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If you are involved in a payment demand case

This is how we process your personal data if you have received or disputed a payment demand from us or are included in our payment demand cases for another reason.

Who is responsible for the personal data Swedish Motor Insurers (TFF) processes?

We are responsible for processing personal data in cases concerning payment demands. We are also responsible for correct processing.

Why does TFF process personal data?

We process your personal data to be able to collect a debt and provide information about the debt. The data is also used to enable us to identify you.

The data is processed for our debt collection service and is used for invoicing, accounting, statistics, legal procedures, as well as troubleshooting and management of our IT systems.

What personal data does TFF have the right to process?

Motor third party liability (MTPL) insurance charge

We process the following personal data: name and personal identity number, contact details, vehicle registration numbers, debt situation and payments, reference number, customer ID number and the various types of case number of the Swedish Enforcement Authority/courts. In addition to this, we may also process personal data that you provide to us yourself, such as the name and contact details of agents/representatives, information relating to your health or social circumstances.

Legal basis

For the performance of a task carried out in the public interest.

Storage period

We dispose of your personal data from our case and document management system no later than 12 months after you no longer have a debt to us. Your personal data is then transferred to a disposal database for storage in unreadable encrypted form for seven years.

Payment demands for premiums and excesses

We have the right to collect unpaid motor third party liability insurance premiums and excesses that your insurance company has contractually transferred to us. We process the following personal data: name and personal identity number, contact details, vehicle registration numbers, debt situation and payments, reference number, customer ID number and the various case numbers of the Swedish Enforcement Authority/courts. In addition to this, we may also process personal data that you provide to us yourself, such as the name and contact details of agents/representatives, information relating to your health or social circumstances.

Legal basis

When your insurance company transfers its demand for unpaid insurance premium or excess to us, TFF (Swedish Motor Insurers) becomes your new contracting party and when we invoice you we do so to fulfil our part of the contract. We then process your personal data to fulfil our contract with you.

Storage period

We dispose of your personal data from our case and document management system no later than 12 months after you no longer have a debt to us. Your personal data is then transferred to a disposal database for storage in unreadable encrypted form for seven years.

Recovery (recourse)

Once we have settled a claim, under the Motor Traffic Damage Act we have the right in certain cases to recover all or part of the claim settlement from the owner or driver of the vehicle. We process the following personal data: name and personal identity number, contact details, vehicle registration numbers, debt situation and payments, reference number, customer ID number and the various case numbers of the Swedish Enforcement Authority/courts.

Under the Motor Traffic Damage Act we have the right to demand repayment of compensation paid from a person who has committed a drink-driving offense and in addition was also negligent at the time the claim was incurred. We also have the right to recover compensation from anyone who has been grossly negligent or caused damage intentionally. In these cases, we process personal data relating to criminal convictions and violations of the law that constitute a criminal offence.

In addition to this, we may also process personal data that you provide to us yourself, such as the name and contact details of agents/representatives and information relating to health or your social circumstances. Read more about our processing of personal data for those involved in a traffic claim case.

If you are involved in a claim case

Legal basis

For the performance of a task carried out in the public interest.

The processing of personal data relating to criminal offences is necessary for the establishment, exercise and defence of our legal claims.

Storage period

We dispose of your personal data from our case and document management system no later than 12 months after you no longer have a debt to us. Your personal data is then transferred to a disposal database for storage in unreadable encrypted form for seven years.

Criminal judgments are not stored in our case and document management system, but are stored separately in a locked space to which a few authorised case officers have access. The criminal judgments are stored until our payment demand is established through a decision or judgment. In cases where TFF is the injured party according to the criminal judgment, the judgment is saved until we have received payment of our claim.

Debt collection measures

We may take debt collection measures against anyone who has a debt to us.

When we have not received payment on time, under the Debt Recovery Act we have the right to take debt collection measures, such as sending a debt collection demand or applying for an order to pay and attachment. We process the following personal data: name and personal identity number, contact details, vehicle registration numbers, debt situation and payments, reference number and customer ID number and the various case numbers of the Swedish Enforcement Authority/courts. In addition to this, we may also process personal data that you provide to us yourself, such as the name and contact details of agents/representatives, information relating to your health or social circumstances. We may also process personal data provided to us by public authorities, such as the Swedish Enforcement Authority’s valuation opinion or the police seized property record.

Legal basis

For the performance of a task carried out in the public interest.

Storage period

We dispose of your personal data from our case and document management system no later than 12 months after you no longer have a debt to us. Your personal data is then transferred to a disposal database for storage in unreadable encrypted form for seven years.

Disputes and court cases

If a person has objected to a payment demand from us or if a case is handled by a court for other reasons, for example in an appealed attachment or debt restructuring or in bankruptcy proceedings, we process personal data about agents/representatives/counsel, witnesses, parties, trustees in bankruptcy and employees of courts, public authorities and insurance companies. The personal data processed are: name and contact details and in some cases the personal identity numbers of parties and witnesses and vehicle registration numberss, reference numbers, customer ID numbers and the various case numbers of the Swedish Enforcement Authority/courts.

Legal basis

Our legitimate interest in communicating and to enable us to establish, exercise or defend our legal claims.

Storage period

We dispose of your personal data from our case and document management system no later than 12 months after you no longer have a debt to us. Your personal data is then transferred to a disposal database for storage in unreadable encrypted form for seven years. 

Statistics and customer surveys

We produce statistics on those who have debts to us. We may also contact those who have debts to us to participate in customer surveys.

We process the following personal data to produce statistics: name and personal identity number, contact details, vehicle registration numbers, debt situation and payments, reference number, customer ID number and the various case numbers of the Swedish Enforcement Authority/courts.

We process the following personal data to conduct customer surveys: name and telephone number.

Legal basis

Our legitimate interest in developing our business and our customer service.

Storage period

For customer surveys, personal data is processed until the survey is completed. For statistical purposes, personal data is collected from our case and document management system. When the statistics and responses from customer surveys are compiled, the personal data is anonymised.

Email, contact form and telephone

We process personal data about those who contact us via email and through contact forms on our website. The following personal data is processed: name, contact details and reference number as well as any personal data you provide yourself.

When you call us, we record information that you provide and that is relevant to our processing.

Legal basis

Our legitimate interest in being able to communicate with those who contact us and to handle cases correctly.

Storage period

If the message concerns a case with us, it is saved in our case and document management system where it is disposed of no later than 12 months after you no longer have a debt to us. If the message concerns something else, it is saved as long as we have an ongoing written dialogue. 

If the call concerns a case with us, notes from the call are stored in our case and document management system. The notes are disposed of no later than 12 months after you no longer have a debt to us. 

Documents sent to us by post

All documents sent to us by post are scanned into our document management system. To avoid the risk of loss of information due to incorrect scanning of documents, all documents received are locked up in a special archive.

Legal basis

Our legitimate interest in ensuring that documents are scanned correctly. We also have the right to process the personal data for the establishment, exercise and defence of our legal claims.

Storage period

Post received is stored in physical form for a maximum of 24 months. Disposal of documents received takes place once per year.

Troubleshoot, develop and test IT systems

We may use data about a person who has a debt to us to troubleshoot, develop and test our IT systems. We may then need to process all personal data included in a case.

Troubleshooting may also take place directly in our document and case management system.

Legal basis

Our legitimate interest in ensuring the protection of personal data and developing the technical functionality of our IT systems.

Storage period

If personal data is processed outside the case management system, they are erased as soon as the troubleshooting, development or testing is completed. 

The Bookkeeping Act

We process personal data about individuals from whom and to whom payments are made.

We process personal data that are accounting records and that are subject to the provisions of the Bookkeeping Act. The following personal data are processed: name, personal identity number, account details, payments or other accounting records, reference number and the various case numbers of the Swedish Enforcement Authority/courts.

Legal basis

For compliance with legal obligations.

Storage period

In accordance with the Bookkeeping Act we retain accounting records for seven years after the calendar year in which the financial year ended. 

Visits to the website tff.se

When you visit tff.se, certain information about what you do on the website is stored on your computer, tablet or mobile phone. To understand how the website is used and obtain a basis for our improvement work, we collect statistics about each visit via a statistical tool.

The data collected may include, for example, a visitor’s IP address, operating system, browser ID and browsing activity. See full details of the data collected by clicking on the icon that appears at the bottom left of the screen.

Legal basis

Our legitimate interest in developing our website.

Storage period

Personal data is stored for 25 months on a server in Sweden. 

My Pages

We describe how we process personal data on My Pages on a separate page.

My Pages terms and conditions and personal data processing

If you use My Pages, cookies are set on your computer, tablet or mobile phone. The cookies that are set are necessary and required to enable you to use My Pages.

Specific information on payment demands to the estate of a deceased person

In the case of a claim against an estate, we need to contact the parties to the estate and/or the heirs stated in the death certificate. We process the following personal data: name and personal identity number, contact details, vehicle registration numbers and payments. In addition to this, we may also process personal data that the parties to the estate/heir themselves provide to us, such as the name and contact details of agents/representatives and information relating to health or concerning social circumstances.

Legal basis

Depending on what the payment demand relates to, we have different legal grounds for our processing. Read more under each heading further up in the text, for example “Motor insurance charge”, ”Payment demands for premiums and excesses”.

Storage period

We dispose of your personal data from our case and document management system no later than 12 months after you no longer have a debt to us. Your personal data is then transferred to a disposal database for storage in unreadable encrypted form for seven years.

Automated decisions

We use automated processes with elements of profiling as the basis for decisions on the collection measures we take. The result of the automated processes may mean, for example, that we apply to the Swedish Enforcement Authority for an injunction to pay or enforcement. Our automated processes do not change your legal status and are therefore not covered by the prohibition of automated decisions in Article 22 of the General Data Protection Regulation.

Where does TFF obtain personal data from? 

We obtain personal data from public authorities, debt collection and credit information companies, insurance companies, banks, the person the case concerns, their representative or trustee in bankruptcy.

Who can see the personal data that TFF processes? 

The case officers can see your personal data. In some cases our IT staff can also see personal data to troubleshoot, protect, develop and test the system.

Who does TFF provide personal data to?

We may disclose information to public authorities, debt collection and credit information companies, statistics companies, trustees in bankruptcy, insurance companies, postal and printing companies, service of documents companies and representatives of the person to whom a case relates.

Public authorities

We provide information to the Swedish Enforcement Authority, the Swedish Transport Agency and courts within the framework of our debt collection activities. When we disclose personal data to the Swedish Enforcement Authority, the Swedish Transport Agency and courts, we do so because it is necessary to perform a task carried out in the public interest.

We also provide information to law enforcement agencies. When we disclose personal data to law enforcement agencies agencies we do so to comply with a legal obligation incumbent on us or for our legitimate interest in protecting ourselves from crime.

Debt collection and credit information companies

We provide information to debt collection companies for collection of our claims and for service of documents. When we disclose personal data to debt collection companies we do so to perform a task carried out in the public interest.

We provide information to credit information companies to obtain the correct address and personal status of the person to whom the case relates. We also provide personal data to credit information companies for the purpose of obtaining decisions on the collection measures we are to take or to be able to dismiss incorrect information. 

When we disclose personal data to debt collection and credit information companies we do so to perform a task carried out in the public interest.

Statistics companies

We provide information to statistics companies to be able to produce statistics. When we disclose personal data to statistics companies we do so to meet our legitimate interest in developing our business and our customer service.

Trustees in bankruptcy

We provide information to trustees in bankruptcy so that we can monitor and receive payment of our claims in a bankruptcy. When we disclose personal data to trustees in bankruptcy we do so to meet our legitimate interest in receiving payment of our claim.

Insurance companies

We provide information to insurance companies to be able to obtain a good basis for our decisions. When we disclose personal data to insurance companies we do so to meet our legitimate interest in obtaining good decision-making data for our measures.

Postal and printing companies

We provide information to postal and printing companies to enable us to communicate for example with the person to whom a case relates, their representative, public authorities, debt collection and credit information companies and others. When we provide personal data to postal and printing companies we do so to meet our legitimate interest in communicating.

Third country transfer  

Our processor and our subsidiary Svensk Försäkring Administration AB (SFAB) provide cloud services owned by the American company Microsoft Ireland Operations Limited (Microsoft), for example Sharepoint and Teams. For our use of these, SFAB has a sub-processor agreement with Microsoft.

When TFF uses these cloud services, information is stored on servers located within the EU/EEA but owned by Microsoft. When using such cloud services, we only process the following pseudonymised personal data: reference number and customer ID number. Pseudonymised personal data is personal data that on its own cannot be linked to a specific person without additional data.

When we process reference numbers and customer ID numbers there is a risk that the pseudonymised personal data will be transferred to third countries.

Personal data may be transferred to a third country if the European Commission has decided that the country ensures an adequate level of protection. On 10 July 2023, the European Commission issued an adequacy decision for the United States. This means that transfers of personal data from the EU to organisations subject to the EU-US Data Privacy Framework (DPF) can now take place without the need for appropriate safeguards. Microsoft has joined the DPF.

Storage period: Reference numbers and customer ID numbers included in communications are erased when no longer needed for the communication or at the latest within six months. Reference numbers and customer ID numbers included in working documents are erased when no longer necessary for our handling of the case.

Recording of telephone calls 

We record calls to our customer services. The recordings are used for the purpose of improving the quality of customer service to train our employees. Anyone calling us can opt out of the call being recorded by pressing a key. Calls are recorded to meet our legitimate interest in developing our service.

TFF’s customer services officers can activate the recording of a threatening call while the call is in progress. Our interest in recording a threatening call is then considered to outweigh the threatening person’s interest in not being recorded.

TFF is responsible for the personal data we process when recording calls. We engage Puzzel AB for telephony services. Puzzel AB complies with current data protection legislation and is responsible for protecting personal data that is recorded.

Those who have access to the recordings are a limited number of our customer services staff with special authorisation. In the event of a technical problem, an authorised person from Puzzel AB may also have access to the recordings.

The recorded calls are stored on a Puzzel AB server in Sweden. They are erased automatically after 14 days. During the 14 day storage period the call recordings are searchable by date, time, length of call or by the telephone number from which the call was made. It is not possible to search for words or other content in the recorded conversation.

By law, recorded calls may be handed over to law enforcement agencies and may then be stored for longer than 14 days.

Your rights concerning your personal data