Compare the Market Information Sharing

IamNotAllowedToUseMyName

rudekid48 wrote: »

Ok, I think I see where you're coming from now. So you think that the insurer should only get your information when you press BUY on compare the market?

the problem is though, that to be able to give you a price so that you can press buy, the insurer has to get your details first. whenever you get a quote on a comparison site, there will probably be over 100 insurers & brokers that have your details on their systems.

My point is that there is a difference between a back end enquiry where they obviously need all your data to get a quote and storing that information for uses other than you intended.

While the risk is obvious, I do wonder whether it goes beyond what the Data Protection Act would envisage - there is a difference between provide your data to get a quote and allowing them to store this data for other purposes. The T&Cs only suggest that you are providing the Data for of a quote and there is nothing that suggests that you have consented to have tour data retained for other purposes.

I'll drop an email to the ICO and see what they think.

AdrianC

IanMSpencer wrote: »

My point is that there is a difference between a back end enquiry where they obviously need all your data to get a quote and storing that information

Is there? Why?

for uses other than you intended.

...The T&Cs only suggest that you are providing the Data for of a quote and there is nothing that suggests that you have consented to have tour data retained for other purposes.

Try reading the Ts & Cs...
http://www.admiral.com/your-privacy-and-security/

And, yes, the comparison site do state in THEIR Ts & Cs that your data is being provided to the insurers, and they will deal with it subject to their Ts & Cs.

IamNotAllowedToUseMyName

AdrianC wrote: »

Try reading the Ts & Cs...
http://www.admiral.com/your-privacy-and-security/

And, yes, the comparison site do state in THEIR Ts & Cs that your data is being provided to the insurers, and they will deal with it subject to their Ts & Cs.

Now that is a classic MSE response where somehow the consumer is supposed to be omniscient and as individuals we are supposed to just put up with things as they are.

On CtM you apply for a quote and consent to your data being provided to how many hundred insurers? In what way is it reasonable that the user of CtM reads or consents to the terms of the partner companies. It would be a classic unreasonable clause, but also you are misrepresenting the T&Cs.

There are two main points:

8. Sensitive personal data

In order to provide you with a quote we may need to collect personal data which the Data Protection Act 1998 defines as sensitive, such as medical history or criminal convictions. By proceeding with obtaining a quote you will signify your explicit consent to such information being processed by ourselves and our product or service providers for the purposes stated above.

My bold - the purposes above are all about things that I need to be done, or that they need to happen for the purposes of providing the quote or special offers.

11.3 If you decide to purchase or make further queries about a product or service through this website you will be directed to the product or service provider's website and the information you have provided may be passed to such providers to allow them to deal with your request. Those product or service providers will be subject to their own terms and conditions and each product or service provider may have a different privacy policy from ours.

Note the implication that if you are not interested in further information or do not decide to purchase then the information is not subject to their T&Cs

In this case I had not investigated Admiral so under the CtM terms, I should not have expected Admiral staff to have personal access to my quotation information (as opposed to an anonymous back end computer system).

It is exactly this sort of wandering around of personal data that the DPA was created.

AdrianC

IanMSpencer wrote: »

Now that is a classic MSE response where somehow the consumer is supposed to be omniscient and as individuals we are supposed to just put up with things as they are.

Not at all. If you don't like those Ts & Cs, it's easy. Don't use a comparison site.

On CtM you apply for a quote and consent to your data being provided to how many hundred insurers?

An absolute oodle. That's kinda their whole point.

but also you are misrepresenting the T&Cs.

Your denial is not my misrepresentation.

In this case I had not investigated Admiral so under the CtM terms, I should not have expected Admiral staff to have personal access to my quotation information (as opposed to an anonymous back end computer system).

Unless you think that Admiral are going to give their weighted actuarial data to a third party, then of COURSE Admiral's back-end computer system is going to be receiving your quotation information. It's unrealistic in the extreme to expect an insurer to place some kind of Chinese Wall between their quotation and live systems - not least because if you ring up directly to purchase the policy, or with a query about it, they will need to have access to that quote.

Next thing, you'll be acting all surprised that a multiplicity of different insurance brands are all the same actual insurer, and share information between themselves.

Don't be surprised if you walk into an independent high street broker and they do exactly the same as the comparison engine, either, feeding your details into a range of insurer quote engines.

IamNotAllowedToUseMyName

AdrianC wrote: »

Not at all. If you don't like those Ts & Cs, it's easy. Don't use a comparison site.

I don't believe I have a problem with CtM's Ts & Cs. There is nothing stated there that seems unreasonable.

Actually, companies are expected to have Chinese Walls. When you are dealing with personal data, a company is only expected to use it in the ways that they have been expressly given permission. CtM I consented to data for the express purpose of obtaining quotation for CtM, I did not consent to my data being used for any other purpose. How long, for example, do I expect Admiral to retain that data? Without explicitly seeking to avail myself of their offer, arguably there is no expectation that they need to retain that data at all once it has been processed, the oodles of providers should dispose of this data immediately until such time I return with a firm request.

AdrianC

IanMSpencer wrote: »

I don't believe I have a problem with CtM's Ts & Cs. There is nothing stated there that seems unreasonable.

Oh, my apologies. I thought you were objecting to them passing your quote details to insurers to deal with according to their own Ts & Cs and privacy policies - which, in the case of Admiral (and, undoubtedly, others) allow them to retain the data and use it for pretty much whatever internal processing they wish.

IamNotAllowedToUseMyName

AdrianC wrote: »

Oh, my apologies. I thought you were objecting to them passing your quote details to insurers to deal with according to their own Ts & Cs and privacy policies - which, in the case of Admiral (and, undoubtedly, others) allow them to retain the data and use it for pretty much whatever internal processing they wish.

Already covered. The Ts & Cs do not grant that except where you investigate or proceed with the offer.

Anyway, I'll see what Admiral and CtM come back with and update here.

AdrianC

IanMSpencer wrote: »

Already covered. The Ts & Cs do not grant that except where you investigate or proceed with the offer.

Just because they explicitly say that, doesn't mean that they don't apply to quote-generation as well...

http://www.comparethemarket.com/information/privacy-policy/

4. Provision of services and disclosure of data

We will use the information provided to us by you to search the websites of our partners in order to obtain the best quotes available to you.

We may use third parties to process personal information on our behalf. Where third parties process your personal information on our behalf, we will ensure that they have the necessary high standards of security in place so that your data is kept secure and only used in accordance with this Privacy Policy.

8. Sensitive personal data

In order to provide you with a quote we may need to collect personal data which the Data Protection Act 1998 defines as sensitive, such as medical history or criminal convictions. By proceeding with obtaining a quote you will signify your explicit consent to such information being processed by ourselves and our product or service providers for the purposes stated above.