Committed to protecting your privacy
In this Privacy Policy:
- “we”, “our” and “us” means Elkington Bishop Molineaux Insurance Brokers Pty Ltd (EBM), along with all companies in the EBM group of insurance companies and third parties who provide services to us or on our behalf.
- “you” and “your” refers to anyone using our services or providing information to us.
We are committed to protecting your privacy
We are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) as amended, replaced or superseded from time-to-time. The below information describes our current policies and practices in relation to the collection, handling, use, disclosure and transfer of personal and other information. It also deals with how you can complain about a breach of the privacy laws, how you can access the personal information we hold and how to have that information corrected.
Personal Information is information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not.
- whether the information or opinion is recorded in a material form or not.
It includes Sensitive Information as defined in the Privacy Act which includes, amongst other things, information about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information or templates.
What kind of information do we collect and hold?
We ask you for the information that is reasonably necessary to offer, provide and administer our services and/or products. This can include a broad range of information ranging from your name, address, contact details or age to other information about your personal affairs including your assets, personal belongings, financial situation, insurance and claims history and payment information. Sensitive information we may collect generally includes criminal record, health information and membership of a professional or trade association.
How we collect personal information?
We only collect personal information by lawful and fair means and where it is reasonably necessary for, or directly related to, one or more of our functions or activities. Unless it is unreasonable or impracticable for us to do so, or as provided otherwise under this Privacy Policy, we will collect your information directly from you or your agents. If we collect details about you from someone else, we will, take reasonable steps to make you aware of the collection in accordance with the APPs.
We may collect personal information indirectly and who it is from can depend on the circumstances. We will usually obtain it from related bodies corporate, referrals, your previous insurers or insurance intermediaries, witnesses to claims, health care workers, publicly available sources, premium funders and persons who we enter into business alliances with. We attempt to limit the collection and use of sensitive information from you unless we are required to do so in order to carry out the services provided to you. However, we do not collect sensitive information without your consent.
What are the purposes for which we collect, hold, use and disclose information?
The primary purpose for collecting, holding, using and disclosing your information is to enable us to provide our services to you or where reasonably necessary for or directly related to our services or one or more of our functions and activities and to meet any obligations we have at law. This includes insurance broking services, insurance intermediary services, funding services, claims management services and risk management and other consulting services.
We do not use or disclose personal information for any purpose that is unrelated to our services and that you would not reasonably expect (except with your consent).
We use information we collect to develop, identify and offer products and services that may interest you, conduct market or customer satisfaction research. From time to time, we may seek to develop arrangements with other organisations that may be of benefit to you in relation to promotion, administration and use of our respective products and services. We do not use sensitive information to send you direct marketing communications without your express consent.
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, or we think will be of interest to you. 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.
We may use your information internally to help us improve our services and help resolve any problems.
If we do propose to disclose or use your personal information other than for the purposes listed above, we will first seek your consent prior to such disclosure or use.
If we give third parties (including their agents, employees and contractors) your personal information, we require them to only use it for the purposes we agreed to.
We usually disclose personal information to third parties who assist us or are involved in the provision of our services and your personal information is disclosed to them only in connection with the services we provide to you or with your consent. We may also disclose it for direct marketing purposes explained in more detail further below.
The third parties can include our related companies, our agents or contractors, insurers, their agents and others they rely on to provide their services and products (e.g. reinsurers), premium funders, other insurance intermediaries, insurance reference bureaus, loss adjusters or assessors, medical service providers, credit agencies, lawyers and accountants, prospective purchasers of our business and our alliance and other business partners.
In the future we may consider the sale or restructure of our business or the purchase of the business of others. In such circumstances it may be necessary for your information to be disclosed to permit the parties to assess the sale or restructure proposal for example through a due diligence process. We will only disclose such of your personal information as is necessary for the assessment of any sale or restructure proposal and subject to appropriate procedures to maintain the confidentiality and security of your personal information. In the event that sale or restructure proceeds, we will advise you accordingly.
Any third parties we disclose information to are prohibited from using your information except for the specific purpose for which we supply it to them, and we take such steps as are reasonable to ensure that they are aware of the provisions of this Privacy Policy in relation to your personal information.
Any information provided to us may be transferred to, and stored at, a destination outside Australia, including the United Kingdom. Details of the countries we disclose to may change from time to time. You can contact us for details. Information may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.
When we send information overseas, in some cases we may not be able to take reasonable steps to ensure that overseas providers do not breach the Privacy Act, and they may not be subject to the same level of protection or obligations that are offered by the Act. By proceeding to acquire our services and products you agree that you cannot seek redress under the Act or against us (to the extent permitted by law) and may not be able to seek redress overseas. If you do not agree to the transfer of your personal information outside Australia, please contact us.
What if you don’t provide some information to us?
If you do not provide the personal information requested and/or do not provide us with your consent to collecting, holding, using or disclosing your personal information as set out in this Privacy Policy, we may not be able to provide our services or products (for example, your insurance application may not be accepted) or you may be in breach of your duty regarding disclosure to insurers or a claim may not be paid. If you do not provide the required personal information or consent, we will explain what the impact will be.
What do we expect of you when you provide us with personal information about another person?
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, how we collect, use, disclose and handle it in accordance with this Privacy Policy and our relevant Privacy Statements. If it is sensitive information, we rely on you to have obtained their consent to the above.
If we give you personal information, you must only use it for the purposes we agreed to.
Unless otherwise agreed, you must meet the requirements of the Privacy Act, 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 you have not done or will not do these things, you must tell us before you provide us with the relevant information.
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 in coded files and coded computer records in secure offices and records management storage facilities. 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 having secure offices and facilities and coded records. Our computer system has sound safeguards such as network and communications security restricting unauthorised access. We maintain physical security over our paper and electronic data and premises, by using locks and security systems.
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, out of date or incomplete.
If you wish to access or correct your personal information, please write to your Account Manager and / or EBM’s Privacy Officer.
We do not charge for receiving a request for access or for correction of personal information but in some cases, we may impose a charge to cover our reasonable expenses incurred in providing access to you.
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.
Website data
Anonymous data
We use technology to collect anonymous information about the use of our website, for example when you browse our website our service provider may log 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 customers and markets and to improve our services.
Cookies
In order to collect this anonymous data, we may use “cookies”. Cookies are small pieces of information which are sent to your browser and stored on your computer’s hard drive. Sometimes they identify users where the website requires information to be retained from one page to the next. This is purely to increase the functionality of the site. Cookies by themselves cannot be used to discover the identity of the user. Cookies do not damage your computer, and you can set your browser to notify you when you receive a cookie so that you can decide if you want to accept it. Once you leave the site, they may allow the website to recognise your computer when you return in the future.
Our standard online applications are stored on a password protected website and the application itself goes by email to EBM team members to process. The information is only used for the purpose it is intended and does not contain any payment details, or sensitive information. It collects only the information required to take out a policy. Payment is made separately either manually or at a later date via our payment gateway. The online payments are made via a secure Ebix page. Ebix use a high-grade encryption system to transmit data over the internet.
Encryption makes it very difficult for unauthorised people to view information travelling between computers. It is therefore very unlikely that anyone read this page as it travelled across the network.
What happens if you want to complain?
If you have any questions or concerns about whether we have complied with the Privacy Act or this Privacy Policy when collecting or handling your personal information, please write to EBM’s Privacy Officer.
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.
Post:
Attention Privacy Officer
Elkington Bishop Molineaux Insurance Brokers Pty Ltd
PO Box 1065
WEST PERTH WA 6872
Phone: 1300 755 112
If you feel that your complaint has not been resolved, then you can contact the Office of the Australian Information Commissioner (OAIC) at:
Post: GPO Box 5218
Sydney NSW 2001
Email: enquiries@oaic.gov.au
Phone: 1300 363 992
Your consent
By asking us to assist with your insurance needs, you consent to us acting in accordance with the Privacy Policy.
