How do we use your personal information?

We mainly use your personal information to provide you with an insurance policy, healthcare trust benefits and other services that you, your employer, or other family members obtain from us and to provide you with the right services based on your situation. So, for example, if you have a problem, we make sure the right network of providers and specialists are in place and we can also update you quickly on the progress and cost of your claim and keep you safe from fraud. However, there are a number of other reasons why we use your personal information; please see below for a more detailed list of how we use your personal information. 

We may process your personal information for a number of different purposes, and these are set out in more detail in the below sub-sections for AXA Insurance and AXA Health where applicable. Under data protection laws we can only process your information where we have one or more legal ground or condition for doing so as set out in the law. We have set out below the main reasons why we process your personal information and the applicable circumstances when we will do so.

When the personal information we process about you is classed as sensitive personal information (criminal offences information and ‘Special Category Personal Data’ such as your health, sexual orientation and ethnic origin), we must have an additional legal condition for such processing, including the substantial public interest condition for the insurance industry or, where necessary, we will ask for your consent.

The substantial public interest condition for insurance is contained in the UK Data Protection Act 2018 and allows for processing special category personal data (including health data) and criminal conviction data which is necessary for an insurance purpose. This includes advising on, arranging, underwriting, administering, administering a claim under, exercising a right or complying with an obligation under, an insurance contract.

  • Processing of personal and sensitive personal information is necessary in order for us to provide your insurance policy, benefits or other services, such as assessing your application and setting you up as a policyholder, or trust beneficiary, administering and managing your insurance policy or benefits, providing all related services, providing a quote, handling and paying claims and communicating with you. In these circumstances, if you do not provide such information, we may not be able to offer you a policy, service or process a claim.
  • We may use Cloud (technology) storage solutions within the United Kingdom and Europe which are chosen to ensure efficiency and improved performance through up-to-date technology. In some instances, we may consider similar technology outside these areas or technical support provided may be from outside. In all cases where personal data is transferred to a country which is deemed not to have the same standards of protection for personal data as the UK, AXA will ensure appropriate safeguards such as UK regulator approved Standard Contractual Clauses and further contractual, organisational and technical measures (as may be required following an assessment of the risk) have been implemented to ensure that your personal information is protected.
  • Where we have a legal or regulatory obligation to use personal information, for example, when our regulators, the Prudential Regulatory Authority, (PRA), the Financial Conduct Authority (FCA) and our data protection regulator, the Information Commissioners Office (ICO) wish us to maintain certain records of any dealings with you.
  • Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claim or where we want to pursue any legal claims ourselves.
  • Where we need to use personal and sensitive information for reasons of public interest, such as investigating fraudulent policyholder applications or claims, including large scale/organised fraudulent claims, medical malpractice and anti-money laundering checks.
  • Where you have provided your consent to our use of your personal information. We will usually only ask for your consent in relation to processing your sensitive personal information (such as health data) or when we would like to provide marketing information to you (including information about other products and services). We do not always need your consent to process your sensitive personal information, but where we do we will make this clear when you provide your personal information. Without your consent, in some circumstances, we may not be able to provide you with cover under a policy or handle a claim, or you may not be able to benefit from some of our services.
  • Where we have appropriate legitimate business needs to use your personal information such as maintaining our business records, developing and improving our products and services, all whilst ensuring that such business need does not interfere with your rights and freedoms and does not cause you any unnecessary harm.
  • When required, we anonymise personal information so that individuals cannot be identified, before we use it for management information and analysis of our products and services. Analysis of anonymous information provides us with insights about our business, and with opportunities to improve our products and services and the health and wellbeing of the people who use them. Analysis of anonymous information also allows us to demonstrate the value of the services we provide to our clients. The way that we anonymise personal information aligns with regulatory guidance and is achieved using different techniques, for example removing identifying data or overwriting it with randomised non-identifiable data. Anonymisation still constitutes use of your personal information and so to do so lawfully, we rely on the legal ground that was used when your data was originally collected.
  • Where we need to use your sensitive personal information such as health data because it is necessary for your vital interests, this being a life or death matter.

Legal grounds we rely on for each use of your personal information

Detail section