Privacy & Data Protection Policy
What information do we collect and how do we use it?
When we arrange insurance on your behalf, we ask you for the information we need to advise you about your insurance needs and management of your risks. This can include a broad range of information ranging from your name, address, contact details, age and other information about your personal affairs including your assets, personal belongings, financial situation, health and wellbeing. We provide any information that the insurers or intermediaries who we ask to quote for your insurances and premium funding require to enable them to decide whether to insure you and on what terms or to fund your premium and on what terms.
Insurers may in turn pass on this information to their reinsurers. Some of these companies are located outside Australia. For example, if we seek insurance terms from an overseas insurer (e.g. Lloyd’s of London), your personal information may be disclosed to the insurer. If this is likely to happen, we inform you of where the insurer is located, if it is possible to do so.
When you make a claim under your policy, we assist you by collecting information about your claim. Sometimes we also need to collect information about you from others. We provide this information to your insurer (or anyone your insurer has appointed to assist it to consider your claim, eg loss adjusters, medical brokers etc) to enable it to consider your claim. Again this information may be passed on to reinsurers.
From time to time, we will use your contact details to send you direct marketing communications including offers, updates and newsletters that are relevant to the services we provide. We always give you the option of electing not to receive these communications in the future. You can unsubscribe by notifying us and we will no longer send this information to you.
What if you don’t provide some information to us?
We can only fully advise you and assist in arranging your insurance or with a claim, if we have all relevant information. The insurance laws also require you to provide your insurers with the information they need in order to be able to decide whether to insure you and on what terms. You have a duty to disclose the information which is relevant to the insurer’s decision to insure you.
When do we disclose your information overseas?
Howden Insurance Brokers (Australia) Pty Ltd is owned by Howden Group Limited (UK). We may share your personal data with Howden Group Limited and other Howden Group Companies in order to identify any other services which the Howden Group offers and may be of interest to you (where we have appropriate permission).
If you ask us to seek insurance terms and we recommend an overseas insurer, we may be required to disclose the information to the insurer located outside Australia. For example, if we recommend a policy provided by Lloyd’s of London, your information may be given to the Lloyd’s broker and underwriters at Lloyd’s of London to make a decision about whether to insure you.
We will tell you at time of advising on your insurance if they are overseas and in which country the insurer is located. If the insurer is not regulated by laws which protects your information in a way that is similar to the Privacy Act, we will seek your consent before disclosing your information to that insurer.
Australian and overseas insurers acquire reinsurance from reinsurance companies that are located throughout the world so in some cases your information may be disclosed to them for assessment of risks and in order to provide reinsurance to your insurer. We do not make this disclosure. This made by the insurer (if necessary) for the placement of their reinsurance program.
We may also disclose information we collect to the providers of our policy administration and broking systems that help us to provide our products and services to you. These policy administration providers and broking systems may be supported and maintained by organisations in New Zealand, the Philippines and Vietnam and your information may be disclosed to those organisations. Please note that the Privacy Act and Australian Privacy Principles may not apply to these organisations.
How do we hold and protect your information?
We strive to maintain the reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
We hold the information we collect from you initially in a working file, which when completed is electronically imaged and stored, after which any paper is destroyed in our onsite shredder. In some cases, your file is archived and sent to an external data storage provider for a period of time. We only use storage providers located in Australia who are also regulated by the Privacy Act.
We ensure that your information is safe by protecting it from unauthorised access, modification and disclosure. We maintain physical security over our paper and electronic data and premises, by using locks and security systems. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to computer systems where your information is stored.
Will we disclose the information we collect to anyone?
We do not sell, trade, or rent your personal information to others.
We may need to provide your information to contractors who supply services to us, e.g. to handle mailings on our behalf, external data storage providers or to other companies in the event of a corporate sale, merger, re-organisation, dissolution or similar event. We may also disclose information we collect to the providers of our policy administration and broking systems that help us to provide our products and services to you. However, we will take reasonable measures to ensure that they protect your information as required under the Privacy Act.
We may provide your information to others if we are required to do so by law, you consent to the disclosure or under some unusual other circumstances which the Privacy Act permits.
How can you check, update or change the information we are holding?
Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate, irrelevant, out of date or incomplete.
If you wish to access or correct your personal information please write to the Privacy Officer at Howden Insurance Brokers (Australia) Pty Ltd, Bligh House, 4-6 Bligh St, Sydney NSW 2000, or by email to [email protected]
We do not charge for receiving a request for access to personal information or for complying with a correction request. Where the information requested is not a straightforward issue and will involve a considerable amount of time then a charge will need to be confirmed for responding to the request for the information.
In some limited cases, we may need to refuse access to your information or refuse a request for correction. We will advise you as soon as possible after your request if this is the case and the reasons for our refusal.
What happens if you want to complain?
Your complaint will be considered by us through our internal complaints resolution process and we will try to respond with a decision within 30 days of you making the complaint.
By asking us to assist with your insurance needs, you consent to the collection and use of the information you have provided to us for the purposes described above.
Website information and content
The information provided on this website does not cover all aspects of the law on the relevant subject matter. Professional advice should be sought before any action is taken based upon the matters described and discussed on this site.
To the extent permitted by law, we make no representations about the suitability of the content of this site for any purpose. All content is provided without any warranty of any kind. We disclaim all warranties and conditions with regard to the content, including but not limited to all implied warranties and conditions of fitness for a particular purpose, title and non-infringement.
We will not be liable for any damages or injury caused by, including but not limited to, any failure of performance, error, omission, interruption, defect, delay in operation of transmission, computer virus, or line failure. To the extent permitted by law we will not be liable for any damages or injury, including but not limited to, special or consequential damages that result from the use of, or the inability to use, the materials in this site.
We believe the content of this site to be accurate, complete and current, however there are no warranties as to the accuracy, completeness or currency of the content. It is your responsibility to verify any information before relying on it. The content of this site may include technical inaccuracies or typographical errors.
We reserve the right to modify the content of this site from time to time.
We use technology to collect anonymous information about the use of our website, for example when you browse our website our service provider logs your server address, the date and time of your visit, the pages and links accessed and the type of browser used. It does not identify you personally and we only use this information for statistical purposes and to improve the content and functionality of our website, to better understand our clients and markets and to improve our services.
In order to collect this anonymous data we may use “cookies”. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to record some aspects of a website and to provide information to the owners of the website. Our cookies do not store personal information or obtain information about you, your family, or read any material on your hard drive. You can adjust the settings in your web browser to determine whether sites can set cookies on your computer. You can also manage what cookies we set when you visit our website.
Our Website allows visitors to submit information via Self-Service forms (Claim Forms, Employment and Contact request). The information submitted via the Forms is not encrypted – an option is available for claim forms to be downloaded in PDF format for faxing. Should you be concerned about confidentiality of the claim information, this would be the recommended method.
Information collected via online forms is sent to our offices via email (not encrypted) and is also stored on a database which is accessible by Howden Insurance Brokers (Australia) Pty Ltd staff only (password protected).
We also use your information to send you requested product information and promotional material and to enable us to manage your ongoing requirements, e.g. renewals, and our relationship with you, e.g. invoicing, client surveys etc.
We may use your personal data to send you direct marketing communications about our insurance products or our related services. This may be in the form of email, post, SMS, telephone or targeted online advertisements. We limit direct marketing to a reasonable and proportionate level, and to send you communications that we believe may be of interest or relevance to you, based on the information we have about you. If you would rather not receive this information or do not wish to receive it electronically, please email or write to us.
We may use your information internally to help us improve our services and help resolve any problems.
Tell us what you think
We welcome your questions and comments about privacy. If you have any concerns or complaints, please contact the Privacy Officer on 1300 904 503 or by email [email protected]
Appendix 1 - CATEGORIES OF PERSONAL DATA
Details of information that we typically capture
Name, address, telephone number, email address.
Policy number, relationship to the policyholder, details of policy including insured amount, exceptions etc., previous claims, voice recordings
Personal Risk Information
Gender, date of birth, claims history
Special Categories of Data
Health Data - e.g. physical and mental conditions, medical history and procedures, relevant personal habits (e.g. smoking)
Criminal Data - e.g. driving offences, unspent convictions
Data relating to children
Name, email address, interests / marketing list assignments, record of permissions or marketing objections, website data (including online account details, IP address), company name, company address, phone number and job title
(excluding third party claimants)
Policy number, relationship to the policyholder/Insured Person, details of policy including insured amount, exceptions etc., previous claims, voice recordings
Details of incident giving rise to claim, including
Health Data - e.g. details of injury, medical report
Criminal Data - e.g. driving offences, police reports
Data relating to minors
Bank account details used for payment
Address, history of fraudulent claims, details of incident giving rise to claim
Criminal Data - e.g. unspent convictions