The Privacy Act 1988 (Cth) contains Australian Privacy Principles (APPs) that apply to the collection, use, disclosure and handling of personal information.
This privacy notice is provided on behalf of Swiss Re Life & Health Australia Ltd (SRLHA) and Genus Life Insurance Services Pty Ltd (Genus), for the purpose of informing you how they (and the parties set out in this notice) collect, use, disclose and handle personal information as part of the management of the remediation program and the other activities described below.
What is the Remediation Program?
Freedom Insurance Pty Ltd (Freedom Insurance) was the distributor of life insurance products issued by SRLHA (from February 2017 to October 2018), NobleOak Life Ltd (NobleOak) (from April 2014 to February 2017) and AIA Australia Ltd (AIA) (from October 2010 to April 2014). Freedom Insurance Administration Pty Ltd was the administrator of all of these policies. Freedom Insurance suspended the sale of all new policies in October 2018.
In December 2018, Freedom Insurance Group Ltd (Freedom), the parent company of the other Freedom entities, announced that ASIC had commenced an investigation into the conduct of Freedom entities which had been highlighted at the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry. SRLHA subsequently agreed to assume responsibility for designing and managing a remediation program to address the conduct of the Freedom entities.
Service providers for the Remediation Program
Genus and NobleOak Services Limited (NOS) have been engaged by SRLHA, NobleOak and AIA (Insurers) to provide administration services for the remediation program. Computershare Communication Services Pty Limited (Computershare) has been engaged by SRLHA to provide communication services for the remediation program. Deloitte Touche Tohmatsu (Deloitte) has also been engaged by SRLHA to maintain the remediation program website and to provide consulting services and carry out the remediation program.
How is your personal information being collected?
Personal information may be collected on behalf of one or more of the Insurers by service providers engaged to provide services to the remediation program, including Genus and Deloitte.
Your personal information may be collected in a number of ways, including via:
- the remediation program website;
- the help line for the remediation program; or
- email or other correspondence.
The personal information collected may include:
- your full name and personal identity information such as date of birth, email address and physical address;
- current and previous insurance policy details such as reference and policy numbers;
- information required to process remediation program payments, such as your bank details; and
- other personal information to conduct identity checks, assess eligibility for the remediation program, or to process claims.
As part of verifying your identity for the remediation program, you will also need to provide personal information via 'greenID', a third party service provided by Vix Verify Pty Ltd (greenID). When you submit information to greenID via the remediation program website, it is used for the purpose of verifying your identity in accordance with the relevant database service for the type of identity document selected. Neither greenID nor the Insurers collect a copy of the verification documentation that you submit. greenID may retain information such as name, date of birth and your user id or code. The Insurers do not control greenID's use of this information.
GreenID provides Genus (as administration service provider) on behalf of the Insurers with verification of your identity based on this process, which may include some personal information, such as the type of identity documents you used to verify your identity.
If you provide information (including government-issued verification documents and references) to the remediation program help line (including via email) as part of identity verification, the information will be collected and retained by Genus (as administration service provider) on behalf of the Insurers and is subject to this privacy notice. This information may be provided to greenID on your behalf in the same way as information submitted via the remediation website in accordance with greenID's privacy notice and terms.
Purpose of collection
Your personal information is being collected for the purpose of:
- verifying your identity;
- making decisions in relation to your entitlement under the remediation program;
- communicating with you;
- dealing with complaints;
- complying with legal and regulatory obligations; and
- managing the remediation program.
The third party service providers who are involved in the management and administration of the remediation program, as well as NobleOak and AIA, will also use your personal information to assist SRLHA with these functions. In particular, Genus and NOS will collect and use your personal information when they perform these functions for SRLHA.
What happens if your personal information is not collected
If you do not provide your personal information, the Insurers may be unable to confirm your identity, or SRLHA may otherwise be prevented from processing your compensation payment under the remediation program.
How is personal information disclosed?
In addition to use by service providers for the remediation program, your personal information may be disclosed to:
- NobleOak and AIA in connection with their role in the remediation program;
- related companies who may assist SRLHA in relation to the remediation program;
- agents and third party service providers who assist the Insurers, Genus and NOS in relation the remediation program, including lawyers and other advisors, and auditors;
- third party service providers who perform functions or services on behalf of an Insurer in the administration of Freedom policies/plans; and
- where required by law
No disclosure of your personal information collected in relation to the remediation program is made to recipients located overseas
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