AA Ireland Data Protection Statement
This document is the full AA Ireland Data Protection Statement and contains all the information you need, to understand how we use your personal data. A summary of this statement can be found on our Terms of Business booklet by clicking the Terms of Business link on the AA home page.
"AA" means the AA group of companies including AA Ireland Limited. A list of the companies within the AA Group can be obtained from The Secretary, AA Ireland Ltd, 61a South William Street, Dublin 2.
AA recognises that protecting personal information is important to you and we are committed to protecting your privacy. This statement sets out how we will use and protect your information and how you can exercise your data protection rights.
It is important that you read this Data Protection Statement and that you show it to anyone else who is named on your insurance policy or AA Membership as it also applies to them. It is important that they have agreed to their personal information being provided to us.
We reserve our right to change this Data Protection Statement from time to time at our discretion. The most up to date version can be found on aa.ie. We encourage you to periodically review this statement to ensure you are informed about how we use and protect your personal data.
All personal data we gather will be processed in accordance with all applicable data protection laws and principles.
Queries & Complaints
If you wish to raise a complaint on how we have handled your personal data, please contact our Data Protection Officer by email, firstname.lastname@example.org or in writing to AA Ireland 20-21 South William Street, Dublin 2. Alternatively you can lodge a complaint with the Office of the Data Protection Commissioner, Canal House, Station Road, Portarlington, Co Laois, R32 AP23
We will take all appropriate steps to keep your personal data safe. In the unlikely event of a security breach we will notify you promptly about the circumstances of the incident.
2. How we collect your information
The personal data we require about you and other people named on your policy or Membership will be gathered and stored in line with this Data Protection Statement. This will be done by AA staff or, where you use them, the AA website or app.
In order to gather the personal data we need to provide you with a policy or Membership we will obtain personal information directly from you or anybody else named on your policy or Membership. When gathering personal data for policies of insurance, we may request details about you or anybody else named on your policy regarding medical conditions and/or information relating to the alleged commission of, commission of or conviction for any relevant offence(s) by you or anybody to be named on your policy.
We may ask you to provide medical information as part of the insurance sales process, including GP letters. Please do not send us the results of any genetic tests carried out on your or any person named on your policy.
By supplying an eircode and/or address of a property when taking out an insurance policy, AA will carry out a search of a third party database to determine address based risk factors (called geocoding). This will return information relating to the area where your property is located as part of the insurance quotation process and will be used to assist insurers in rating, when providing you with a quotation.
It is important that you give us correct information. If you provide us with inaccurate, incorrect or incomplete information for insurance policies, this may result in your insurer avoiding the contract of insurance refusing claims. This may result in you finding it difficult to arrange insurance in the future. For AA Membership, this may result in us cancelling your cover, or not providing you with service.
3. How we use information you provide us
We use the information we receive from you or which we obtain from our dealings with you as an AA customer (including in relation to products and/or services we provide to you and/or your use of those products and/or services) to provide quotes, products and/or services that you request, to communicate with you, and to personalise information provided to you. We ask for your home, mobile telephone number, and email address to enable us to contact you in relation to an enquiry you have made, to communicate with you about your quotation or product, to contact you if there is a problem with your order, or if there is another genuine reason for doing so. An example of how we may personalise information include using your information to generate an insurance quote for you.
We may use the personal data we gather for any or all of the following purposes –
|Purpose ||Legal Basis
|To verify you or your authorised representative’s identify in any interactions with AA whether in person, online, by telephone or through the AA app ||Processing is necessary for compliance with legal obligations
|To verify the accuracy of the information provided to us ||Processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract
|To provide you with a quote for insurance and/or Membership, and insurance cover and/or AA Membership if you buy the cover ||Processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract
|To manage and administer any products or services you have obtained with us ||Processing is necessary for the performance of a contract
Processing is necessary for compliance with legal obligations
|To make and receive payments in relation to your policy and/or AA Membership ||Processing is necessary for the performance of a contract
Processing is necessary for compliance with legal obligations
|To manage and investigate complaints ||Processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract
Processing is necessary for compliance with a legal obligation
|For statistical analyses, market research, customer satisfaction surveys and data analytics including profiling ||Processing is necessary for the purposes of our legitimate interests. This is for the improvement of AA’s processes, products and services
|To store and make back-ups of your data for disaster recovery purposes ||Processing is necessary for compliance with a legal obligation
|To comply with laws and regulations ||Processing is necessary for compliance with a legal obligation
|To detect and prevent fraud and other offences and to assist An Garda Siochana with investigations ||Processing is necessary for the purposes of our legitimate interests. This is to investigate and prevent potential fraudulent or other illegal activity
|To inform you of other AA products or services that may be interest to you, unless you have informed us otherwise ||The data subject has given consent to the processing of his or her personal data for one or more specific purposes. The sending of marketing material is only done where you have provided us with your consent.
|Processing is necessary for the purposes of our legitimate interests. AA’s legitimate interest is to determine how to communicate the most appropriate message to you
Staff training, performance management and disciplinary action ||Processing is necessary for the performance of a contract
Processing is necessary for compliance with a legal obligation
Sometimes we may need sensitive personal data such as past medical history. When this is required we will process this by obtaining your explicit consent first. Where we process personal data relating to criminal convictions we will do so for the assessment of risk to provide you with an insurance quotation.
Effect of not providing information
If you do not provide the information that is required for an insurance or Membership quote, we may not be able to offer you a quote. Some categories of information are required for us to administer the products you hold with us and we would not be able to offer you a contract without this information.
Calls, both inbound and outbound, may be recorded and monitored for training and quality purposes, to verify information, prevention of fraud, to manage complaints and to improve customer satisfaction.
4. Sharing your information
We may share your details with third parties, including your representatives and our representatives. The categories and types of third parties we may share your details with are outlined below. As the exact list of third parties may change, the below is a non-exhaustive list and is indicative of the companies/individuals whom we share data with.
|Your representatives ||This is any party you have given us permission to speak with such as a relative, other people insured under your policy and/or your legal representative
|Our representatives ||Our employees, agents and contractors. This includes companies that provide services in relation to telecommunications, postage, document providers, payment providers, hosting/storage providers, IT, IT security, debt collection agencies, customer research partners and data storage providers.
|Other third parties |
Insurance companies to enable us to provide you with an insurance quotation and the ongoing administration of your policy.
External advisors such as solicitors, accountants and auditors.
Other third parties to fulfil your specific orders for a product or information in circumstances that third parties deliver the requested or relevant service. Examples of this are –
- Cartell.ie who process the Car History Service on behalf of AA Ireland.
- Car Hire companies if availing of this benefit under your Membership cover
- Kent Carty Solicitors, if you avail of the legal service provided by the Legal Expenses policy.
Law enforcement agencies such as An Garda Siochana.
Debt collection agencies in relation to outstanding monies owed to AA.
AA, as Data Controller, will use every effort to protect your personal data and we will not sell your information to any third parties.
On occasions some of your personal information may be sent to, or accessed by, other parties outside of the European Economic Area (EEA). This is done in compliance with the appropriate legal and technical safeguards including strict contractual obligations.
The non-European Economic Area countries to which we currently send personal data include Canada and the United States of America.
If you would like more information about the relevant safeguards involved in the transfer of personal data please contact us, using the contact details in Section 1.
5. Collection of Data
To provide you with the product or service you have requested, we need to collect many categories of personal data for the purposes set out in this statement.
The exact categories may change, however we have set out the types of information that we gather and use. The category headings and types of data collected noted below are not exhaustive; these are indicative of the data we may hold about you. The information listed under one heading may be used relating to activities that are noted under another heading. Data may be gathered in relation to both you and other people who are named on your insurance or Membership.
|Category ||Type of Data Collected
|Insurance policy information – General Insurance ||Name, address, date of birth, contact information, employment details, gender, residency years in Ireland or the UK, call recordings, previous insurance policy numbers and renewal dates, payment details (bank and/or payment card details), Membership breakdown record (if an AA Member), policy information including car/property details, claims history including details of relevant claims, criminal convictions, disqualifications and penalty points.
|Insurance policy information – Life Insurance ||Name, address, date of birth, contact information, employment details, gender, call recordings, previous insurance policy numbers and renewal dates, payment details (bank and/or payment card details), policy information including your medical history, claims history including details of relevant claims.
|Membership information ||Name, address, date of birth, contact information, gender, call recordings, your location (if you use the AA app), payment details (bank and/or payment card details)
6. Retention of Data
Quote information may be retained by us for up to 15 months from the date of the quotation. All policy information will be held for 6 years following the end of the policy or relationship with you to ensure we meet our regulatory requirements. We will retain call recordings for 6 years from the date of the call.
In some cases, we may need to keep personal data for a longer timeframe than specified above. Examples of this include long-running disputes and system back-ups (required for disaster recovery purposes).
7. Automated decision making
As part of the provision of your insurance contract, including at quotation stage, AA Ireland may use profiling. This means that we may use your personal data to evaluate, analyse or predict the performance of your contract of insurance. The results of this profiling may be a factor in fees or charges set by AA Ireland. This has no factor on the price of your insurance premium as this is determined by the insurer.
8. Your rights
As a data subject, you have the rights which are detailed below. Certain restrictions may apply in some cases. Please send your request in writing, either by email or post, using the addresses noted in Section 1 above.
It may take us up to 30 days to process your request. If we need extra time to process your request, we will notify you of this, and the reasons for the delay within 30 days of receiving your request. If we have reason to refuse your request, we will notify you of this within 30 days of receiving your request, and the reasons for the refusal. If this happens, you are entitled to complain to the Office of the Data Protection Commissioner.
|Your Right ||Details
|Right to withdraw consent|| If we are processing your information on the legal basis of consent, you can withdraw your consent at any time. If you withdraw your consent, we are not permitted to use your personal data for that activity going forward.
We do not rely on consent for processing your personal data in relation to insurance or Membership contracts. We rely on the basis that the processing is required for the purpose of entering into, and the performance of, a contract with you. Details of legal bases are in Section 3 above.
|Right of access ||You have the right to get details about the personal data we hold about you, and why and how we process that data. You also have the right to get a copy of the personal data we hold (data access request).
Please provide as much information as possible when making a request, including your name, address, reference number and details of the information that you want access to.
|Right of rectification ||You have the right to require the AA to correct any incorrect or inaccurate information that we hold about you.
|Right to be forgotten ||You have the right to have the personal data about you erased, in certain circumstances. You may request the deletion of your data in the follow circumstances –
• The personal data is no longer necessary for the purposes for which it was originally collected and processed
• If you withdraw consent, and there is no other legal basis for processing the data (for example, if you withdraw your marketing consent and hold no active products or services with the AA)
• If the data subject objects to the processing, and there are no legitimate grounds for the processing of the data
• If the personal data has been unlawfully processed
• If the personal data must be deleted for compliance with a legal obligation
The right to be forgotten does not apply in certain circumstances, including where the processing of the data is necessary for a reason, such as the performance of your contract with the AA.
We will keep a record of your request so that we know your data has been deleted and why.
|Right not to be subject to Automated Individual Decision-making, including Profiling ||You have a right not to be subject to decisions based solely on automated processing. In certain circumstances, we are entitled to use automated decision making and profiling. These relate to situations where the decision is necessary for entering into a contract, or for performing that contract.
|Right to Data Portability ||You have the right to receive the personal data you provided to us, in a commonly used, machine readable format. You may also request that the AA send this to another data controller, where technically feasible. This right applies to personal data that we process on the legal basis of consent or for the purpose of entering into a contract, and where this processing is carried out on a computer (automated means).
If exercising this right to transfer data from another company, please note the contents of this Statement to ensure that you do not provide us with excessive data. We will not be responsible for the quality or accuracy of the data transferred to us. We will review all received data and delete information that is inappropriate, excessive, incorrect or not required.
|Right to Object ||You have the right to request us to stop processing your personal data. When making this request, please outline why you want us to stop processing your personal data. We will review your request and stop processing your personal data unless we can demonstrate legitimate grounds for the processing that override your interests and rights.
|Right to Restrict the Processing of your Personal Data ||You have the right to restrict the processing of your personal data in the following circumstances – |
- Where you believe the personal data is not accurate. This restriction will be for a period to allow us to verify the accuracy of your personal data.
- Where the processing of the personal data is unlawful and you request this to be restricted, rather than erased
- Where we no longer need your personal data for the purposes of processing but you require it for the establishment and exercise of a legal claim
When processing is restricted, your personal data will only be processed with your consent or for the establishment and exercise of a legal claim. If your policy or product is current then it may need to be cancelled. If you are near the end of a policy or product term, we may not be able to process your data in order to issue you with a renewal notice.
9. Contact with our Customers
We may contact you from time to time in relation to your dealings with AA Ireland. This will relate to the purposes noted in this Data Protection Statement and may include (but not limited to) –
- Administration of your insurance policy/AA Membership
- Discussion of your insurance/Membership renewal
- Discussion of quotes already provided to you
- Handling complaints
- Marketing products and services, where you have given us consent to such contact
- Conducting market research
As part of the quotation process (point c above), we may contact you shortly after you get a quote to discuss the quote, the premium, level of cover and help you with any questions that you may have. We will not make calls before 9am or after 9pm Monday – Saturday, or at any time on a Sunday or a bank holiday.
All calls are recorded and may be monitored for the purposes of training, quality purposes and to verify information and help prevent and detect fraud.
Where you have consented to receive marketing information from us, we may contact you from time to time about other AA products that we think may be of interest to you. To do this we contact you by post, email, telephone and text message using the contact information you have given us.
If you have opted to receive marketing messages from us and you decide you no longer want to receive them you can change your preferences by –
- Emailing email@example.com or firstname.lastname@example.org
- Calling us on 01 617 9950 and the AA agent will update your preferences
- Writing to us at Compliance, AA Ireland, 20-21 South William Street, Dublin 2
11. Access to myAA
Access to myAA is based on the understanding that this service is provided to allow registered users to get and retrieve quotes, view and administer their insurance policies and products held through AA Ireland. Users must agree to the Terms and Conditions of use prior to registering with myAA. AA Ireland may terminate access to myAA at its own discretion. Inappropriate use of myAA will result in access to myAA being revoked. By agreeing to receive documentation via myAA, the user is agreeing to receive documentation online.
12. The AA Ireland App
By downloading the AA App you agree, and provide your consent, to the use of your data as set out below (subject to the preferences you indicated when registering for the AA App).
We will respect your right to privacy and treat all of the personal information you give to us as confidential when you register to download the AA App. This includes your name, address, email address, telephone contact number(s), gender, date of birth, vehicle details, information you provide us through myAA, when you contact us for help, and payment details.
We may collect technical information in relation to your usage. This may include type of mobile device and operating system you use, a device identifier, IP address, IDFA, identity of your network operator, current location data (if you have enabled this for the AA App) and sessions (when you have the AA App open in either the foreground or background) which we may use to generate statistical usage data relating to the AA App.
We may use your information to:
- Provide live traffic and travel updates
- Inform you of new products, offers or services
- Provide rescue services
- Understand your interests based on in-app behaviours to improve our products and services Provide you with vehicle reminders
The AA does not sell, trade or rent your information. We will only share your information with third parties if we have your consent to do so or when they are providing a service for us. For example, a third party developer or an analytics company. Such third parties will only use that information in accordance with our instructions and not for their own purposes. Only aggregated, anonymised data is periodically transmitted to external services to help us improve the AA App and our service.
When you use the AA App we may invite you to share content via email or via a social network. If you choose to share content then please be aware that the privacy and cookies policies of such third party sites govern the information you submit to them and we encourage you to read them.
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What are cookies?
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Rest assured that the cookies we use do not store personal details, such as payment card numbers.
Here are the main types of cookies and what they do:
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Targeting or advertising cookies In brief: These cookies collect anonymous information about your browsing habits which are then used to make advertising relevant to you. They remember if you have visited a website and share this information with advertisers.
For example, for remarketing purposes, we use DoubleClick Cookies. These cookies are provided by our online advertising agency. They help us tailor the advertisements you see on third party sites by understanding what interests you on our sites, such as the pages you view. We don’t combine this information with other personal information you provide with us. These cookies expire 30 days from when you last click on the advertisement. We limit advertising to certain sections of the website. These services are provided by our carefully selected and monitored partners, and we are committed to ensuring any information is used appropriately.
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How you can control cookies
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Tell us what you think
The AA welcome your questions and comments about privacy. Please write to The Secretary, AA Ireland Ltd, 20-21 South William Street, Dublin 2.