
• Data portability – to ask for your personal information to be provided to you, or another organisation, in a structured, commonly used and machine‑readable format, where applicable.
• Withdraw consent – where we rely on your consent to process personal information, you have the right to withdraw that consent at any time.
• Be informed about automated decisions – to receive information about, and in some cases challenge, decisions made using automated processing that affect your insurance or premiums.
• Make a complaint – to raise concerns with us or to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator.

We may ask for proof of your identity before we can respond to your request.

Children’s rights are usually exercised on their behalf by a person with parental responsibility unless the child is able to exercise those rights themselves.

We may use your contact details to send you marketing communications about our own products and services where permitted by law. This may include marketing sent to existing customers under the “soft opt‑in” rules, where you have previously taken out insurance with us or asked about our products.

You will always have the right to opt out of receiving marketing at any time. You can do this by using the unsubscribe link included in our marketing messages or by contacting us using the details set out below.

If you wish to exercise any of your rights, please contact us at:

Data Protection Officer ERS
30 Fenchurch Street
London
EC3M 3BD

dpo@iquw.com

If you are not satisfied with our use of your personal data or our response to any request by you to exercise your rights in relation to your personal data, please contact compliance@iquw.com

You also have a right to make a complaint to the Information Commissioner:

Information Commissioner’s Office
Wycliffe House
Water Lane Wilmslow Cheshire
SK9 5AF

0303 123 1113

icocasework@ico.org.uk

Appendix
Legal Basis for Processing Personal Information

PURPOSE	Categories of data	Legal grounds	Disclosures
QUOTATION/INCEPTION Setting you up as a client, including fraud, credit and anti-money laundering and sanctions checks	Personal data: Individual details Identification details Financial information	Personal data: Performance of our contract with you Compliance with a legal obligation Legitimate interests (to ensure that the client is within our acceptable risk profile)	Group companies providing administration. Credit reference agencies. Anti-fraud databases
	Special categories of personal data: Credit and anti-fraud data	Special categories of personal data: In the substantial public interest Consent
QUOTATION/INCEPTION Evaluating the risks to be covered & matching to appropriate policy/premium	Personal data: Individual details Identification Policy information	Personal data: Perform contract. Legitimate interests (to determine the risk profile and appropriate insurance product and premium)
	Special categories of personal data: Risk Details Previous claims Credit and anti-fraud data	Special categories of personal data: Consent
QUOTATION/INCEPTION and POLICY ADMINISTRATION Collection or refunding of Premium	Individual details Financial information	Perform contract. Legitimate interests (to recover debts due to us)	Banks
MARKETING	Personal data: Individual details Identification details marketing preferences (opt in/opt out) Technical data	Consent Legitimate interests (to administer promotions and deliver prizes)	Group companies providing administration. Third parties in respect of other insurance products e.g. Relata Social media companies marketing on our behalf
POLICY ADMINISTRATION General client care, including communicating with you regarding administration and requested changes to the insurance policy. Sending you updates regarding your insurance policy.	Personal data: Individual details Policy information Special categories of personal data: Risk Details Previous claims Current claims	Personal data: Perform contract Legitimate interests (to correspond with clients, beneficiaries, and claimants to facilitate placing of and claims under insurance policies) Special categories of personal data: Consent

PURPOSE	Categories of data	Legal grounds	Disclosures
CLAIMS PROCESSING Managing insurance claims including fraud, credit and anti-money laundering and sanctions checks	Personal data: Individual details Identification details Financial information Policy information	Personal data: Perform contract Legitimate interests (to assess the veracity and quantum of claims)	Claims handlers. Solicitors Loss adjustors Experts Third parties involved in the claim
CLAIMS PROCESSING Managing insurance claims including fraud, credit and anti-money laundering and sanctions checks CLAIMS PROCESSING Defending or prosecuting legal claims	Special categories of personal data: Credit and anti-fraud data. Risk Details Previous claims Current claims	Special categories of personal data: Consent Legal claims	Claims handlers. Solicitors Loss adjustors Experts Third parties involved in the claim Claims handlers. Solicitors Loss adjustors Experts Third parties involved in the claim
	Personal data: Individual details Identification details Financial information Policy information	Personal data: Perform contract Legitimate interests (to defend or make claims)
CLAIMS PROCESSING Defending or prosecuting legal claims CLAIMS PROCESSING Investigating & prosecuting fraud	Special categories of personal data: Credit and anti-fraud data. Risk Details Previous claims Current claims	Special categories of personal data: Consent Legal Claims	Claims handlers. Solicitors Loss adjustors Experts Third parties involved in the claim Solicitors Private Investigators Police Experts Third parties involved in the investigation or prosecution. Other insurers Anti-fraud databases
	Personal data: Individual details Identification details Financial information Policy information	Personal data: Perform contract Legitimate interests (to assist with the prevention and detection of fraud)
CLAIMS PROCESSING Investigating & prosecuting fraud	Special categories of personal data: Health data Criminal records data Other sensitive data Credit and anti-fraud data. Risk Details Previous claims Current claims	Special categories of personal data: Consent Legal claims Substantial Public Interest	Solicitors Private Investigators Police Experts Third parties involved in the investigation or prosecution. Other insurers Anti-fraud databases
RENEWALS Contacting you to renew the insurance policy	Personal data: Individual details Policy information Special categories of personal data: Risk Details Previous claims Current claims	Personal data: Perform contract Legitimate interests (to correspond with clients, beneficiaries, and claimants to facilitate the placing of and claims under insurance policies) Special Categories of personal data: Consent

PURPOSE	Categories of data	Legal grounds	Disclosures
THROUGHOUT THE INSURANCE LIFECYCLE Transferring books of business, company sales and reorganisations	Personal data: Individual details Identification details Financial information Policy information	Personal data: Legitimate interests (to structure our business appropriately) Legal obligation	Courts Purchaser
THROUGHOUT THE INSURANCE LIFECYCLE Transferring books of business, company sales and reorganisations THROUGHOUT THE INSURANCE LIFECYCLE General risk modelling & underwriting	Special categories of personal data: Credit and anti-fraud data. Risk Details Previous claims Current claims	Special categories of personal data: Consent Substantial Public Interest	Courts Purchaser
	Personal data: Individual details Identification details Financial information Policy information	Personal data: Legitimate interests (to build risk models that allow accepting of risk with appropriate premiums)
THROUGHOUT THE INSURANCE LIFECYCLE General risk modelling & underwriting REINSURANCE managing reinsurance claims	Special categories of personal data: Credit and anti-fraud data. Risk Details Previous claims Current claims	Special categories of personal data: Consent Substantial public interest	Reinsurance brokers, reinsurers, and advisers.
	Personal data: Individual details Identification details Policy information	Personal data: Legitimate interests (to ensure we have appropriate insurance in place from reinsurers and to make claims under the reinsurance policies)
REINSURANCE managing reinsurance claims	Special categories of personal data: Medical data	Special categories of personal data: Substantial public interest (use of the data is necessary for insurance purposes) Legal Claims	Reinsurance brokers, reinsurers, and advisers.

PURPOSE	Categories of data	Legal grounds	Disclosures
THROUGHOUT THE INSURANCE LIFECYCLE: Complying with our legal or regulatory obligations.	Personal data: Individual details, Identification details, Financial information, Policy information. Special categories of personal data: Credit and anti-fraud Data, Risk Details, Previous claims, Current claims.	Personal data: Legal obligation Special categories of personal data: Consent, Substantial Public Interest.	PRA, FCA, ICO and other regulators, Police, Other insurers (under court order).

ERS Privacy Notice March 2026