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PRIVACY NOTICE

This privacy notice explains what information we collect about you, how we use
it and how we protect it. It also gives you information about your rights.

We are committed to protecting and using your personal information responsibly.

If you have any questions about our privacy notice, please email
dataprotection@bupa.com


PRIVACY NOTICE SECTIONS

Who this notice is for



About Bupa



Where we collect your personal information



What personal information we collect



How and why we use your personal information



Sharing your personal information



Who this notice is for



Transferring your personal information abroad



How long we keep your personal information



Cookies, AI, analytics, and profiling



Opting out of marketing



Your rights



How to exercise your rights



Transferring your personal information abroad




WHO THIS NOTICE IS FOR




THIS PRIVACY NOTICE IS FOR:

 * anyone who buys, uses or contacts us about our products and services (such as
   our health or dental insurance customers)
 * residents in our care homes
 * patients of our dental practices, our health clinics or the Cromwell Hospital
 * people who work with Bupa, such as intermediaries or suppliers (but not our
   employees or healthcare professionals)


BUPA BLUA HEALTH APP

We have a different privacy notice for the Bupa Blua Health app, our digital GP
service.


Go to Blua Health privacy notice


BUPA BE.ME

We have a different privacy notice for our health assessment services.


Go to Bupa Be.Me privacy notice


HEALTHCARE PROFESSIONALS

We have a different privacy notice for our healthcare professionals such as our
consultants and clinicians.

If this applies to you, please contact us for a copy.


ABOUT US


WHO WE ARE

We’re a healthcare organisation that offers a wide range of services to support
our customers’ health. When we say ‘Bupa’ in this notice, we mean all our
businesses within Bupa UK, Bupa Global and Bupa Group.

 * Bupa UK means our Care Services, Cromwell Hospital, Dental Practices, Health
   Clinics and UK Insurance businesses. It provides health insurance as well as
   health and dental care, care homes and the Cromwell Hospital services to
   UK-based customers.
 * Bupa Global provides international private medical insurance to customers
   globally.
 * Bupa Group sets policy and standards for Bupa’s businesses globally.


Find out which legal entities make up Bupa UK or find out which entities make up
Bupa Global.


WHO PROCESSES YOUR PERSONAL INFORMATION?

Which business looks after and uses your information as a data controller
depends on which services you’re using or interacting with. A data controller is
the business that looks after your data and decides how it is used.

The information we process, and the reasons why, may vary across our products
and services. We explain any differences in this privacy notice.


HOW WE COLLECT YOUR PERSONAL INFORMATION


FROM YOU

We collect your personal information from you when you get in touch with us:

 * by phone, where we may record or monitor phone calls for quality assurance
   and to make sure we’re keeping to legal rules, codes of practice and internal
   policies
 * by email
 * through our websites, including webchats and virtual assistants
 * through our apps
 * by using our products and services
 * by post
 * by completing an application or other form(s)
 * by entering competitions
 * through social media
 * face to face, for example during treatment


THIRD PARTIES

We also collect information about you from third parties. Find out more about
how we collect and share your personal information with third parties.


WHAT PERSONAL INFORMATION WE COLLECT


BASIC PERSONAL DATA

Name, membership or registration number or patient ID, age and date of birth.


CONTACT

Username, address, email address and phone numbers.


RESIDENCY

The country you live in and national identifiers such as national insurance or
passport number.


COMMUNICATIONS

Details of any contact we’ve had with you, including phone calls and written
complaints.


FINANCIAL DETAILS

Payments and bank account details.


EMPLOYMENT DETAILS

Your role and the company you work for, if your employer pays for your
insurance, scheme or treatment.


CRIMINAL CONVICTIONS AND OFFENCES

Your criminal offences and convictions are collected when carrying out
anti-fraud or anti-money-laundering checks, or other background screening checks
to prevent crime.


BEHAVIORAL AND USAGE INFORMATION

How you use and access our digital services.


TECHNICAL INFORMATION

The devices and technology you use and website browser settings.


SPECIAL CATEGORY INFORMATION

Information about your physical or mental health, including genetic or biometric
information. We may get this information from:

 * application forms
 * notes and reports about your health and any treatment and care you’ve
   received or need
 * notes from calls and other communications you’ve had with us
 * referrals from your existing insurance provider
 * quotes
 * records of medical services and treatment you’ve received


HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Under data protection laws, we can only process your information if we have a
legal reason (known as a ‘lawful ground’) for doing so.

You can find out how we use your personal information, including the lawful
grounds, under data protection laws that we rely on to process your information.
You can find out what the different types of information mean under ‘what
personal information we collect’.

Provide health, dental and aged care
Type of information we process



 * Basic personal details
 * Contact
 * Communications
 * Residency
 * Financial details
 * Employment details
 * Special category information
 * Behavioural and usage information
 * Technical

Our reason for processing



 * It’s necessary to provide the services set out in a contract
 * It’s required or allowed by law
 * We have a legitimate interest to:
   * deliver our products and services
   * tailor the delivery of our products and services to your specific needs and
     interests


For special category information

 * It’s necessary for health or social care purposes such as:
   * preventive or occupational medicine
   * assessing your working capacity as an employee
   * medical diagnosis
   * providing healthcare or treatment
   * providing social care
   * managing healthcare or social care systems or services
 * With your consent (if required)
 * When it’s in your vital interests

Manage and administer health insurance
Type of information we process



 * Basic personal details
 * Contact
 * Communications
 * Residency
 * Financial details
 * Employment details
 * Special category information
 * Behavioural and usage information
 * Technical

Our reason for processing



 * It’s necessary to provide the services set out in a contract
 * It’s required or allowed by law
 * We have a legitimate interest to:
   * manage our relationship with you, our business and third parties
   * deliver our products and services
   * tailor the delivery of our products and services to your specific needs and
     interests
   * communicate with our customers and business partners
   * process insurance claims and collect money owed to us


For special category information

 * It’s necessary for health or social care purposes such as:
   * advising on, arranging, providing or managing an insurance contract
   * dealing with a claim made under an insurance contract
   * relating to rights and responsibilities relating to or in an insurance
     contract or insurance law
 * With your consent (if required)
 * When it’s in your vital interests

Customer relationship, complaints and managing claims
Type of information we process



 * Basic personal details
 * Contact
 * Communications
 * Residency
 * Financial details
 * Employment details
 * Criminal convictions and offences
 * Behavioural and usage information
 * Location

Our reason for processing



 * It’s required or allowed by law
 * We have a legitimate interest to:
   * manage our relationship with you, our business and third parties
   * resolve issues and answer questions about our products and services
   * investigate and respond to complaints
   * monitor how well we are meeting our clinical and non-clinical performance
     expectations
   * protect the public against dishonesty, malpractice or other seriously
     improper behaviour
   * manage a claim where a third party may be at fault
 * With your consent (if required)

­­Detect and prevent fraud, financial crime and breaches of our terms and
policies, and carry out anti-money laundering and other background checks
Type of information we process



 * Basic personal details
 * Contact
 * Communications
 * Residency
 * Financial details
 * Employment details
 * Criminal convictions and offences
 * Behavioural and usage information
 * Technical

Our reason for processing



 * It’s required or allowed by law
 * We have a legitimate interest to:
   * detect and prevent fraud and financial crime
   * ensure compliance with our terms and conditions and policies

Identify and verify you, and monitor access to our products and services
Type of information we process



 * Basic personal details
 * Contact
 * Residency
 * Employment details
 * Behavioural and usage information
 * Technical

Our reason for processing



 * It’s required or allowed by law
 * We have a legitimate interest to:
   * confirm that you’re an employee of your employer when they are paying for
     the product or service you’re using
   * confirm you’re an employee of a business we’re purchasing products or
     services from
   * identify you when you access our digital services and websites
   * identify if you were redirected to our websites through an advert or
     referral link
   * identify if you’re under the age of 16
   * identify fraud and fraudulent activity

Administer payments to and from Bupa
Type of information we process



 * Basic personal details
 * Contact
 * Communications
 * Residency
 * Financial details
 * Employment details

Our reason for processing



 * It’s necessary to provide the services set out in a contract
 * It’s required or allowed by law
 * We have a legitimate interest to:
   * take payment and charge for our products and services
   * review invoices and make payments

Communicate and send marketing information to you by post, phone, email, text
and through social media and to develop and tailor our marketing and sales
activities
Type of information we process



 * Basic personal details
 * Contact
 * Communications
 * Behavioural and usage information
 * Technical

Our reason for processing



 * We have a legitimate interest to:
   * market to our customers and prospective customers if they’ve shown an
     interest in us
   * request feedback from customers and people we work with
   * follow your contact preferences, marketing, cookies and other tracking such
     as in-app, profiling and automated decision making.
   * operate cookies on our websites and undertake other tracking to personalise
     our marketing activities
   * develop and run tailored advertising
 * With your consent (if required)

Improve our products and services by conducting statistical analysis, market
research and other analysis
Type of information we process



 * Basic personal details
 * Contact
 * Communications
 * Residency
 * Financial details
 * Employment details
 * Health information
 * Other sensitive information
 * Behavioural and usage information
 * Technical

Our reason for processing



 * We have a legitimate interest to:
   * undertake statistical research and analytics
   * understand our customers and the people we work with
   * understand more about our products and services, and how to improve them
 * With your consent (if required)

Protect and secure our company, systems, services and business operations.
Compliance with laws and regulations, and to defend ourselves against claims
Type of information we process



 * Basic personal details
 * Contact
 * Residency
 * Behavioural and usage information
 * Technical

Our reason for processing



 * It’s required or allowed by law
 * We have a legitimate interest to:
   * secure our systems and digital services
   * make sure we’re only providing and working with products and services in
     permitted locations
   * exercise our rights and defend ourselves from legal claims

Improve training and the quality of our services
Type of information we process



 * Basic personal details
 * Contact
 * Personal information shared with us during a phone call or other method of
   communication, for example webchat and email

Our reason for processing



 * We have a legitimate interest to:
   * monitor phone calls for training and to review the quality of our services
   * review online and email exchanges between you and us for training and to
     review the quality of our services
 * It’s required or allowed by law


WHEN WE NEED YOUR CONSENT TO PROCESS YOUR PERSONAL INFORMATION

We’ll only ask you for consent to process your personal information if there’s
no other legal reason to process it, or we think it’s appropriate to do so.

WE ALWAYS TELL YOU WHEN WE NEED IT

We’ll tell you when we need your consent and ask you for it. If we can’t provide
a product or service without your consent, we’ll make this clear when we ask for
it. For example, we can’t process health insurance claims without health
information.

YOU CAN ALWAYS CHANGE YOUR MIND

If you later withdraw your consent, we’ll be unable to provide you with any
product or service that relies on us having your consent to process your
personal information.


WHEN WE USE ANONYMISED INFORMATION

Anonymised information is where all names and other information that could
identify you, for example a membership or registration number or IP address, has
been removed. We use it for example:

 * to support clinical research
 * for research and statistical purposes
 * to help us train our people
 * to undertake analytics that help us understand more about our business and
   make decisions. You’ll find more on this in the analytics section of this
   privacy notice.


When we use anonymised information, we will:

 * only share it with legitimate third parties
 * always limit the ways and reasons it is processed
 * never sell it


COLLECTING AND SHARING YOUR PERSONAL INFORMATION

Sometimes we need to collect your information from, or share it with other
people or organisations. When we share your information, we only share the
information needed, and as little of it as possible, for a specific purpose. For
example, if you need treatment, we’ll share relevant medical details with your
treatment provider.

We have processes in place to make sure that your information is protected when
we share it with third parties. If you’re sharing someone else’s personal
information with us, please make sure they’ve seen this privacy notice and are
comfortable with you giving us their information.

We’ve set out below the types of third parties we collect and share information
with, and our reasons for doing so. We may also disclose your personal
information to other third parties if we’re required or permitted to do so by
law.

All our businesses
Bupa group of companies



Description

 * Our affiliated companies, listed at Bupa Legal Notices and Bupa Global Legal
   Notices

What we do

 * We collect information from them
 * We share information with them

Our reasons

 * Deliver our products and services to you
 * Send you communications about products and services that might interest you
 * Undertake statistical research and analysis to understand more about our
   products and services and how to improve them
 * Understand and improve clinical outcomes for our customers
 * Product and service development
 * Fraud prevention and detection
 * Reporting on business activity and success
 * Enabling us to deliver a seamless experience across our businesses, and give
   you easy access to our products and services across our businesses

Your parent or guardian (if you are a child) and authorised third parties



Description

 * You’ve given us consent to speak to a third party on your behalf, for example
   a family member, solicitor or a person acting through a Power of Attorney.

What we do

 * We collect information from them
 * We share information with them

Our reasons

 * Deliver our products and services to you
 * Manage our relationship with you
 * Set you up as a customer
 * Meet our regulatory obligations or comply with legal requests or legal claims
 * Manage complaints, claims or individual rights requests

Your employer



Description



 * You’re under a group insurance scheme or health trust, or they’re paying for
   our services
 * You’re working with us in a professional capacity as a business partner

What we do

 * We collect information from them
 * We share information with them

Our reasons

 * Product or service administration
 * Transfer to a new service provider
 * Set you up as a business partner
 * Manage our relationship with your employer
 * Process and validate invoices, and make or receive payments

Healthcare providers



Description



 * Doctors, clinicians and other healthcare professionals
 * Hospitals and clinics
 * Dental laboratories
 * Medical laboratories
 * Individuals or organisations who pay for your care

What we do

 * We collect information from them
 * We share information with them

Our reasons

 * So you can give or have treatment
 * Process and validate invoices, and make or receive payments
 * To investigate complaints, claims and possible fraudulent activity

Medical regulators, bodies and associations our consultants belong to



Description


Professional associations our consultants belong to or ar regulated by,
including:

 * Care Quality Commission
 * General Medical Council
 * General Dental Council
 * The Health and Care Professions Council
 * Responsible Officer
 * Any others that are relevant to you

What we do

 * We collect information from them
 * We share information with them

Our reasons

 * For safeguarding purposes
 * Investigate complaints and clinical incidents
 * Monitor quality and performance

Credit reference and fraud prevention agencies



Description



 * Health insurance counter-fraud groups
 * Financial crime screening services

What we do

 * We collect information from them
 * We share information with them

Our reasons

 * Detect and prevent fraud
 * Meet our regulatory and legal obligations

Debt collection agencies



Description

 * Debt collection agencies we engage to act on our behalf


What we do

 * We collect information from them
 * We share information with them


Our reasons

 * Recover money owed to us

Third party that buys or takes over any of our businesses



Description

 * Potential buyers or sellers of businesses and assets we’re buying or selling
 * Third parties that assume responsibility for Bupa


What we do

 * We collect information from them
 * We share information with them


Our reasons

 * Enable the third party to take over our business activities
 * Support the third party’s decision making and processes to buy our business

Professional consultants



Description

 * Solicitors, auditors, actuaries and tax advisors
 * Translators and interpreters

What we do

 * We share information with them


Our reasons

 * Support us to manage our business and meet our regulatory obligations
 * Gain advice on business decisions and strategy

Public sector bodies, government and regulatory organisations



Description

 * Government and their agencies
 * Law enforcement agencies, for example the police
 * Authorities and regulators such as the Financial Conduct Authority (FCA) or
   Prudential Regulation Authority (PRA)
 * Data protection supervisory authorities
 * HM Courts and Tribunals Service



What we do

 * We share information with them


Our reasons

 * Comply with our legal and regulatory obligations
 * Protect our rights

Public data sources



Description

 * Electoral register
 * Information about you on social media
 * For our business partners, public sources that include professional
   information about you

What we do

 * We collect information from them


Our reasons

 * Validate and update our records
 * Understand how our customers and business partners have reviewed or discussed
   us or our competitors online

Suppliers who process your personal information on our behalf



Description

We put measures in place to ensure that our suppliers process your personal
information fairly and in line with our expectations. We use the following types
of suppliers:

 * IT service providers: Cloud storage, databases and data repositories,
   practice management systems, customer relationship management systems (CRM),
   communication and phone software, back-up solutions, network security and
   monitoring solutions and other ‘software as a service’ providers
 * Marketing, sales and business development: market and customer research
   consultants, social media platforms and marketing and digital marketing
   agencies, data set and contact list providers 
 * Customer service support: Outsourced support with customer communication and
   servicing, including translation

What we do

 * We share information with them


Our reasons

 * Help us run our business
 * Manage our relationship and communicate with you
 * Provide our products and services to you
 * Understand our customers and market to them
 * Identify and communicate with people that might be interested in our products
   and services

UK Insurance and Bupa Global
Policyholders



Description

 * Main policyholder, if you are a dependant under an insurance policy

What we do

 * We collect information from them
 * We share information with them

Our reasons

 * Manage our relationship with you and the policyholder
 * Issue invoices, requests and take payment

Funders arranging services



Description

 * Insurance brokers
 * Your agents
 * Other intermediaries


What we do

 * We collect information from them
 * We share information with them


Our reasons

 * Confirm you’re entitles to claim discounts on our products and services
 * Manage our relationship with you through your broker or agent
 * Discuss purchase, renewal and availability of our products and services
   through your broker and agent
 * Set you up as a customer or business partner

Other insurers and reinsurers



Description

 * Other health and benefit insurers
 * Reinsurers

What we do

 * We collect information from them
 * We share information with them


Our reasons

 * Set you up as a customer
 * Support you to transfer to a new insurer
 * Manage and settle claims that are a third party’s fault
 * If reinsurance is necessary

Travel assistance services 



Description

 * Evacuation or repatriation providers

What we do

 * We collect information from them
 * We share information with them

Our reasons

 * To arrange evacuation or repatriation

Dental care, clinics, Cromwell Hospital and Care Services
Public sector bodies, government and regulatory organisations 



Description

 * Local authorities and other public sector bodies
 * Commissioners and embassies
 * HM Courts and Tribunals Service


What we do

 * We share information with them


Our reasons

 * Enable the third party to pay for the services we’re providing to you
 * Comply with our legal and regulatory obligations
 * Manage legal claims

Those providing treatment



Description

 * Those providing your treatment such as consultants, clinicians, doctors,
   therapists and other healthcare professionals
 * Hospitals, clinics and other healthcare providers



What we do

 * We collect information from them
 * We share information with them


Our reasons

 * Provide you with your treatment
 * When those providing treatment are involved in legal proceedings, such as for
   negligence or malpractice
 * Manage, investigate and report on negligence or malpractice, and for legal
   claims

National registries



Description


 * Cancer registry

What we do

 * We share information with them


Our reasons

 * Aid monitoring cancer rate
 * Improve cancer care
 * Aid cancer research

National screening database



Description

 * NHS Cervical Screening recall system

What we do

 * We share information with them

Our reasons

 * Make sure the screening is safe and in accordance with national service
   specifications

Health authority and agencies



Description

 * Health Protection Agency for infectious diseases such as tuberculosis and
   meningitis


What we do

 * We share information with them

Our reasons

 * Protect public health

Cromwell Hospital consultants



Description

 * Your consultant will be the data controller for any information they collect,
   use or store outside our systems, or in a way that isn’t in line with our
   instructions (this means they’ll be responsible for how your personal
   information is used)
 * We recommend you speak to your treating consultant if you have any questions
   about how they handle your information



What we do

 * We collect information from them
 * We share information with them


Our reasons

 * So you can have treatment
 * Manage our relationship with consultants
 * Process and validate invoices, and make or receive payments

Dental, occupational health and care providers



Description

 * If you’re referred or you’re transferring from or to a different provider
 * The NHS and your general practitioner (GP)



What we do

 * We collect information from them
 * We share information with them


Our reasons

 * Set you up as a customer
 * Support you to transfer to the new provider
 * Keep records up to date
 * Ensure continuity of care

Our partners



Description

 * Our partners offer support and add-on services, such as patient finance and
   dental subscription plans
 * In some cases, the partner may be the data controller of the personal
   information they hold about you (this means they’ll be responsible for how
   your personal information is used). We’ll confirm this when you choose to use
   the product or service



What we do

 * We collect information from them
 * We share information with them


Our reasons

 * Offer you products and services that may interest you
 * Enable you to purchase or take up offers on additional products and services
   offered by our partners


TRANSFERRING YOUR PERSONAL INFORMATION ABROAD

Sometimes we need to transfer your personal information outside of the UK and
EEA (the EU member states plus Norway, Liechtenstein and Iceland). For example:

 * a supplier based in India administers some of our health insurance policies
 * a Bupa company based in Egypt administers some of Bupa Global’s international
   private health insurance.

Here’s how we keep your personal information safe when we do this:


PROTECTION BY LOCAL LAW

Certain countries are considered safe by regulators since they have adequate
data protection laws. We can freely transfer your personal information where
needed.

The UK government and the European Commission have lists of which countries they
consider to have adequate protection for personal information.


PROTECTION BY OTHER SAFEGUARDS

We can also transfer personal information to countries that have not been
assessed as adequate if we use appropriate safeguards. The main safeguards we
use are:

 * regulator-approved Standard Contractual Clauses
 * additional contractual, organisational, and technical measures (as required
   following a risk assessment of the transfer)


Transfers within the Bupa group are covered by an agreement that contractually
obliges each company to ensure an adequate and consistent level of protection.


HOW LONG WE KEEP YOUR INFORMATION FOR

We keep your personal information in line with set periods:

For UK Insurance and Bupa Global, we typically keep personal information for
seven years after you stop being our customer or business partner (such as
brokers or intermediaries) in line with our legal obligations and business
needs.

For Dental, Clinics, Cromwell and Care Services, we typically keep personal
information for 20 years to comply with the law and NHS guidance.

Some countries have different retention rules due to local laws. If you’d like
to know more about how long we keep your information for, please get in touch.


HOW WE CALCULATE HOW LONG WE KEEP YOUR INFORMATION FOR

How long we keep your information depends on several factors:

 * how long you’ve been a customer with us, the types of products or services
   you have with us, any relevant events and when you’ll stop being our customer
 * how long it’s reasonable to keep records to show we’ve met the obligations we
   have to you and by law
 * any periods set by law or recommended by regulators, professional bodies or
   associations
 * any time limits for making a legal claim
 * any relevant proceedings that apply


We often have to keep your personal information to comply with a legal
obligation, and this means that if you ask us to delete your personal
information before the retention period has expired, we’ll be unable to do so.


COOKIES, AI, ANALYTICS, AND PROFILING

Here you’ll find information on certain technologies we use to process your
personal information:

Cookies and other similar technologies



Analytics



Profiling and automated decision making



AI and ML



Cookies and other similar technologies




COOKIES AND OTHER SIMILAR TECHNOLOGIES


WHAT ARE THESE TECHNOLOGIES?

When you use our websites and apps, we and third-party companies use cookies and
similar technologies such as pixel tags to collect information.

A cookie is a text file containing small amounts of information which a server
may download to your computer, mobile or tablet when you visit a website or use
an app.

A pixel tag (sometimes called a web beacon) is an invisible image with a line of
code placed in an email or on a web page.

For simplicity, we refer to all such technologies as 'cookies'.



HOW DO WE USE THEM?

There are different types of cookies to do different things, for example:

 * letting you navigate between different pages on a website efficiently
 * remembering preferences you’ve given
 * helping us identify ways to improve your overall experience of using our
   websites and apps

Some cookies are used to show you advertising tailored to your interests, or to
count the number of site visits and find out which are the most popular pages.


MANAGING COOKIES AND TRACKING TECHNOLOGIES

You can use our cookies management tool to see and control what cookies we use,
how they are categorised and how long they last.

You can also control, block, or delete cookies through your web browser
settings, usually found under ‘settings’ on your chosen browser.


ANALYTICS

Analytics is a process to analyse data, statistics and other information, either
automatically by a computer or manually by a person.



ANONYMOUS ANALYTICS

As part of our day-to-day business, we produce management information reports.
These are typically aggregated which means the information is grouped together
and not looked at on an individual basis, and often they do not contain personal
information. For example, we produce reports showing business performance split
by day, business area or customer type.






ANALYTICS USING PERSONAL INFORMATION



We sometimes conduct analytics that cannot be performed without personal
information. This type of analytics involves analysing personal information and
other data. The goal is to make recommendations about changes to the business or
improvements to the services we offer our customers.

For example, we may analyse how our customers access our apps so we can
understand how popular they are and identify where we can make improvements.
This will involve us capturing your personal information, such as your member or
registration number or email address used to access the app.

As part of these analyses, we sometimes carry out profiling activities.

For example, if we want to know how many customers may be interested in our
dental practices in a particular area, we will conduct analysis based on
postcode.


PROFILING AND AUTOMATED DECISION MAKING

Like many businesses, we evaluate information about you and use technology to
give you automatic responses and decisions. This is known as profiling and
automated decision making. We use these processes for:

 * business activities, to give you a quicker, more consistent and fair service
 * marketing, to give you information we think will interest you


Business activities

Running our business and delivering our products and services

All our businesses
Improving our products and services



Profiling and automated decision making can help us identify how our products
and services can be improved, as well as how we can achieve better outcomes for
our customers and business partners. For example, we may profile you so we can
give you relevant information and notices within our apps.

Detecting and preventing fraud



We may share some of your information including your name, date of birth, sex
and the country you live in with third party companies who carry out fraud
checks. This will allow us to identify matches and carry out further checks to
detect and prevent fraud.





Even if you aren’t at risk of fraud or suspected of committing fraud, using a
range of people’s information allows us to have a better and more accurate
anti-fraud process.

UK Insurance and Bupa Global
Pre-authorisation



We use technologies that automatically pre-authorise your treatment. This is
more efficient for our customers, business partners and healthcare
professionals. We need to use profiling to create a reliable system and this
involves automatic decision making. We typically make sure an adviser reviews
any problems with treatment approval to guarantee a fair outcome to our
customers. 

Medical underwriting



We use profiling and automated decision making to help us decide what level of
cover we can offer you. We’ll use technology to review your medical information
and find out if you have any previous or existing health conditions which aren’t
covered by your health policy or scheme. 

Pricing



We may use software to help us calculate the price of products and services
based on what we know about you and other customers.

Our software may:

 * analyse your previous claims and compare it with the information we hold to
   find out how likely you are to claim in future
 * use data such as your age, where you live and details about your health, for
   example existing health conditions and whether or not you smoke, to calculate
   prices for products
 * evaluate your payment and previous claims, information you’ve given us about
   yourself, and other information we’ve received from third parties to
   automatically:
    * provide you with a renewal quote
    * decide what incentives we can offer you
    * choose the marketing messages you’ll receive




We use AI and machine learning technologies to do this automatically. The
technology gives us more accurate and tailored information.



We use AI and machine learning technologies to do this automatically. The
technology gives us more accurate and tailored information. You can find more
information about this under AI and machine learning below.

Marketing

Conducting and improving our marketing activities

We use profiling for marketing purposes. This helps us understand what offers,
incentives and information may interest you and other people. We take the
following steps:




1 ‐ WE COLLECT YOUR INFORMATION

We collect information directly from you and through automated means both as
part of your onboarding as a customer or business partner and during our
relationship with you. We also collect information about you from third parties,
such as your employer or insurance brokers.


2 ‐ WE CREATE DATA SETS

We combine your information with other people’s information. This helps us
understand our customers and business partners on a less individual level. We
also segment the information into different categories, for example by type of
customer. This gives us a more accurate picture of the marketing that might
interest you and others.


3 ‐ WE MAKE PREDICTIONS AND GATHER INSIGHTS ABOUT YOU AND OTHERS

Profiling helps us evaluate information about you and others to improve our
marketing activities. We undertake manual profiling, meaning our team will
manually review a set of data and filter it by different categories. For
example, we may predict that our female customers in a given age range will be
interested in a female health initiative, or that if you’re already engaging
with some of our digital products you may be interested in other useful digital
features to improve your experience.

We also use AI and machine learning technologies to run the process
automatically. The technology gives us more accurate information, such as
predicting how likely you are to stop using our products and services. You can
find more information about this under AI and machine learning below.


4 ‐ WE MARKET OUR PRODUCTS AND SERVICES TO YOU AND OTHERS

We share personalised marketing communications by email and phone and within our
apps and other digital services, displaying content that we think will be
relevant to you. We also use the results of this to find other people with
similar traits who might be interested in our products and services.

We use a combination of social media platforms and digital capabilities, such as
customer relationship management tools, to send marketing, show our adverts and
create personalised marketing campaigns using the results of our profiling and
automated decision making.


YOUR RIGHTS ABOUT PROFILING AND AUTOMATED DECISION MAKING

Right to object to profiling related marketing
If you object, we’ll stop these activities.

Right to object to a purely automated decision about you
If you object, a member of our team will manually review the decision that was
made about you.


ARTIFICIAL INTELLIGENCE AND MACHINE LEARNING



What are these technologies?

Artificial intelligence (AI) is where computers are programmed to think and act
like humans This includes doing things such as learning, problem solving and
decision making.

Machine learning is a subset of AI that involves training machines to learn and
improve from experience without being explicitly programmed. This is typically
done by providing large amounts of data to the machine and allowing it to learn
patterns and make predictions based on that data.


HOW DO WE USE AI AND MACHINE LEARNING?

Some of the ways we use AI

 * Customer service. AI and machine learning can be used to improve customer
   service by providing personalised recommendations and assistance. For
   example, chatbots powered by AI can help customers claim or answer questions
   about their policies. This improves response times and our efficiency.
 * Risk assessment and pricing
 * Fraud detection
 * Training our model (the AI algorithm) that creates predictions for marketing
   and business activities


HOW DO WE USE AI AND MACHINE LEARNING RESPONSIBLY?

We are committed to using AI responsibly by following five key principles:

 * privacy and security
 * fairness
 * transparency
 * safety
 * accountability


YOUR CHOICES AND RIGHTS

Information on how to control your personal information and the rights you have
under the law.

Opting-out from marketing



Your rights



How to exercise your rights



Opting-out from marketing




OPTING-OUT FROM MARKETING

You can ask us to stop sending you email marketing by using the ‘unsubscribe’
link in the message we send you.

For all other types of marketing, you can opt out (ask us not to send it) or
change your preferences:

UK Insurance, Clinics, Cromwell Hospital and Care Service customers
Change your preferences in your Bupa Touch online account or app, or email
optmeout@bupa.com

Bupa Global customers
Opt out through the MembersWorld portal or email info@bupaglobal.com

Bupa Dental Care and Smiles patients
Change your preferences in the Patient Portal or email optmeout@bupa.com

You can’t unsubscribe from service communications. These are communications we
need to send you for administrative or customer service reasons.

You also have the right to object to us profiling you for direct marketing
purposes.


YOUR RIGHTS



You have rights under privacy law about to your personal information.


RIGHT OF ACCESS

You can ask us for a copy of the personal information we hold about you.


RIGHT TO RECTIFICATION

You can ask us to correct or remove inaccurate information we hold about you.


RIGHT TO RESTRICTION OF PROCESSING

You can ask us to use your information for restricted purposes only.


RIGHT TO PORTABILITY

You can request that we transfer your information to you or to someone else in a
format that can be read by computer.


RIGHT TO ERASURE

You can ask us to delete your information if there’s no good reason for us to
keep it. If there’s a reason why we can’t do this, for example legally we need
to keep it for a certain length of time, we’ll let you know.


RIGHT TO WITHDRAW CONSENT

You can withdraw any consent you’ve given us. We’ll let you know if we have to
stop providing a product or service to you as a result. Any processing of your
personal information that happened before you withdrew your consent will remain
lawful.


RIGHT TO OBJECT

You can object to us processing your information when:

 * we’re processing it or profiling you for direct marketing purposes
 * we’re processing it for a legitimate interest (see ‘how we use the personal
   information we collect’ for when this applies)
 * our processing is based on a task carried out in the public interest (such as
   prevention of crime)


However, we may be unable to action your objection if there’s an overriding
reason or the processing is necessary for legal claims. We’ll tell you if this
applies when you contact us.

You don’t always have the right to object. We’ll let you know if you can’t and
explain our reasons for turning down your objection.


RIGHTS IN RELATION TO PROFILING AND AUTOMATED DECISION

You can ask us not to make solely automated decisions about you or use profiling
if this has a legal effect on you or an effect as significant as a legal effect.

You can also ask us to reconsider an automated decision and find out more how
the decision was made. If you do, we’ll see if we can review the decision and
let you know the outcome.


We may be unable to action with your request if:

 * the automated decision making or profiling is necessary for us to enter into
   a contract
 * we’re authorised by law to make an automated decision or undertake profiling


YOU ALSO HAVE A RIGHT TO MAKE A COMPLAINT TO YOUR LOCAL PRIVACY SUPERVISORY
AUTHORITY

If you’d like to do this, please tell us first, so we have a chance to address
your concerns.

If we don’t, you can complain to:

 * the Information Commissioner’s Office, if you’re a customer based in the UK
 * the supervisory authority of your country, if you’re an Irish or European
   Bupa Global customer
 * if you’re based another country, we’ll let you know your relevant authority


HOW TO EXERCISE YOUR RIGHTS



If you want to exercise your rights, please email:

 * dataprotection@bupa.com for customers of our UK businesses
 * info@bupaglobal.com, if you’re a Bupa Global customer


To help us manage your request, please tell us in your email which Bupa business
you’re a customer of.


WHAT TO EXPECT




1. IDENTIFICATION

We may ask you to confirm your identity and provide information that helps us
understand your request better.


2. WE’LL LET YOU KNOW IF WE CAN FULFIL YOUR REQUEST

Unless you’re exercising an absolute right, for example the right to object to
the processing of personal information for direct marketing purposes, we may be
unable to fulfil your request. We’ll let you know and explain why.


3. OUR RESPONSE

We’ll respond to requests about automated decisions in 21 days. For all other
requests, we’ll tell you within one month what action we’ve taken, starting from
the day we receive them.


HOW TO GET IN TOUCH OR MAKE A COMPLAINT

If you have any questions, comments or would like to complain about this notice,
or any other questions about the way we process your information, please get in
touch with our Data Protection Officer and privacy team.


SEND US AN EMAIL

Email us at dataprotection@bupa.com, or use the button below.

Email us


REACH US BY POST

Address your letter to:

Bupa, Privacy Team,
1 Angel Court,
City of London, EC2R 7HJ,
United Kingdom

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