INDEX / DIRECTORY / CHURCHILL / DIGITAL

Churchill DIGITAL

DIGITAL INFRASTRUCTURE AUDIT UPDATED 2026-09-08
Digital Score 0.00 /10 D Churchill - BDS-1000 383
Digital 0.00

Evidence-only forensic audit. Scoring happens downstream - see the main dossier for the composite assessment.

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Enterprise Technology Stack & Vendor Relationships

Churchill Insurance is a trading brand operated by U K Insurance Limited (UKI), which underwrites Churchill general-insurance policies and is regulated by the FCA and PRA.1

As of 31 December 2025, UKI was a wholly owned subsidiary within the chain Aviva plc → Aviva Group Holdings Limited → Aviva Insurance Limited → Direct Line Insurance Group Limited → U K Insurance Limited, with Aviva plc as ultimate controlling parent.2 Aviva completed its acquisition of 100% of Direct Line Insurance Group plc on 1 July 2025 for total consideration of £4.0 billion following CMA clearance, and the acquired holding company was re-registered as Direct Line Insurance Group Limited on 3 December 2025.3, 4, 5, 6, 7

UKI’s current Companies House PSC record identifies Direct Line Insurance Group Limited as its single active corporate PSC, holding more than 75% of shares and voting rights and the right to appoint or remove directors; a 2026 UKI filing records the consequential PSC-detail change after the re-registration.8, 9

On 14 August 2026, Aviva stated that it had completed the transfer of all Direct Line employees to Aviva, but this does not establish migration or adoption of a particular Aviva technology by Churchill or UKI.10

A 2021 Direct Line Group announcement stated that its cloud-based motor platform served Direct Line, Churchill and Privilege customers, with Capgemini as systems-integration partner and integrated capabilities from Guidewire, MuleSoft, Salesforce, AWS, and Willis Towers Watson Radar Live.11 The announcement described the platform rollout as continuing in 2021, so it does not establish the present deployment status of each named product or supplier.11

Direct Line Group stated in 2022 that it used Microsoft Surface Go 2 devices and Microsoft 365 tools, including Teams, for contact-centre and remote-working operations; this is group-level evidence and does not establish a Churchill-specific deployment.12

Earnix’s Deloitte partner page states that Deloitte has implemented Earnix with “Aviva Group,” describing business analysis, actuarial science, solution design, implementation, systems integration and rollout in pricing and rating contexts.13 Aviva’s 2025 annual report identifies the more specific disclosed undertaking: Aviva Canada General Insurance implemented its full personal-lines product suite on Earnix in 2025, adding property and lifestyle products to an AI-driven pricing, rating and decisioning platform.4

Aviva states that the Canadian implementation supports pricing decisions, including rate-territory and catastrophe-peril modelling.4 Earnix’s 2023 event material identifying Aviva Canada’s CIO and Group Chief Architect is consistent with that Canada-specific disclosure, but does not establish Earnix deployment elsewhere in Aviva.14

No public evidence identified that the Earnix implementation included UKI, Direct Line, Churchill, or another UK Aviva unit.4, 13 The Deloitte source does not identify the Aviva legal entity, deployment date, modules or data scope, while the Aviva annual report identifies Aviva Canada General Insurance and the 2025 implementation but does not establish a UK deployment.4, 13

Verint states that Five9 has supplied Verint services to Aviva for several years through a Verint solution hosted in the Five9 cloud, including call recording, quality management, speech analytics, desktop/process analytics and workforce management integrated with Five9 CCaaS; the vendor describes more than 3.5 million calls annually handled through approximately 2,500 agents.15 A separate Verint case study identifies Aviva Life’s AWS-hosted use of Verint Speech Analytics, describing recorded and transcribed calls and more than three million calls, or more than 330,000 hours, annually in that operation.16

These Verint sources support Aviva-level vendor relationships as described by the vendor, but do not name Churchill, UKI, Direct Line, a particular acquired business unit, controller/processor roles, or hosting regions.15, 16 A 2024 Employment Tribunal judgment records a May 2022 “Verint system” schedule in an Aviva employment context, corroborating historical Aviva workforce-management use but not Churchill or UKI deployment or present use.17

No public evidence identified of a Churchill, UKI, Direct Line, or Aviva licensing, subscription, integration, procurement, or operational deployment relationship with NICE or Nexidia.15, 16, 10, 13

No public evidence identified of an operational Churchill, UKI, Direct Line, or Aviva customer/vendor deployment with Check Point, CyberArk, SentinelOne, Wiz, Palo Alto Networks, or comparable named Israeli-origin cyber providers, apart from the Aviva Investors fund holdings described below.18, 19

As at 31 December 2025, three specified Aviva Investors Funds ACS sub-funds reported Check Point shareholdings: 83 shares valued at £11,000 in the AI Balanced Life Fund, 1,561 shares valued at £215,000 in the AI Balanced Pension Fund, and 210 shares valued at £29,000 in the AI Distribution Life Fund.18 The same AI Distribution Life Fund reported 98 CyberArk Software shares valued at £32,000.18 Check Point identifies its international headquarters as Tel Aviv, Israel.20

The Check Point and CyberArk disclosures concern portfolio securities held by specified managed sub-funds, not a corporate-venture investment, controlling stake, technology-procurement decision, Churchill data flow, or commercial supplier relationship.18, 21 The non-appearance of SentinelOne or Verint in that single 2025 fund report is report-scoped and does not establish wider non-holding.18

Surveillance, Biometrics & Retail Technology

Churchill’s DriveSure terms describe a telematics scheme underwritten by UKI in which suppliers provide or install plug-in or installer-fitted devices and collect, transmit, and analyse driving data for UKI.22 The terms identify the customer portal as mydrivesure.com but do not name the device, analytics, or technology suppliers.22

UKI’s privacy policy states that it uses profiling, automated processing, machine-learning tools, and natural-language processing to analyse speech and text, including sentiment.23 The policy lists underwriting and claims support, query routing, identity verification, fraud detection, process monitoring, risk assessment, and data-quality checks among the stated applications.23 The public disclosure does not identify the relevant software vendors, processing locations, or an Israeli-origin product.23

At Aviva level, Verint describes desktop and process analytics used to identify customers who have become “orphaned” from financial advisers, including analysis of call metadata.15 Verint’s Aviva Life case study describes analysis of recorded call transcriptions for FCA vulnerability categories, additional fraud-concern and high-risk categories, repeat-caller watchlists, and normal transcription within four hours.16 These sources confirm processing of recorded customer communications and associated metadata in the described Aviva operations, but do not establish that Churchill or UKI customer data enters either workflow.15, 16

No public evidence identified of facial recognition, gait analysis, biometric identification, Trigo, BriefCam, AnyVision/Oosto, Israeli-origin behavioural analytics, predictive-policing tools, or Israeli-origin retail or workforce-surveillance products used by Churchill, UKI, or Direct Line.22, 23, 15, 16

Cloud Infrastructure, Data Residency & Sovereign Cloud Participation

At an AWS event in June 2023, Direct Line Group product owners presented a data-democratisation platform using Amazon S3, AWS Glue Studio, AWS Glue DataBrew, and Amazon Redshift Serverless.24 The presentation describes data-lake, ETL, data-science, visualisation, access-control, data-catalogue, data-lineage, and governance functions, while listing auto-ingestion, conversational AI, and data quality as future-roadmap items.24 This substantiates Direct Line Group use of the specified AWS services in 2023 but does not establish continued use, hosting regions, sub-processors, or post-acquisition data-routing architecture.24

UKI’s privacy policy states that it and service providers may transfer personal information outside the United Kingdom subject to stated safeguards, but does not name transfer destinations, cloud regions, data centres, vendors, or Israel as a transfer destination.23 The Aviva-level Verint material identifies a Five9-cloud deployment and a separate AWS-hosted deployment, but does not disclose cloud region, routing, sub-processors, Israeli operations, Israeli legal access, or Churchill/UKI data scope.15, 16

Earnix’s published materials describe a cloud-based/SaaS insurance platform, while Aviva identifies the Canada deployment as pricing, rating and decisioning for personal-lines products.4, 13, 25 No public evidence identified of the hosting provider or cloud region, data residency, data-routing, retention, support-access locations, controller/processor allocation, Israeli-jurisdiction access, or personal-data fields for the Aviva Canada Earnix deployment.4, 13, 26, 27, 28-25 Earnix’s privacy policy expressly excludes SaaS-solution processing, so it does not establish those customer-deployment arrangements.27

No public evidence identified that Churchill, UKI, or Direct Line operates or leases data-centre infrastructure in Israel, participates in Project Nimbus or another Israeli government-cloud programme, holds an Israeli government-cloud contract, or provides data-sovereignty or resilience services to Israeli state institutions or military bodies.24, 23, 15, 16, 29, 13, 25

Defence, Intelligence & Security Sector Technology Relationships

Earnix Ltd’s current LEI record identifies its legal jurisdiction as Israel, registration with the Israeli Corporations Authority, and legal and headquarters addresses in Ramat Gan, Israel.26 Earnix’s contact and careers pages identify its Tel Aviv/Ramat Gan office and describe Ramat Gan as the place where it began and continues product enhancement and innovation; its 2022 release described the company as Israeli-based.28, 30, 31

The public record does not establish Earnix’s legal domicile at the exact date of the otherwise undated Deloitte “Aviva Group” implementation, although its current Israeli legal-jurisdiction record and current Ramat Gan product-development footprint are documented.13, 26, 28, 30 No public evidence identified in the reviewed sources that Earnix was Israeli military-tech, Unit 8200-linked, state-security-linked, a defence exporter, or a supplier of surveillance or offensive-cyber technology in connection with the disclosed Aviva implementation.13, 26, 27, 28-25

No public evidence identified of an Earnix contract, partnership, service agreement, procurement award, or operational product deployment for the Israeli Ministry of Defence, IDF, Israeli intelligence agencies, Project Nimbus, settlements, or occupied-territory authorities in the targeted and reviewed sources.13, 26-25 The documented Earnix platform is insurance pricing, rating, underwriting and product-decisioning technology; no reviewed source presents it as a purpose-built kinetic targeting, fire-control, target-generation, or autonomous-tracking product.4, 13, 31-25

No public evidence identified of contracts, partnerships, service agreements, dual-use deployments, offensive-cyber products, digital-weapons activity, or technology provision involving Churchill, UKI, or Direct Line and the Israeli Ministry of Defence, IDF, intelligence agencies, or other Israeli state-security bodies.1, 2, 24, 23, 15, 16

No public evidence identified of Aviva’s documented Verint use being supplied to an Israeli state, military, intelligence, settlement, or occupied-territory customer; the vendor sources describe UK insurance, wealth, and retirement use cases.15, 16

Churchill’s public legal materials identify UKI as the underwriting entity, while UKI’s 2025 solvency filing identifies Aviva plc as its ultimate controlling parent.1, 2 Churchill Insurance Company Limited is a separate active English private limited company with SIC 65120, and UKI’s organisational chart places it beneath UKI.2, 32 That separately incorporated company should not be conflated with the Churchill brand’s stated underwriting entity, UKI.1, 2, 32

UKI’s public legal page states that it is proposing a transfer of insurance business to Aviva Insurance Limited, and the 2025 solvency report describes Part VII transfer work as subject to court approvals.1, 2 The reviewed material establishes a proposal rather than completion, and no reviewed current corporate record establishes final court approval or completion.1, 2, 9

AI, Algorithmic & Autonomous Systems

UKI publicly describes automated processing, statistical modelling, machine-learning tools, and natural-language processing in insurance, fraud, and customer-service contexts.23 The disclosure does not identify model suppliers, training-data locations, Israeli state or security customers, or occupied-territory customers.23

Direct Line Group’s 2023 AWS presentation listed conversational AI as a future-roadmap item rather than documenting a deployed Churchill-specific conversational-AI system.24 Aviva’s August 2026 results state that the group is deploying AI in medical underwriting and wealth quality assurance, and plans a virtual assistant and an AI-enabled claims agent; the announcement does not identify an Israeli supplier, Israeli operations, or Churchill-specific implementation.10

Aviva describes Earnix in the Canadian deployment as an AI-driven pricing, rating and decisioning platform, including rate-territory and catastrophe-peril modelling.4 The disclosed evidence does not establish its use by UKI, Direct Line, or Churchill, nor does it enumerate underlying personal-data fields, training-data locations, model-hosting regions, or Israeli data access.4, 13, 27

No public evidence identified of AI or machine-learning provision by Churchill, UKI, or Direct Line to Israeli state or security bodies, model training on Israel or occupied-territory surveillance data, or provision of autonomous targeting, target-generation, or autonomous-tracking systems.24, 23, 10

Technology Ecosystem & R&D Footprint

UKI’s 2025 solvency report describes its operations as being in the United Kingdom.2 The 2024 Direct Line Group report stated that UKI had been registered as a foreign company in South Africa and had an Irish branch that was deauthorised in February 2025.33 No Israeli office, subsidiary, branch, franchise, or operating location was identified in the reviewed Churchill, UKI, Direct Line, Aviva, Companies House, and solvency-record sources.1, 2, 33, 32, 4, 8, 6, 34, 9-35

Direct Line’s Companies House filing history records a registered-office change on 29 May 2026 to 8 Surrey Street, Norwich, NR1 3NG, and accounts to 31 December 2025 filed on 21 April 2026; this is a UK registered-office fact, not evidence of an operational technology location.7

Aviva plc is an active UK public limited company and is exempt from PSC-register disclosure because its voting shares are admitted to trading on a UK regulated market.35 At its 6 May 2026 AGM, shareholders re-elected George Culmer, Amanda Blanc, Charlotte Jones, Cheryl Agius and Andrea Blance as directors.36 Aviva’s current executive profile states that Charlotte Jones is a director of Aviva Group Holdings Limited, Aviva Insurance Limited and Direct Line Insurance Group Limited, corroborating an Aviva-to-Direct-Line governance link.37

The preserved UKI and Direct Line officer records establish overlapping post-acquisition directorships with Aviva Insurance Limited, but directorship alone does not establish personal beneficial ownership, a family-office vehicle, or personal investments in Israeli technology companies.19, 38, 39 The reviewed UKI PSC disclosure identifies only its corporate parent, Direct Line Insurance Group Limited; it identifies no individual PSC.8 The prior Companies House and Aviva annual-report review did not identify a current individual or family-office vehicle holding 10% or more of Aviva plc, but this is record-scoped and does not rule out reportable institutional shareholdings.4, 8, 34, 35 Targeted searches of publicly available sources for Amanda Blanc, George Culmer and Charlotte Jones found no public evidence of personal investments, board roles, or family-office vehicles involving Israeli surveillance, cyber, AI, SIGINT, or military-technology firms; that finding does not resolve undisclosed holdings.36-37

Aviva Ventures is Aviva plc’s corporate venture-capital fund; Aviva states that it makes direct and indirect investments for financial and strategic returns and identifies AI/GenAI, fintech, cyber/security/digital trust, and mobility/IoT among its innovation areas.21 Aviva announced a further £150 million commitment to Aviva Ventures in April 2023.40 Aviva’s 2015 launch announcement described a technology-investment remit and intended annual investment of approximately £20 million for five years, but that historical description does not establish the fund’s current portfolio.41

No public evidence identified in the reviewed sources of an Aviva Ventures investment, acquisition, accelerator programme, R&D facility, engineering office, or co-development arrangement involving Earnix or another Israeli-domiciled fintech, cyber, surveillance, or AI company.21, 40, 41, 13, 26-25 The disclosed Check Point and CyberArk positions are managed-fund portfolio holdings, not evidence that Aviva Ventures made direct investments in those companies.18, 21

No public evidence identified of Churchill, UKI, or Direct Line-operated Israeli R&D facilities, engineering offices, innovation labs, Israeli technology acquisitions or investments, material patent portfolios, or co-development arrangements with Israeli-domiciled entities or research institutions.2, 33, 21, 13, 26-25 The 2024 Direct Line Group annual report listed several then-associated entities, including Churchill Insurance Company Limited, Direct Line Insurance Limited, U K Insurance Business Solutions Limited, and DLG Support Services India Private Limited, but it is not evidence of their present status following Aviva integration.33

Civil Society Scrutiny & Regulatory History

The reviewed KLP lead concerns Churchill Downs Inc., a distinct US company, rather than Churchill Insurance, UKI, Direct Line, or Aviva, and is therefore not evidence concerning this target.42

The current BDS priority-target guide contains no text match for “Churchill” or “Aviva,” which is a page-scoped finding only.43 The retrieved default Who Profits company-database page contains no text match for those names; because no target-specific search result was returned, that does not establish absence from the full database.44 The retrieved HRW and Amnesty reports contain no text match for “Aviva” and concern Israeli authorities, rather than establishing a Churchill, UKI, Direct Line, or Aviva technology relationship.45, 46

No public evidence identified of a boycott or divestment campaign, regulatory inquiry, export-control action, sanctions-related investigation, or legal action specifically concerning Churchill, UKI, or Direct Line technology provision to Israeli state entities or operations in occupied territory.1, 2, 42, 43-46

Aviva’s 7 March 2025 statement says it had approximately £900 million invested in UK defence companies and intended to invest more; it does not identify an Israeli company, Israeli state customer, occupied-territory activity, Churchill/UKI technology provision, or an Earnix relationship.47

The reviewed corporate records do not identify an Israeli subsidiary, branch, office, franchise, or legal entity for Churchill, UKI, or Churchill Insurance Company Limited.1, 2, 32, 8, 6, 48

Footnotes

  1. https://www.churchill.com/about-us/legal-and-regulatory ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  2. https://static.aviva.io/content/dam/aviva-corporate/documents/investors/pdfs/regulatoryreturns/2025/31-Dec-25-UK-Insurance-Limited-SFCR.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12

  3. https://www.aviva.com/newsroom/news-and-research-overview/news-releases/2025/07/aviva-completes-acquisition-of-direct-line/ ↩

  4. https://static.aviva.io/content/dam/aviva-corporate/documents/investors/pdfs/reports/2025/annual-report-and-accounts-2025.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12

  5. https://www.gov.uk/cma-cases/aviva-slash-direct-line-merger-inquiry ↩

  6. https://find-and-update.company-information.service.gov.uk/company/02280426 ↩ ↩2 ↩3

  7. https://find-and-update.company-information.service.gov.uk/company/02280426/filing-history ↩ ↩2

  8. https://find-and-update.company-information.service.gov.uk/company/01179980/persons-with-significant-control ↩ ↩2 ↩3 ↩4 ↩5

  9. https://find-and-update.company-information.service.gov.uk/company/01179980/filing-history ↩ ↩2 ↩3

  10. https://www.aviva.com/newsroom/news-and-research-overview/news-releases/2026/08/half-year-2026-results-announcement/ ↩ ↩2 ↩3 ↩4

  11. https://www.capgemini.com/news/press-releases/direct-line-group-launches-new-self-serve-platform-for-motor-lines-products/ ↩ ↩2

  12. https://www.microsoft.com/en/customers/story/1475089093659040045-directline ↩

  13. https://earnix.com/partners/system-integrators/deloitte/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14

  14. https://earnix.com/newsroom/press-releases/industry-visionaries-and-change-makers-to-speak-at-earnix-e-celerate-summit-2023/ ↩

  15. https://www.verint.com/case-studies/aviva-increases-nps-and-improves-compliance-using-verint-speech-analytics/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  16. https://www.verint.com/nl/case-studies/aviva-life-reimagines-vulnerable-customer-experience-with-verint-speech-analytics/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  17. https://assets.publishing.service.gov.uk/media/66a7785849b9c0597fdb062e/Miss_S_Bailey_v_Aviva_Employment_Services_Limited_-_6000010-2022_-reserved_Judgment.pdf ↩

  18. https://static.aviva.io/content/dam/aviva-investors/main/assets/capabilities/reports-and-financial-statements/aviva-investors-acs-funds/aviva-investors-acs-funds-annual-report-31-dec-2025.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  19. https://find-and-update.company-information.service.gov.uk/company/01179980/officers ↩ ↩2

  20. https://www.checkpoint.com/about-us/ ↩

  21. https://www.aviva.com/about-us/our-purpose-and-priorities-overview/innovation/ ↩ ↩2 ↩3 ↩4 ↩5

  22. https://www.churchill.com/car-insurance/black-box-original/terms-new ↩ ↩2 ↩3

  23. https://u-k-insurance.co.uk/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10

  24. https://pages.awscloud.com/rs/112-TZM-766/images/ANA102-democratising-data-at-direct-line-group.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  25. https://earnix.com/newsroom/press-releases/earnix-acquires-zelros-to-transform-insurers-business-performance/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  26. https://lei.bloomberg.com/leis/view/549300UDGBYB0LFZ0W45 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  27. https://earnix.com/privacy-policy/ ↩ ↩2 ↩3 ↩4

  28. https://earnix.com/contact/ ↩ ↩2 ↩3 ↩4

  29. https://find-and-update.company-information.service.gov.uk/company/01179980/filing-history?page=2 ↩

  30. https://earnix.com/our-story/careers/israel/ ↩ ↩2

  31. https://earnix.com/newsroom/press-releases/earnix-opens-new-north-american-hub/ ↩ ↩2

  32. https://find-and-update.company-information.service.gov.uk/company/02258947 ↩ ↩2 ↩3 ↩4

  33. https://www.directlinegroup.co.uk/content/dam/dlg/corporate/images-and-documents/investors/oar-2024/documents/annual-report-and-accounts-2024.pdf ↩ ↩2 ↩3 ↩4

  34. https://find-and-update.company-information.service.gov.uk/company/02468686/officers ↩ ↩2

  35. https://find-and-update.company-information.service.gov.uk/company/02468686/persons-with-significant-control ↩ ↩2 ↩3

  36. https://www.aviva.com/investors/events/2026/meeting-agm-2026/ ↩ ↩2

  37. https://www.aviva.com/about-us/our-board-and-executives-overview/leader-profiles/charlotte-jones ↩ ↩2

  38. https://find-and-update.company-information.service.gov.uk/company/02280426/officers ↩

  39. https://find-and-update.company-information.service.gov.uk/company/SC002116/officers ↩

  40. https://www.aviva.com/newsroom/news-and-research-overview/news-releases/2023/04/aviva-plc-commits-further-150-million-to-aviva-ventures-and-invests-in-scan-dot-com/ ↩ ↩2

  41. https://www.aviva.com/newsroom/news-and-research-overview/news-releases/2015/12/aviva-launches-venture-capital-arm-to-invest-in-new-digital-businesses-17560/ ↩ ↩2

  42. https://www.klp.no/en/corporate-responsibility-and-responsible-investments/exclusion-and-dialogue ↩ ↩2

  43. https://bdsmovement.net/Guide-to-BDS-Boycott ↩ ↩2

  44. https://www.whoprofits.org/companies/ ↩

  45. https://www.hrw.org/report/2021/04/27/threshold-crossed/israeli-authorities-and-crimes-apartheid-and-persecution ↩

  46. https://www.amnesty.org/en/documents/mde15/5141/2022/en/ ↩ ↩2

  47. https://www.aviva.com/newsroom/news-and-research-overview/news-releases/2025/03/media-statement-on-investing-in-uk-defence/ ↩

  48. https://find-and-update.company-information.service.gov.uk/company/02258947/filing-history ↩