RCS Privacy Policy

Rental Claims Services (“RCS” or “we or us”) is a third-party liability claims management company that processes claims on behalf of American International Group UK Limited (AIG) for vehicles rented through Enterprise Rent-a-Car UK Limited (hereinafter referred to as "Enterprise").

The following notice has been set out to provide you with how RCS processes claims data for AIG. Please review AIG’s full privacy notice for any additional information. This privacy notice ("Privacy Notice") explains the data we receive, use, disclose, and transfer, as well as the individual access rights you may have when processing your claim on behalf of AIG. 

What Information We Collect/Receive

We may collect or receive directly from you or from the insurer, insurance broker, or an instructed third party:

Contact Information, including: name, address, phone numbers, email addresses.

Biographical Information including date and place of birth, educational background, physical attributes, activity records, county court judgments (CCJs), lifestyle, social media profile, and date and cause of death, injury, or disability, and criminal convictions.

Employment Information including employment history, occupation, skills and experience, professional licenses and affiliations, employer.

General Identification Information including information issued by government bodies or agencies such as national insurance number, passport number or driver’s license.

Financial Information including bank account details, credit history and credit scores.

Health Information including information about relevant health conditions you have related to claims involving injuries. For example, current or previous physical, mental, or medical conditions, injuries or disabilities, medical procedures and prescriptions, personal habits (smoking or alcohol consumptions) and overall medical history.

Special Categories of Information.

In certain specific situations we may also process sensitive information about your trade union membership, religious beliefs, political options, or family medical history information. This information may be obtained voluntarily, for example, if you express preferences regarding medical treatment based on religious beliefs.

Information Enabling Us to Handle Claims

Claims Information including information related to details of accidents involving Enterprise vehicles, including that of any third parties such as involved individuals, witnesses, and police reports. This may also include the location and identification of insured property.

Insurance Information including policy details, details of policy coverage, other insurance policies you may hold.

Previous Claim Information including information relating to your prior accident or loss history.

Customer feedback Preferences you may let us know how you want to be contacted (such as, by email/phone or post).

Personal Information of Others

To the extent that you have provided (or will provide) personal information to RCS about any other individual, you agree that you have provided information to the individual about the content of this Privacy Notice and you have their permission to share their Personal Information with us as detailed in this Privacy Notice.

How We Process Information About You

To process the information provided to us for the purpose of claim handling, to determine the extent of liability for a claim and, where appropriate, to arrange vehicle repairs, replacement, or payment, or for other purposes as permitted by AIG or applicable data protection legislation.

To communicate important information regarding the claim and other administrative information to interested Parties 

Under the insurer’s direction, to facilitate decisions about claim assessment, processing, and settlement. This will include details of those involved with the claim, the circumstances, and value of the claim. This is determined and governed by the insurer based on their contractual terms.
To provide customer service related to your interactions with us or to respond to your enquiry;
For the management of our business operations and IT infrastructure to ensure we comply with internal policies and procedures.
For prevention, detection, and investigation of crime, such as fraud and money laundering 
For establishment and defence of legal rights or claims with AIG and to protect their business interests and rights, privacy, safety and property, or that of individuals and the public. 
Legal and regulatory compliance (including compliance with applicable laws and regulations) 
For monitoring and recording of telephone calls for quality, training, and claims handling purposes. In anticipation of any legal defence and security purposes.

Retention of Your Personal Information

We retain your personal information for as long as we need to fulfil our obligations to AIG, as set out below:

Claims

We keep the data associated to claims for the life of the claim and up to six years from conclusion of our obligation to AIG, subject to other legal requirements.

Who We Share Information With

We may share your information with the following parties for the purpose of handling and fulfilling claims, or as required by law:

Insurance, Insurance Brokers or other appointed representatives of an involved insurance company
Service Providers such as but not limited to professional advisors, medical professionals, and actuaries. Service providers also include our vendors that provide IT systems, support and hosting service providers, document and records management providers that assist in carrying out business activities.
Third Party Claim Administrators, claim investigators, engineers, translators or similar third-party vendors.
Other services relating to the information provided, to check, detect and prevent fraudulent claims. Such information may be placed on registers of claims and shared with other insurers. These registers are searched when dealing with claims.
Government/Public Authorities and/or Third Party Litigants as required by applicable laws or as we believe to be necessary or appropriate:
To comply with applicable laws and regulations, regardless of your country of residence
To follow the legal process
To allow us to purse available remedies or limit our damages
To protect our rights, privacy, safety or property.

We may also share your personal data with approved vendors, or other affiliated entities in order to process and fulfil your claim. If these entities are separate Data Controller for that service, they will identify and notify you of their applicable privacy notice. We will also share your personal data with companies within the enterprise group for the purpose of auditing claims, maintenance, security of systems. For more details please see here.

Legal basis for Processing

The legal basis is determined by AIG as the data controller. Please see their privacy policy for full details. At the time of writing the legal basis set out by AIG for processing your Personal Data is one of the following:

You have given consent to the party for whom we are acting
The processing is necessary for the performance of a contract you have with the entity we are processing your claim on behalf of or that entities’ legal duty
Processing is necessary for a legitimate interest pursued by the entity for whom we are acting on their behalf. 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 defence of legal claims
Prevention, detection of crime

Automated Decisions  

On behalf of AIG, we may use automated processes to analyse your personal data to streamline the handling of your claim. However, any decision making that would affect you or your claim will be handled by a person.

Data Transfers and Processing

RCS maintains its global information systems in the United States.  If you provide us with or if we collect personal information about you, we will transfer and maintain your personal information in the United States.

When we transfer your personal information and process it in the United States, we do so in accordance with UK approved standard contractual clauses (or other similar standard as applicable to your country). When we transfer your personal information to our third-party service providers who are located outside the UK or European Economic Area (EEA), we use UK -approved standard contractual clauses. When making these transfers, we will take steps to ensure that your Personal Information is adequately protected and transferred in accordance with the requirements of data protection law.

Your Data Subject Rights

We assist AIG in fulfilling the below rights:

You have the right to information about what personal data we process, how and on what basis as set out in this Privacy Notice.
You have the right to access your own personal data by way of a subject access request.
You have the right to modify your information, to correct any inaccuracies in your personal information.
You have the right to request that we erase your personal data where AIG is not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected.
While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made.
You have the right to object to data processing where we, on behalf of AIG, are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.
You have the right to complain to the data controller, ICO or another supervisory authority.
Contact the AIG Data Protection Officer: _________________
You may exercise any applicable rights described above by accessing our Global Privacy Portal* or by emailing RCSPrivacy@ehi.com

Changes to These Policies

As necessary, we will update our Privacy Notice to reflect changes in our practices. By means of a notice on this site or as otherwise may be required or permitted by law, prior to the change becoming effective. We encourage you to periodically review this site for the latest information on our privacy practices.

Contact Us

For questions or enquiries related to privacy and data protection, please email RCSPrivacy@ehi.com or you can submit your request through our Global Privacy Portal