Privacy Notice for FR Scheme 2018
Who are we?
Flood Re Limited is an organisation set up to administer the Flood Re Scheme (“FR Scheme”). The FR Scheme is a UK wide Government and insurance industry initiative under the Water Act 2014 set up to help provide affordable home insurance to households at the highest risk of flooding. In addition to running the FR Scheme, Flood Re must also manage the market’s transition to risk reflective flood insurance pricing during the lifetime of the FR Scheme. We operate within the boundaries and according to the obligations and rules set out in law, including The Flood Reinsurance (Scheme Funding and Administration) Regulations 2015, the Scheme Document and The Flood Reinsurance (Scheme and Scheme Administrator Designation) Regulations 2015.
In order for us to carry out our role, as specified in the legislation described above, we may collect and use certain personal information about you. When doing so, we must use and process personal details in compliance with data protection laws including the General Data Protection Regulation (GDPR). This notice is to provide you with more information about us and our use of your personal details.
What personal data is collected?
To administer the FR Scheme, we may collect or be provided with personal information about you. The personal data we collect focuses on your household property and its insurance in respect of flood risks. We work with insurance providers across the UK which offer and provide such insurance 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 we require to manage the FR Scheme. Lastly, we sometimes receive questions about the FR Scheme from householders, such as yourself, and you may provide us with personal information about you through those communications. 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);
- 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 might be provided with 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. Furthermore, 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 also learn 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;
- For direct queries, we may receive personal details such as your name, address, email address and other information directly from This may be the case if you write to us with questions about the FR Scheme or a particular policy reinsured by the FR Scheme. We will always provide you with information on how we may use your personal data within our response to your query at the time; and
- 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 misuse 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
Protecting your data
Normally, the personal details we use for the FR Scheme, as described above, 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, we do not typically hold sufficient details to identify you individually and would not try to do so.
Wherever possible, we also try to use depersonalised or anonymised or aggregated data.
On what lawful basis do we process your personal data?
The personal data that we gather is necessary to manage and run the FR Scheme and deliver on its purpose of facilitating the availability and affordability of flood insurance and managing the transition to risk reflective pricing. The lawful basis on which we are able to process your personal information is detailed in Article 6(1)(e) of the GDPR which says:
“processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”
We are able to process your personal data using this basis as Flood Re administers the FR Scheme in the public interest and is named in legislation as the FR Scheme administrator.
Why do we need your personal data 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 by law, as the FR Scheme administrator. 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 the cost of the part of your home insurance premium connected to flood risk. 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. In addition we may need anonymised or statistical versions of your data to help us evaluate the success of the FR Scheme over the course of its 25 year lifespan
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 providerand 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 and FCA regulated); for good governance (including being audited as required by law); for reporting to and working with Governments across the UK (especially with DEFRA, 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;
- 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; and
- To anonymise or depersonalise the personal details to create data helpful in evaluating the successes and achievements of the FR
We work with numerous service providers, contractors and professional advisers to help us to manage the FR Scheme and your details may be shared with them for the same purposes set out above.
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.
How long will we keep your personal data?
Your personal information may be required for the duration of the FR Scheme and may therefore be kept until the FR Scheme is terminated. Unless terminated prematurely, the FR Scheme is scheduled to run until 2039.
Who to contact for more information or help?
You have the right to review your personal data (a” Subject Access Request”), have certain inaccurate information about you corrected and/or object to Flood Re’s processing of your personal data on the grounds of your particular situation. If you wish to do so; or notify us of a change in your details; or obtain more information about our use of your details, please write to us at:
Flood Re Limited, 75 King William Street, London, EC4N 7BE
or, email our service desk at email@example.com
marking your correspondence for the attention of our General Counsel, who also acts as our Data Protection Officer.