Who are we?
We are Flood Re Limited, an organisation set up to administer the FR Scheme, which is a UK wide government and insurance industry initiative under the Water Act 2014, to help provide affordable home insurance to households at the highest risk of flooding. We are the current administrator appointed to run the FR Scheme and to transition the provision of affordable insurance to the insurance industry over the lifetime of the FR Scheme.
In order for us to carry out our role, we may collect and use certain personal information about you. We must use personal details in compliance with data protection laws. This notice is to provide you with more information about us and our use of your details. We also use personal information about other individuals, e.g. our staff, and for different reasons e.g. to operate our website, and additional privacy notices we provide may also be relevant to our use of your personal information.
What personal information is collected?
To administer the FR Scheme, we may collect or be provided with personal information about you. The details focus on your household property and its insurance in respect of flood risks. We work with insurance providers across the UK who offer such insurance to you, who provide such insurance cover to you and who deal with your insurance claims in respect of flood damage. We also work with the VOA in England and Wales, the Scottish Assessors in Scotland and the Land and Property Services in Northern Ireland in order to obtain accurate records about residential housing which is necessary for us to manage the FR Scheme. The personal data which we collect may include the following details:
- For all UK household properties: full address and postcode of the property; and other information about the property such as: when it was constructed; its council tax band; and its unique property reference number(s);
- In addition, for all those properties where the flood risk is passed to us to provide reinsurance cover, we may collect the following from your insurer: specific details about the policy and risk being transferred to us, including, the type of building (e.g. flat or house) and which floor you live on; size and make up of property (e.g. number of bedrooms) and type of construction (e.g. brick building); the type of policy; the start and end date of the policy; the specific buildings sum insured; and the specific contents sum insured;
- For all those reinsured properties which have suffered flooding and where your insurance provider has asked for us to help with the insurance cover and claim, we will also collect information necessary for us to process your insurer’s reinsurance claim, such as: insurance policy reference number and insurance policy claim number; and information about the claim, including, when you made the claim, any payments paid out by your insurer, the date, type, height, cause and severity of the flooding; the amount of the claim and any excess paid and the status of the claim. In addition, we may request from your insurer historic information about your previous claims from your claims files, including any previous incidents of insurance fraud. It is possible that whilst assessing the reinsurance claim, we may collect a limited amount of your sensitive personal data (for example information about your health) if this impacted on your insurance claim. This information would not be routinely provided to us, but rather it may be collected on an exception basis given the value of a claim where a health condition may require that specific alternative accommodation is required to address any health condition, which has caused an unexpected claim or payment value.
To ensure effective and appropriate use of the FR Scheme by the insurance industry, we may collect information from insurance providers relating to other policies insured by them and claims paid out by them but which are not reinsured with Flood Re. We require this information in order to ensure that claims made to and paid out by the FR Scheme align with those in non-flood related circumstances, allowing us to monitor and audit the use of the FR Scheme and to prevent and/or detect any abuse of the FR Scheme. Therefore, we may collect some of the information described above in paragraphs (b) and (c) even if that policy does not contain flood risk or, if it does, where this flood risk was not passed on to the FR Scheme for reinsurance cover.
Normally, the details we use for the FR Scheme will not involve your name, only your property details and unique identifier numbers (which numbers help us and your insurance provider to distinguish your household property with its flood risks and claims, from other such properties, risks and claims). On that basis, normally we may not hold sufficient details to identify you individually and would not try to do so. We also try to use depersonalised or anonymised or aggregated data wherever possible.
If you make a claim on your household insurance in respect of flood damage and your insurance provider asks for our help with that cover and claim, we may then receive details of your name and be able to identify you individually. This may also involve us learning about others involved with the insurance cover, such as your partner living at the property and also named on the policy, or where, following a death, the claim is dealt with by executors of the estate.
Why do we need your personal information and what will it be used for?
Our use of your details is to administer the FR Scheme and to perform the obligations and functions imposed on us as the FR Scheme administrator by law. The personal information which we collect as part of the FR Scheme is required so that we can effectively offer flood reinsurance and settle reinsurance claims; so that we are better able to assess the level of flood risk across the UK by area and property; are able to plan accordingly so that we have sufficient funds and reserves in order to provide reinsurance; and can reduce cost of the part of your insurance premium connected to flood risks when buying household insurance. We also need the information in order to fulfil our obligations to provide information to the insurance industry and the wider public about flood risk and how it may be managed.
Your personal information may be used:
- For catastrophe modelling, so we can map out the various flood risk areas across the UK; and for capital modelling, so we can assess the level of capital which we will require to cover all of the insurance policy flood risks and claims that could be passed to us;
- To assist insurers when considering your insurance application and the relevant flood risk element of the insurance premium; to arrange reinsurance cover for ceded flood risks and to manage any flood risks and insurance claims passed to us, including working with your insurance provider and their service providers to deal with such claims, including identifying and dealing with fraudulent claims;
- As permitted by law e.g. cooperation with law enforcement authorities; for compliance with legal and regulatory obligations and guidance (we are PRA regulated); for good governance (including being audited as required by law); for reporting to and working with Governments across the UK (especially with DEFRA and its equivalents, the UK’s environmental agencies and HM Treasury); and for reporting on the FR Scheme to Parliament;
- For the planned FR Scheme transition to risk reflective pricing over time, or re-organisation or re-designation of the FR Scheme administrator and any related transfers of obligations, functions and records; and
- To anonymise or depersonalise the personal details so that we are able to create aggregated or statistical data and use it for flood related research, analysis and reporting, such as on trends in relation to flood patterns and associated flood risks.
We work with service providers, contractors and professional advisers to help us to manage the FR Scheme and your details may be shared with them.
We do not normally transfer personal information outside of the UK. If we transfer any of your personal data outside of the UK, or outside the European Economic Area, we will take appropriate steps to protect the personal data being transferred, as required by applicable law.
For more information or help?
You have the right to review your personal data and have certain inaccurate information about you corrected. If you wish to do so; or to notify us of a change in your details; or to obtain more information about our use of your details, please contact us.