Sedgwick’s caring counts® commitment is to value the right of privacy of the companies and individuals we serve. It is Sedgwick’s policy to comply with all applicable privacy and data protection laws and maintain the trust of those we serve.
We want to share with you our policy to what personal information we may collect, how we may use this information and other important areas relating to your privacy and data protection. Please find below links to the policies that apply to all internet sites and applications of Sedgwick and its groups of companies.
Introduction and scope
Sedgwick, its subsidiaries and affinities (“Sedgwick,” “we,” “us,” “our,”) take your privacy seriously.
This Privacy Notice describes the types of Personal Data that we obtain through the Sites and Services (each as defined below), how we may use that Personal Data, with whom we may share it, and how you may exercise your rights regarding our processing. The Notice describes the measures we take to safeguard the Personal Data that we obtain and how you can contact us about our privacy practices. We conclude by describing further specific rights that may be available in your jurisdiction.
“Personal Data” is information that identifies you or other individuals (such as your dependents). This Privacy Notice describes how we will handle Personal Data that we collect through:
- Our websites and other software applications made available through computers and mobile devices (the “Sites”) and
- Claims handling, loss adjusting, or similar processes such as claim forms, telephone calls, e-mails and other communications with us, as well as from claim investigators, medical professionals, witnesses or other third parties involved in our business dealings with you (the “Services”).
Personal information we obtain
General identification and contact information
- Your name, address, e-mail and telephone details, gender, marital status, family status, date and place of birth, educational background, physical attributes, activity records, driving records, photos and video images, employment history, skills and experience, professional licenses and affiliations, relationship to the policyholder, insured or claimant, and date and cause of death, injury or disability.
- Identification numbers issued by government bodies or agencies – Social Security or national insurance number, passport number, tax identification number, military identification number, national resident number, or driver’s or another license number.
Financial information and account details
- Bank account number and account details, credit history and credit score.
Medical condition and health status
- In certain cases, we may receive information about your current or former physical or mental or medical condition, health status, injury or disability information, medical procedures performed, personal habits (for example, smoking or consumption of alcohol), prescription information and medical history.
Other potentially sensitive information
- In certain cases, we may receive sensitive information about your trade union membership, religious beliefs, political opinions, family medical history or genetic information (for example, if you apply for insurance through a third-party marketing partner that is a trade, religious or political organization). In addition, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud.
- We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).
- Recordings of telephone calls to our staff and offices.
- Information to investigate crime, including fraud and money laundering: For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.
Information enabling us to provide our services
- Location and identification of property insured (for example, property address, vehicle license plate or identification number);
- Travel arrangements including reservation numbers, destination and hotel details;
- Policy details and claim numbers, details of policy coverage and cause of loss; and
- Prior accident or loss history, your status as director or partner or other ownership or management interest in an organization and other insurance policies you hold.
Cookies contain small amounts of information which are downloaded to your device when you visit our website. Cookies are sent back to our website to allow us to recognize your device.
We use the following cookies:
- CraftSessionId to maintain sessions across web requests. For GDPR purposes, please note that Craft’s default cookies do not collect any personal or sensitive information. Craft’s default cookies do not collect IP addresses. The information they store is not sent to any 3rd parties.
The default cookies are only used to communicate for the purposes of user authentication, form validation/security, and basic web application operations.
- Google Analytics _gat, _ga These two cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
How we use your personal data
We use the personal data that we collect to:
- Communicate with you and other interested parties to manage your claim.
- Send you important information regarding your claim and other administrative information.
- Make decisions about claim assessment, processing and settlement.
- Manage claim disputes, where applicable.
- Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
- Prevent, detect and investigate crime, including fraud and money laundering, and analyze and manage other commercial risks.
- Conduct satisfaction surveys.
- Use during the normal course of pre-employment contracting during the recruitment process.
- For our legitimate interests while conducting the recruitment process.
- Manage our business operations to comply with internal policies and procedures, including those relating to auditing finance, accounting and billing, IT systems, data and website hosting, business continuity, document and print management.
- Resolve complaints, and handle requests for data access or correction.
- Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and comply with legal process and respond to requests from public and government authorities (including those outside your country of residence).
- Establish and defend legal rights, protect our business operations (including our group companies), our rights, privacy, safety of employees and property, you or others related to the claim and pursue available remedies to limit our damages
We use data during the recruitment and employment process, including:
- to decide whether to employ (or engage) you;
- to decide how much to pay you, and the other terms of your contract with us;
- to check you have the legal right to work for us;
- to determine whether we need to make reasonable adjustments to your workplace or role because of your disability;
- to monitor diversity and equal opportunities;
- to comply with employment law, immigration law, health and safety law, tax law and other laws which affect us;
- the prevention and detection of fraud or other criminal offences; and
- for any other reason which we may notify you of from time to time.
We may process special or sensitive personal data when we are processing it for the following purposes, which we may do:
- where it is necessary for carrying out rights and obligations under law;
- where it is necessary to protect your vital interests or those of another person where you/they are physically or legally incapable of giving consent;
- where you have made the data public;
- where processing is necessary for the establishment, exercise or defense of legal claims; and
- where processing is necessary for the purposes of occupational medicine or for the assessment of your working capacity.
We will only process personal data for the specific purposes set out above or for any other purposes specifically permitted by the data protection legislation. We will notify you of those purposes when we first collect the data or as soon as possible thereafter.
We may, as a matter of law, and without requiring notice or consent, use your information for crime and fraud prevention, or systems administration within Sedgwick and to monitor and/or enforce Sedgwick’s compliance with any regulatory rules and codes.
You may let us know how you want to be contacted (e.g. by email, phone or post).
Legal basis for processing
For personal data to be processed lawfully in most countries, data must be processed on a basis as set forth by applicable law. These include, among other things, the data subject’s consent to the processing, or that the processing is necessary for the performance of a contract with the data subject, for the compliance with a legal obligation to which the data controller is subject, or for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive Personal Data is being processed additional conditions must be met. When processing Personal Data as data controllers in the course of our business, we will ensure that those requirements are met.
Depending on your relationship with us, the legal basis for us processing your Personal Data is one of the following:
- You have given consent to us or the party for whom we are acting
- The processing is necessary for the performance of a contract or legal duty
- Processing is necessary for a legitimate interest pursued by us or a third party. Where processing is based on legitimate interest only, it will be in relation to one of the following:
- Claim handling on behalf of another party
- Establishing, exercise or defense of legal claims
- Prevention, detection of crime
Where we use legitimate interest as our grounds for processing your data you have the right to object at any time.
How we share your personal data
Sedgwick may make personal data available to the following parties for the purposes of claim assessment or as required by law:
Other insurance and distribution parties
- In the course of processing claims, we may make Personal Data available to third parties such as reinsurance brokers, appointed representatives, distributors, financial institutions, securities firms and other business partners.
Our service providers
- External third-party service providers, such as medical professionals, accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; travel and medical assistance providers.
- IT systems, support and hosting service providers, document and records management providers and outsourced service providers that assist us in carrying out business activities.
- Banks and financial institutions that service our accounts, third-party claim administrators, claim investigators, construction consultants, engineers, examiners, jury consultants, translators and similar third-party vendors.
Authorities and third parties involved in court action
- We may share personal data with government or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate:
- to comply with applicable law and regulations, including those outside your country of residence;
- to comply with legal process;
- to respond to requests from public and government authorities including public and government authorities outside your country of residence;
- to protect our operations or those of any of our group companies;
- to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and
- to allow us to pursue available remedies or limit our damages.
Other third parties
- We may share personal data with emergency providers (fire, police and medical emergency services); retailers; medical organizations and providers; travel carriers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business. To check information provided, and to detect and prevent fraudulent claims, personal data (including details of injuries) may be put on registers of claims and shared with other insurers. We may search these registers when dealing with claims to detect, prevent and investigate fraud.
International data transfers
Due to the global nature of our business, for the purposes set forth above we may transfer personal data to parties located in other countries (including the United States and other countries that have a different data protection regime than is found in the country where you are based). For example, we may transfer Personal Data in order to process international travel insurance claims and provide emergency medical assistance services when you are abroad. We may transfer information internationally to our group companies, service providers, business partners and governmental or public authorities in order to perform our services.
We will rely on legally-provided mechanisms to lawfully transfer personal data across borders. In many cases, we will use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the EU. You can find more information about Standard Contractual Clauses here on the European Commission website. These clauses are contractual commitments between companies transferring Personal Data, binding them to protect the privacy and security of the data.
Security of personal data
We will take all appropriate reasonable technical, legal and organizational measures, which are consistent with applicable privacy and data security laws to safeguard your Personal Data. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any personal data you might have with us has been compromised), please immediately notify us.
Where we provide personal data to a vendor, the vendor will be selected carefully and required to use appropriate measures to protect the confidentiality and security of your Personal Data.
Retention of personal data
We will retain Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
Control of your PIN
Your account can be used to view sensitive information for applications where a PIN is required. It is, therefore, important that you keep your PIN private, as you would your banking PIN. If your PIN is compromised, contact Sedgwick immediately.
From time to time we alter our Privacy Notice as we introduce new services or change existing ones. Changes to this notice are effective as soon as they are posted on the Site and a notice has been placed on the login screens of the self-service applications. We from time to time also communicate this change via e-mail. The effective date of this version of the Privacy Notice appears at the top of the notice.
Third party web sites
You from time to time have the option to enter third party web site through the Site, or you from time to time have the option to enter our web site from another third-party web site. Since we cannot be assured that such third-party web site follow our privacy policies, we encourage you to ask questions and review the privacy policies of these third parties. We have no responsibility or liability for the actions or policies of these independent sites, do not endorse any product or service mentioned or offered in such sites, and are not responsible for the content or privacy practices of such sites.
Ours are general purpose and professional websites that do not knowingly collect any information from children under age 18 at any time. We also strive to be fully compliant with the Children’s Online Privacy Protection Act (COPPA). We strongly encourage parents and guardians to regularly monitor and supervise their children’s online activities. If a child under the age of 18 has provided Personally Identifiable Information on one of our web site without the consent of his or her parent or guardian, we ask that a parent or guardian send an e-mail to privacyissues@Sedgwick.com, and we will delete the child’s Personally Identifiable Information from our files.
The list below summarizes our collection, use, and disclosure of personal data. To the extent that there is any conflict between this list and other sections of this Privacy Notice, this list shall prevail.
For these types of personal information collected
- Identifiers (e.g., name, e-mail, postal address, and phone number)
- Demographic information
- Employment information
- Education history
- Sensitive information such as government identifiers
- Financial information and account details
- Geolocation information
- Commercial information (e.g., travel history)
- Photos and videos
- Criminal history
- Telephone recordings
Whose source is: You provide directly to us, such as during the claims process or through a customer satisfaction survey, and from business partners such as insurers.
Collected and used with the purpose of: Manage your claim and related disputes; Make decisions about claim assessment, processing and settlement; Train employees; Prevent fraud; Conduct surveys; Manage our business operations including legal compliance; Resolve complaints; Establish and defend legal rights.
This Information is Disclosed for a Business or Commercial Purpose
Personal information is shared with these categories of Third Parties (which does not include service providers): Partners in our industry such as reinsurance brokers, appointed representatives, distributors, financial institutions, securities firms, and retailers.
Personal information collected via Website Browsing Activity, including web tracking technology such as browser cookies, flash cookies, and web beacons is used for business and commercial purposes of website functionality, customization and security, advertising and marketing. It is provided to Third Party web tracking providers.
CALIFORNIA PRIVACY RIGHTS (effective January 1, 2020)
Data Subject Rights – California Residents
If you do, we will need to collect personal data and other information such as your name, email or transaction history in order to verify your identity. You may also authorize an agent to make a request on your behalf, who will need to provide similar information for verification.
Right to Deletion of Personal Data
California residents have the right to request the deletion of personal data as prescribed in Section 1798.105(a) of the CCPA. Sedgwick may not delete some or all requested personal data as allowed or required by applicable law.
Right of Access: Right to Request Disclosure of Data Collection and Sharing Practices
You may request to receive details about how we collect, use, and share your personal data. Specifically, you may request to receive the specific pieces of personal data that we have collected about you.
You may also request to receive:
- the categories of personal data that we have collected about you,
- the categories of personal data that we have disclosed for a business purpose
- the categories of sources from which we collected the personal data
- our purposes for collecting that personal data, and
- the categories of parties with whom we share your personal data.
Right to Opt-Out of Sale
We do not, and do not intend to, sell your personal data.
Right to not be Discriminated Against for Exercising CCPA Rights
We do not discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above.
Do Not Track
We treat the data of everyone who comes to our site in accordance with this Privacy Notice, regardless their “Do Not Track” setting.
If you have questions about this Privacy Notice or about Sedgwick’s privacy practices, please contact our privacy team via e-mail at firstname.lastname@example.org or by post at 8125 Sedgwick Way, Memphis, TN 38125