What information do we collect?
We collect and hold personal information about our applicants and potential applicants for our products and services, our customers and business partners. The type of personal information we collect and hold may include but is not limited to:
- identity details such as your name, address, and date of birth;
- contact information such as phone numbers, email addresses and digital handles;
- employment information;
- information about your loan if we provide credit insurance (consumer credit or general asset protection insurance);
- information about assets or rights (such as travel) that we arrange insurance for;
- health information relevant to your products;
- lifestyle information relevant to your products; and
- interactions with us through our website or any other communication platform.
If you are considering employment with us, we will also collect your career history, aspirations and motivations.
Where do we collect personal information from?
We collect information from you directly when you inquire or apply for, any product or service from us and when we speak with you on the phone, exchange electronic and other correspondence, and from our authorised representatives when engaged in providing financial services on our behalf or in referring you to us.
We also collect information from your lender if you finance your policy, and if you make a claim, we may collect information relevant to your claim from your lender, your current and previous employers, referees, your comprehensive insurer, government agencies, medical practitioners and publicly available sources, including social networks.
We may also collect health information about your dependents from their medical practitioners if you hold Loan Protection Insurance and make a Carer Cover claim.
Our Product Disclosure Statements provide more detail about when and from whom we collect information..
Why do we collect personal information?
Our main purposes for collecting your personal information are to help us with:
- assessing applications for products and services offered by us, including products issued by third party insurers who authorise us to deal in their products;
- managing and servicing your products;
- assessing and paying your claims;
- letting you know about products and services offered by us or by an organisation that we are associated with that might interest you or meet your financial or insurance needs;
- complying with our legislative or regulatory requirements;
- verifying your identity;
- research and product development; and
In some circumstances, we may collect sensitive health information about you and your family, for example when applying for, or claiming on, a consumer credit insurance. We will only collect personal information from you that is necessary to one or more of our functions and activities.
We will only collect personal information from you by lawful and fair means, without being unreasonably intrusive, such as when you complete an application form or respond to some other communication relating to the management of your relationship with us.
In most cases, it is necessary for us to identify you so that we can provide our products and services or pay claims. However, if it is lawful and practicable, you may have the option of not providing us with your identity information such as when making general enquiries about products or services.
How do we use your information?
We will only use your personal information for the purposes we told you it was needed except where:
- you give us consent to use your personal information for another purpose;
- the other purpose is related to one of those purposes, or it is not unreasonable to expect us to use your personal information for that other purpose; or
- purposes permitted or required by law.
We may also use your personal information to send you materials about products or services we think may benefit you, and we may disclose your personal information to our associated organisations so that they may send you marketing materials. You may tell us at any time that you do not wish to receive any further marketing materials by sending an email to email@example.com and we will stop sending you such materials unless you consent to receiving them again.
Who do we share your information with?
We may share your personal information with our related companies and third parties with whom we have a business relationship including but not limited to:
- if we provide you with credit insurance, your lender;
- external dispute resolution bodies and government authorities;
- related entities to which we outsource information technology, governance and business support functions;
- organisations who offer or manage mortgage or finance brokers who are our Authorised Representatives (usually termed ‘aggregators’) for the purpose of monitoring and supervising compliance;
- specialist advisers such as accountants and solicitors (both yours and ours);
- if you hold consumer credit insurance with life insurance, we may share your information with the life insurer for the purpose of renewing your policy or in assisting you to make a claim on the life cover. Your PDS identifies your life insurer.
You should be aware that the recipients of your information have their own privacy policies explaining how they collect, hold and use your information.
Do we send your information overseas?
We share your information with our service providers who use cloud servers located overseas to store your information, and our related entities overseas perform operational or administrative services on our behalf.
Countries we may send personal information to include New Zealand, the United States, United Kingdom, Singapore, Japan and countries in the European Union. These countries have laws that protect privacy offering similar standards of privacy protection to Australia.
If you are considering employment with us, we may share your information to our related entities in New Zealand.
How can you access your information?
You may request access to your personal information at any time. We will respond to you within 30 days of receiving your request.
In most cases we will facilitate access by providing you with copies of or a summary of relevant documents. However we may decide that other means of providing you with access are more appropriate based on the circumstances of your request.
We are not required to provide you with access to your personal information in certain circumstances, such as where your request is frivolous or vexatious, or where providing access would unreasonably interfere with another person's privacy, would be a breach of the law, or where the information you request is not relevant, commercially sensitive or relates to existing or anticipated legal proceedings. If we refuse access, we will advise you in writing of our reasons for doing so and the mechanisms available for you to make a complaint.
What if your information is inaccurate?
Once we collect your personal information, we will take steps to keep it accurate, complete and up-to-date.
If you request, or if we believe that the personal information we hold about you is inaccurate, out-of-date, incomplete or misleading, we will take reasonable steps to correct your information. We will respond to your request for correction within a reasonable period of receiving your request. We will not charge you for making a request if we correct your information.
If we have previously disclosed your personal information to another entity, you may ask that we notify the other entity of the correction. We will notify the particular entity you have identified in your request provided it is not impracticable or unlawful for us to do so.
If we refuse the correction, we will advise you in writing of our reasons for doing so and the mechanisms available for you to make a complaint. If we refuse to correct your personal information, you may request that we associate your information with a statement that the information is inaccurate, out-of-date, incomplete or misleading. We will take reasonable steps to associate the statement in an appropriate way.
You may make a request for access or correction by contacting our Privacy Officer using the details below.
How do we protect your information?
We take steps to protect personal information from misuse, interference, loss and unauthorised access. Some of these steps include physical security such as locks and access control to our premises and computer security including requiring passwords and other security measures for accessing our systems and databases, as well as having information security policies that our staff and Authorised Representatives must follow.
You can also help us keep your personal information secure by ensuring that any password you use to access our systems is kept strictly confidential and by logging off when you have finished using a shared computer. We will not be responsible for any access or change made to your personal information occurring as a result of you disclosing your password to a third party or through any unauthorised access..
How do we protect your information?
We are committed to providing applicants, customers, and other parties whose personal information we hold, a fair and responsible system for the handling of their complaints..
If at any time you have any complaints in relation to privacy, please contact our Privacy Officer at one of the points referred to in this policy. We will seek to address any concerns that you have through our complaints handling processes and, in most cases, will respond within 30 days of receiving your complaint.
If we are unable to resolve your complaint to your satisfaction you may refer your concerns to the Australian Financial Complaints Authority (AFCA) or the Office of the Australian Information Commissioner (OAIC).
How to contact our Privacy Officer
How to contact the AFCA
How to contact the OAIC