Jardine Lloyd Thompson Pty Ltd (and its subsidiaries and related entities) (JLT) respects the privacy of personal information that it collects and is committed to managing that information in a responsible manner.
We ensure to the extent possible that our agents and service providers are aware of our and their respective obligations under the Privacy Act.
NPP 1 Collection
We will only collect and hold personal information that is necessary for us to have to attend to your insurance, risk management and related needs. This will include such information as your name, age, address, contact details, gender, employment, income, health and medical history, insurance and claims history, information about the subject matter of the insurance, credit card details and other relevant information.
Usually, we will collect the personal information directly from you. Sometimes, we may collect the information from other parties, such as your employer (eg. for Group insurance policies) or from medical practitioners or insurers when arranging your insurance or submitting an insurance claim.
Where practical, you will be advised of the purpose for which we are collecting the information.
NPP 2 Use and Disclosure of Personal Information
We only use and disclose your personal information in accordance with the terms of the Privacy Act.
We use the personal information collected principally for the purpose of assessing and advising you on your insurance needs, approaching the insurance/reinsurance market and placing your insurance, handling insurance claims or for risk management. This may include identifying and providing you with information about other products or services that may help you to understand and make decisions about your insurance, risk management and related needs. Where necessary, we may disclose information about you to third parties. For example, information may be provided to insurers, reinsurers, insurance intermediaries, service providers, finance providers, consultants, advisers, agents and JLT related entities. If you are proposing for insurance or renewing insurance, relevant or material information must be disclosed to the insurer under your legal duty of disclosure (for this purpose a special Duty of Disclosure notice will be provided to you).
NPP 3 Data Quality
We endeavour to ensure that information we hold about you is accurate, complete and up-to-date whenever we collect, use or disclose it.
We will provide you with copies of insurance policies, schedules, benefit statements, renewal notices and invoices that show many of the items of primary information that we hold, and give you the opportunity to identify any incorrect information. It is therefore important that you check these insurance documents carefully. In some instances, you (or another party on your behalf) will be asked to complete insurance declarations annually to update information.
To assist us to keep your personal information accurate and up-to-date, please also advise us of any changes as they occur.
NPP 4 Data Security
Your personal information is held securely and we take steps to protect it from misuse and loss, and from unauthorised access, modification or disclosure. Some of these steps include:
- Physical access controls to the information where information is kept
- Computer and network security including password and other electronic protection
- Our employees and data processors are obliged to respect the confidentiality of personal information we hold
- Training of staff on information handling processes
- Secure off-site storage and audited disaster recovery practices
We only retain information that is necessary and relevant to our operations. We retain most information relating to you for at least seven years in order to meet legal and business requirements. Once information is no longer required, we arrange for it to be destroyed in a secure manner.
NPP 5 Openness
NPP 6 Access & Correction
You have a right to access any personal information that we hold about you on written request, unless one of the exceptions in the NPPs applies. A reasonable charge may apply to gain access to information. You will be advised of any charges that may apply when you make a written request.
If you establish that information held is not accurate, complete or up to date, then we will take reasonable steps to correct the information.
Should you wish to access your personal information, please direct your request to your account executive or our Privacy Officer. You may be required to provide suitable identification to enable us to protect the security and privacy of your personal information.
NPP 7 Identifiers
We will not use any personal identifiers issued by a government agency (eg. Tax file number or Medicare number) as an identifier in our records systems. Should legislation requires us to ask you to provide your tax file number, we will only use that number for the purposes permitted by legislation and not as a general means of identifying you.
NPP 8 Anonymity
Our operational and legal obligations will generally require that you identify yourself to us in order for us to provide insurance broking and risk management services to or on your behalf.
NPP 9 Transborder (Overseas) Information Flows
In the ordinary course of business, it may be necessary for us to disclose personal information about you to a person or organisation in a foreign country. (eg. to overseas insurers/reinsurers and JLT related entities) We will only do this if:
- We reasonably believe that the foreign country has substantially similar privacy obligations; or
- You consent; or
- The obtaining of your consent is impractical but the disclosure is for your benefit and you would be likely to give your consent; or
- We have taken reasonable steps to ensure the recipient will not hold, use or disclose the information in a manner inconsistent with the NPPs
NPP 10 Sensitive Personal Information
We will only collect sensitive information (eg. medical and health information) if you consent or other requirements under the Privacy Act have been met.
WHAT WE EXPECT OF YOU AND THIRD PARTIES WE DEAL WITH
When you provide us with personal information about other individuals, we rely on you to have made them aware that you will or may provide their information to us, the purposes we use it for, the types of third parties we disclose it to and how they can access it (as described in this document). If it is sensitive information we rely on you to have obtained their consent to the above. If you have not done either of these things, you must tell us before you provide the relevant information.
If we give you personal information, you and your representatives must only use it for the purposes we agree to.
Where relevant, you must meet the requirements of the NPPs when collecting, using, disclosing and handling personal information on our behalf;
You must also ensure that your agents, employees and contractors meet the above requirements.
If we send you any information about services or products, or you do not want us to disclose your personal information to any other organisation in this context (including related bodies corporate) you can opt out by contacting your account executive or our Privacy Officer.
Complaints or Concerns
If you have any complaints or concerns about privacy matters, please advise our Privacy Officer in writing as follows:
C/- The Privacy Officer, Jardine Lloyd Thompson Pty Ltd
Level 37, Grosvenor Place, 225 George Street, SYDNEY NSW 2000
Telephone: (02) 9290 8000
Further Information About the Privacy Act
For further information, you can contact The Office of the Privacy Commissioner, or visit their website on http://www.privacy.gov.au or read the National Privacy Principles at http://www.privacy.gov.au/publications/npps01.html
In accordance with the Privacy Act 1988 (and subsequent amendments), we, Jardine Lloyd Thompson Pty Ltd (and our subsidiaries and related entities) (JLT) draw your attention to the following:
- We may collect personal information about you by means of the online application form.
- We are collecting the information principally for the purpose of approaching the (re)insurance market, placing insurance, assessing and advising you on your insurance needs, claims handling or risk management (depending on your requirements). Other purposes include providing you with information about other JLT products or services. If you are proposing for or renewing insurance, the information is required pursuant to your duty of disclosure under the Insurance Contracts Act 1984, the Marine Insurance Act 1909 or at common law.
- The information we collect may be disclosed to third parties including but not limited to (re)insurers, insurance intermediaries, service providers, finance providers, advisers, agents and JLT related Group companies.
- Your personal information may be sent to our administrative processing centre in Mumbai (India), Kuala Lumpur (Malaysia) and to other JLT Group companies, insurers, reinsurers and other third party service providers (e.g. data storage providers) in the United Kingdom, Singapore, Hong Kong, the United States of America and elsewhere.
Jardine Lloyd Thompson Pty Ltd Level 37, Grosvenor Place, 225 George Street, Sydney NSW 2000
Telephone: (02) 9290 8000