Privacy Notice

Introduction

This notice explains when and why we collect your Personal Data, how we use it, how we keep it secure and your rights in relation to it. “Personal Data” is any information which identifies a person (the “Data Subject” or “you”).

The Data Protection Act 2018 (DPA), the Privacy and Electronic Communications Regulations (PECR) and the General Data Protection Regulation (GDPR) protect Data Subjects’ rights. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the secure movement of personal data. Further details can be found at the website for the Information Commissioner.


Who we are

We are The Veterinary Defence Society Limited (VDS), a mutual insurance company incorporated in England and Wales. We provide professional indemnity insurance. Our members are veterinary surgeons, Registered Veterinary Nurses (RVNs) and veterinary practices in the United Kingdom and the Republic of Ireland. We provide insurance against claims arising from allegations of professional negligence and the costs of criminal and/or disciplinary proceedings.

We are authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority (Firm Reference number 202598) and the Prudential Regulation Authority in the United Kingdom and are regulated by the Central Bank of Ireland (Firm Reference number C38444) for conduct of business rules. We are registered as a Data Controller with the Information Commissioner under registration number Z6856064.

Our registered office is 4 Haig Court, Parkgate Industrial Estate, Knutsford, Cheshire, WA16 8XZ under company number 2159441.

We have a wholly owned subsidiary, VDS Training Services Limited (“VDS Training”) which develops and delivers non-clinical risk mitigation training for vets, RVNs and other members of the veterinary profession. Its registered office is at the same address as the VDS and it is registered in England and Wales under company number 10727838.

For the purposes of the Data Protection Act 2018, the VDS is the “Data Controller” and “Data Processor” of your Personal Data. Unless otherwise indicated, references in this notice to the VDS, ‘we’ or ‘us’ include VDS Training.


What Personal Data we collect

We need your Personal Data to create and service insurance policies and to deliver the range of services we offer. We collect and process Personal Data that relates to our members, the employees that work in veterinary practices alongside our members, our members’ authorised agents, customers of VDS Training, third party claimants/complainants and others involved with claims, potential claims, criminal and disciplinary proceedings and criminal or disciplinary investigations. The Personal Data we collect may include:

  • individual details such as name, address, proof of address, contact details (including emails and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title, employment history, qualifications and family details (including their relationship to you)
  • registration/identification numbers issued by the RCVS and VCI or by government bodies, agencies or similar (e.g. national insurance, passport, tax identification or driving licence numbers)
  • financial information such as bank account or payment card details, income or transaction histories
  • risk information such as the type of veterinary work you undertake, the amount of time you spend on veterinary work and whether this is on a full time or part time basis
  • insurance policy information including information about quotes you receive and policies you take out, and/or product and services you have purchased from us
  • credit and anti-fraud data including credit history, credit score, sanctions and criminal offences, and information received from various anti-fraud databases relating to you
  • information about previous and current claims (including in connection with other related or unrelated insurance) which may include data about your health, criminal convictions, or special categories of personal data and, in some cases, surveillance reports
  • technical information including your computer’s IP address
  • special categories of personal data which have additional protection under the GDPR, namely health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation.


Where we collect Personal Data from

We collect Personal Data from:

  • you, including from forms and surveys that you complete, from your correspondence and phone calls with us (which may be recorded) and details of your visits to our website
  • the nominated individual at your practice who applies for insurance coverage and completes the proposal form on behalf of the practice, vets and/or RVNs to be insured
  • anyone who acts as your agent in connection with the products and services we provide
  • our website, social media pages and other software applications we make available for use via computers and mobile devices
  • other sources such as public registers, anti-fraud databases, sanctions lists, court judgments, third party websites or our business partners or subcontractors
  • in the event of a claim, circumstances that may give rise to a claim, or criminal or disciplinary investigations or proceedings, third parties including any other parties involved in the claim, witnesses, experts, adjusters, lawyers, claims handlers, translators and others.


Cookies

Cookies are strings of information stored on a visitor’s computer which the visitor’s browser then provides to our website each time the visitor returns. Our website uses cookies to identify site visitors and collect information about their behaviour on the site. Website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our website.


Why we collect and process your Personal Data

Your Personal Data may be collected and processed for a number of reasons:

  • providing a quote, setting up, administering and renewing insurance policies (which may include fraud, sanctions, credit and anti-money laundering checks and client care communications)
  • dealing with claims, making payments, defending legal claims or regulatory proceedings, investigating and prosecuting fraud
  • providing risk mitigation advice and training
  • risk modelling
  • researching your opinions and exploring new ways to meet your needs
  • assessing and developing our products, systems, prices and brand
  • administration of our products and services
  • fulfilling legal or regulatory obligations
  • if you are a member, sending you membership information
  • sending you newsletters and marketing communications which we believe may be of interest to you (see Lawful Basis for processing Personal Data, below)
  • monitoring the use of our websites
  • maintaining records of your use of the products and services provided by the VDS and VDS Training
  • transferring books of business, company sales, restructuring and reorganisation.


Lawful Basis for processing Personal Data

We only collect, store and use Personal Data when we have a ‘lawful basis’ to do so under the GDPR. We process Personal Data on the following bases:

  • Administration and operation of our contracts and services for example, in providing you with insurance, handling claims and/or fulfilling orders for goods or services;
  • ‘Legitimate interest’ where we have identified a legitimate interest for which processing your data is necessary and which balances your interests, rights and freedoms, including:
    - protecting against fraud
    - administration and services to our members including the transmission of Personal Data between the VDS and VDS Training, maintaining databases of our members and their choices and preferences, providing members benefits, and enabling the provision to members of risk mitigation information
    - direct marketing and keeping you informed by newsletter, post or email about the benefits of membership; our events and activities; VDS Training courses; and products, services and offers from us, VDS Training and/or carefully selected third parties which may interest you or where the VDS/VDS Training can access particular benefits on your behalf (see Consent below)
    - providing, improving, developing and promoting the products and services we offer
    - personalising, modifying, enhancing or otherwise improving our products or services for you
    -internal research and analysis of data, e.g. to understand patterns, trends and behaviours; target and improve risk mitigation training; identify what information about risk mitigation or products and services would be of interest to you; determine the effectiveness of promotional campaigns and advertising (including profiling and/or interrogating our membership database to ensure we communicate with you effectively and efficiently)
    - where there is a claim or potential claim under one of our insurance products, we may process the Personal Data of claimants, potential claimants, complainants, their representatives and/or individuals involved in criminal or disciplinary investigations or proceedings without informing the data subject because this is necessary in connection with legal proceedings and/or prospective legal proceedings and/or for establishing, exercising or defending legal rights.
  • Legal obligation including undertaking due diligence and reporting, for instance where we have a legal obligation to investigate members, or potential members/insureds to check for involvement in fraud, undertake sanctions screening or make money laundering checks and/or to report to a competent authority
  • Consent. We will ask your consent for us and VDS Training to send you marketing communications, newsletters and/or information about new products and services by email, text message (SMS) or telephone (electronic communications). We will also ask for your consent to allow carefully selected third parties to contact you with relevant products and services. You can set your preferences in respect of electronic communications, or amend them at any time, on our website at www.thevds.co.uk. We and any third parties will only send you electronic direct marketing communications if you have given us your explicit consent, and only via the channels you have agreed. We may also send marketing communications and/or newsletters to VDS members by post. If you would prefer not to receive marketing communications by post, please contact our Data Protection Officer using the contact details below and we will remove you from the mailing list.
  • Necessary to protect vital interests. This will usually only apply in "life‑or-death" scenarios. We may disclose your information to the police or other authorities if we have serious concerns about your wellbeing.


Retention Policy

We process Personal Data for the duration of any contractual relationship we have with you (which may be longer than the policy period). After the contractual relationship ends we will store Personal Data for as long as is necessary for the purpose(s) for which it was collected. In particular, we must do so as long as there is any possibility that either you or we may bring or face legal claims in connection with a contract of insurance or other services, or if there are legal or regulatory reasons to retain Personal Data.


Data Security

We apply appropriate technical and organisational measures to encrypt and protect email traffic. If your email service does not support encryption, however, any emails we send or receive may not be protected. We use strict procedures and security features to protect communications and Personal Data from unauthorised access. Data is held in the United Kingdom using secure servers, in printed form and in secure off-site storage facilities. VDS do not transfer personal data outside the European Economic Area.


Sharing Personal Data

We may share Personal Data with the following entities:

  • other insurance and distribution parties including reinsurers, reinsurance brokers, financial institutions and other business partners or suppliers such as accountants, actuaries, lawyers and other professional advisers
  • data processors involved in providing our products and services to you such as printing companies
  • government or other public authorities such as HMRC, law enforcement and other regulators.
  • VDS Training and other carefully selected third parties such as veterinary membership organisations.


Your rights

If you have any questions about our use of your Personal Data, please contact our Data Protection Officer using the contact details below. You should be aware that you may have the right to require us to:

  • provide you with further details about the use we make of your Personal Data
  • provide you with a copy of the Personal Data we hold
  • correct any inaccuracies in the Personal Data we hold
  • delete any Personal Data we no longer have any lawful ground to use
  • where the processing requires your consent, to withdraw that consent so we stop the processing in question
  • transfer your Personal Data to another organisation
  • object to any processing based on the legitimate interests grounds set out above unless our reasons for that processing outweigh any prejudice to your data protection rights
  • object to automated processing, including profiling (which forms a limited part of our underwriting process) and request human intervention
  • restrict how we process or use your Personal Data in certain circumstances e.g. whilst a complaint is being investigated.

In certain circumstances we may need to restrict the above rights to safeguard the public interest (e.g. prevention or detection of crime) or our interests (e.g. legal or litigation privilege). If you are not satisfied with our use of your Personal Data or our response to any request by you to exercise any of your rights, or if you think we have breached the Data Protection Act 2018, you have the right to complain to the ICO, details below.

  • England
    Information Commissioner’s Office
    Wycliffe House
    Water Lane
    Wilmslow
    Cheshire
    SK9 5AF
    Tel: 0303 123 1113 (local rate)
    01625 545 745 (national rate)
    Email: casework@ico.org.uk
  • Scotland
    Information Commissioner’s Office
    45 Melville Street
    Edinburgh
    EH3 7HL
    Tel: 0303 123 1115
    Email: scotland@ico.org.uk
  • Wales
    Information Commissioner’s Office
    2nd Floor
    Churchill House
    Churchill Way
    Cardiff
    CF10 2HH
    Tel: 01625 545297
    Email: wales@ico.org.uk
  • Northern Ireland
    Information Commissioner’s Office
    3rd Floor
    14 Cromac Place
    Belfast
    BT7 2JB
    Tel: 0303 123 1114 (local rate)
    02890 278757 (national rate)
    Email: ni@ico.org.uk

Data subjects in the Republic of Ireland may have the right to complain to

The Data Protection Commission,

Canal House,

Station Road,

Portarlington,

Co. Laois,

R32 AP23,

Ireland.

Tel: +353 (0) 761 104 800.

Email:info@dataprotection.ie.


Changes to our Privacy Notice

This notice is kept under review and updated as required.


Data Protection Officer Contact Information

  • Data Protection Officer
    The Veterinary Defence Society Limited
    4 Haig Court, Parkgate Industrial Estate
    Knutsford
    Cheshire
    WA16 8XZ
    Email: privacy@thevds.co.uk
    Tel: +44 (0) 1565 652737