Professional Secrecy

Scottish Widows Europe

Last updated: December 2024

Scottish Widows Europe may outsource certain services, activities or tasks to external providers (which may or may not be (a) regulated or (b) located in the Grand-Duchy of Luxembourg) (the “Service Providers”).

Data provided by you or your broker to Scottish Widows Europe (which may directly or indirectly identify you, a beneficiary under the policy or your authorised representative) may be communicated to Service Providers during the course of such outsourcing.

In order to comply with our professional secrecy obligations, we are providing you with further information about:

  • The types of services we may outsource to Service Providers
  • The types of information transmitted to those Service Providers
  • The countries in which the Service Providers are located


1. Type of services outsourced

We use the following categories of Service Providers such as:

  • Providers of insurance policy administration service.
  • Other insurers, reinsurers, insurance and reinsurance brokers, other intermediaries and agents, appointed representatives, distributors and financial institutions, and other business partners.
  • External third party service providers, such as medical and security professionals, accountants, actuaries, auditors, experts, lawyers and other professional advisors, medical assistance providers, IT systems, support and hosting service providers, printing, human resources, and data analysis service providers, banks and financial institutions that service our accounts, third party claim administrators; document and records management providers, and other third party vendors and outsourced service providers that assist us in carrying out business activities.
  • Intragroup service providers such as IT applications hosting and support providers, providers of salvage, subrogation, deductibles & overpayments recovery, and marketing.
  • Payees, emergency providers (police).


2. Type of information transmitted

Any data which you or your broker has provided to Scottish Widows Europe, may be transmitted to one of our Service Providers. This includes data which may directly or indirectly identify you (the policyholder), the insured parties, a beneficiary under the policy or an authorised representative (including present and past employees, directors and officers, if any) of the policyholder. Please see examples of such information listed in the table below.

Type of information Examples
Contact information Name, address, email and telephone number.
General information Gender, marital and family status, date and place of birth, and physical characteristics (appropriate to the circumstances) or company’s registered address, number and date of incorporation, activities and shareholders.
Education and employment information Educational background, employer or employee details, employment history.
Insurance and claim information Policy and claim numbers, relationship to policyholder, insured, claimant or other relevant individual, injury, disability or death, and other information relevant to insurance policy issuance, and claim assessment and settlement.
Government and other official identification numbers Social security or national insurance number, passport number, tax identification number, driver’s licence number, or other government issued identification number.
Financial information and account details Bank account number, or other financial account number and account details, assets, income, and other financial information, account log-in information and passwords for accessing insurance policy, claim and other accounts.
Medical condition and health status Health data that we may have collected from you on your application form.
Other sensitive information
  • Information about religious beliefs.
  • We may obtain information about criminal records or civil litigation history (for example, for preventing, detecting and investigating fraud).
  • Information provided voluntarily to us (for example, preferences expressed regarding medical treatment based on religious beliefs) (where collected in accordance with applicable law).
Photographs and video recordings Images (including photographs and pictures) or video recordings created in connection with our insurance or other business activities, including for claims assessment, administration and settlement, claim disputes, or for other relevant purposes as permitted by law.
Information to detect, investigate or prevent crime, including fraud and money laundering Insurers commonly collect, hold and share information about their previous dealings with policyholders and claimants with the intention of detection, investigation and prevention of fraud, money laundering and other criminal activities.
Information enabling us to provide products and services Age categories of individuals to be insured, details of the risks to be insured, prior accident or loss history, and cause of loss, status as company officer or director, or partner, or other ownership or management interest in an organisation, history of disputes, civil or criminal proceedings or formal investigations involving you, the insureds and the company and information about other insurance held.
Online activity information We will receive data about you, the insureds and the company when you use the Scottish Widows Europe portal (in the future) and other Personal Information that you provide to us online.

3. Countries where the Service Providers are located

Luxembourg, Germany, Austria, UK, Italy, Netherlands, USA (exclusively for US citizen)*.

For more information on how we transfer your personal data please refer to the “Sending data outside the EEA” section of our Data Protection Notice available at:

https://www.scottishwidowseurope.com/en/dataprotection.asp

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