Kinds of personal information we collect and hold
Personal information is any information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not, and
- whether the information or opinion is recorded in a material form or not.
Types of personal information we generally collect may include:
- Names, addresses, dates of birth and contact details;
- Details of any property being insured;
- Personal qualifications if relevant such as for professional liability insurance;
- For employment applications – past employment information, qualifications, information about residency status and proof of identity details.
How personal information is collected and held
When we need to collect personal information we will, in most cases, collect the information directly from you.
Unless we are required or permitted by law to collect sensitive personal information, such as health information, we will first obtain your consent.
We collect personal information that you submit when you are using our online services, including payment information or recruitment information processed by our service providers.
Your personal information is held in secure environments including computer systems and databases, paper records and telephone recordings. We may utilise related companies, agents and third party suppliers for data storage services.
When you supply information via the internet, all information you submit is held securely and is not retained on our web servers. Credit card details submitted via our websites are processed through our service providers. Other information held on our systems cannot be accessed through the internet connection. Our online payment facilities are secure and the data, once collected, cannot be accessed through the internet.
Purposes for collecting, holding, using and disclosing personal information
We only collect personal information where it is reasonably necessary for one or more of our functions or activities, such as assessing and administering an insurance application or policy, insurance broking and other insurance-related services or assessing an individual for employment. Where the personal information is sensitive – such as health and medical information – we will also obtain your consent before collecting the information unless we are permitted by law or an exception under the Act applies. An example of an exception would be where the collection is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety.
If you request, there are limited circumstances where you may be able to deal with us anonymously or by using a pseudonym. Examples include where you are seeking only general information about one of our products or services, or are looking only for indicative pricing. In most cases it will not be reasonably possible for you to deal with us in this way.
If you do not supply the information we request we may not be able to process your application for insurance, administer your claim or policy, or accept your expression of interest or application for employment with us.
How we use and disclose your personal information
We will only use or disclose your personal information in ways that you would reasonably expect, in order for us to provide and market insurance services to you, provide you with online training or allow you to use our recruitment facilities. We will request your consent for any other purpose.
Who we may disclose your personal information to and why
We, or our authorised agent, may disclose your personal information to:
- any person authorised by you;
- a mail house, records management company or technology services provider (for printing and/or delivery of mail and email, including secure storage and management of our records);
- a financier whose name appears on your policy schedule (for the purpose of confirming the currency of your policy or when you have a claim and the insured property is a total loss, to confirm if the financier has a current interest);
- an organisation that provides you with banking facilities (for the purpose of arranging direct debit or other payment transactions or confirming payments made by you to us);
- a referrer, or a financial services provider or our agent who is arranging your insurance (for the purpose of confirming your personal and insurance details);
- another person named as a co-insured on your policy (such as for the purpose of confirming if full disclosure has been made to us);
- insurers (such as to assist in assessing insurance risks or to assist with an investigation);
- reinsurers (such as to assist in seeking recovery);
- a dispute resolution organisation such as the Financial Ombudsman Service (for the purpose of resolving disputes between us and you or between us and a third party);
- a company who conducts surveys on our behalf for the purpose of improved customer services; and
- an insurance reference bureau (to record any claims you may make upon us).
In addition to the above, in the event of a claim, we or our authorised agent may disclose your personal information:
- to a repairer or supplier (for the purpose of repairing or replacing your insured items);
- to an investigator or assessor (for the purpose of investigating or assessing your claim);
- to a lawyer or recovery agent (for the purpose of defending an action by a third party against you or recovering our costs including your excess or seeking a legal opinion regarding the acceptance of a claim);
- to a witness to a claim (for the purpose of obtaining a witness statement);
- to another party to a claim (for the purpose of obtaining a statement from them or seeking recovery from them or to defend an action by a third party).
Personal information (about you) may also be collected from the above people or organisations.
Disclosure to overseas recipients
In some instances our service providers and related companies to which we disclose personal information may be located overseas. The countries in which these service providers and related companies are located may vary from time to time, but include the Philippines, India, Ireland, the UK, the USA, China and countries in the European Union.
Where personal information has been disclosed to an overseas recipient, there is a possibility that in certain cases that recipient may be required to disclose it under a foreign law. Where this occurs, such disclosure is not a breach of the Act.
Accessing and seeking correction of your personal information
Our aim is to always have accurate, complete, up-to-date and relevant personal information. When you receive policy schedules, renewal notices or other documents from us you should check that the information is correct. You may contact us to request access to your personal information that we hold at any time, and request us to correct any errors in that information. Generally no restrictions or charges will apply.