We’re committed to protecting the privacy of your personal information in accordance with the Privacy Act 1988 and the Australian Privacy Principles, and in accordance with the Life Insurance Code of Practice (the Code) on behalf of our insurers.
Collecting your personal information
We only collect personal information that is reasonably necessary for our functions or activities. These functions and activities are conducted by us and our partners on behalf of the insurers and trustees for the product or service you have applied for or which we have provided to you, and may include:
- establishing your identity
- underwriting and assessing an application for an insurer’s product
- administering insurance plans including sending of renewal notices, statements and other information
- assisting the insurer or trustees with claims management
- providing information and services to assist financial advisers to work with us
- responding to enquiries and providing information about the products we administer and our services
- developing and improving the products we administer and our services
- complying with our legal obligations such as taking measures to identify and prevent fraud
- meeting our legal obligations and co-operating with Government, law enforcement agencies and regulators; and
- for any other permissible purpose identified at the time of collection.
What personal information do we collect?
The kinds of personal information that we may collect and hold can include:
- name, contact details (including address, email, phone number)
- date of birth and gender
- personal information which is required to acquire a product or service through us and as may be needed during the lifecycle of that product or service
- information required to assess or underwrite an application for an insurer’s product or a claim
- information about beneficiaries and nominated representatives, employment and income
- financial details such as your tax file number and bank account details, superannuation fund(s) and other life insurance policy information
- sensitive information (see ‘Sensitive information’ section below)
- any other information we believe is necessary for you to acquire the products we administer and our services and for us to provide services to you, including notes and opinions made by us or our service providers.
Where we collect, use or disclose your tax file number, Medicare number or other government related identifiers, we do so where we’re required or authorised by or under the law to do so. We’ll take special measures to protect government related identifiers to ensure they’re not used in order to identify you.
We recognise that certain information about you is sensitive.
“Sensitive information” is defined in privacy legislation as information about a person’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or practices, criminal record, health, and certain genetic or biometric information.
The sensitive information that we mostly require is health and health-related information, such as genetic and lifestyle information, so that we can accurately assess life and health risks for the insurers of the products we administer, as well as providing the insurers and trustees information related to claims.
How we collect your personal information
We generally collect your personal information from you directly when you provide it to us with your authority to use a product or service.
We may also collect your information from other parties that work with us regarding the product or service that you have applied for or which we have provided to you. These parties include, but are not limited to, a financial adviser, insurers or reinsurers, our service providers and business partners, employers to verify employment details for income protection claims, doctors and health practitioners, government, statutory or regulatory bodies, market research organisations, organisations who provide document verification services, and anyone you have provided your authorisation to deal with us.
We may collect information about you because we’re required or authorised by law to collect it. There are laws that affect financial institutions, including company and tax law, which require us to collect personal information.
You can withdraw your permission at any time by contacting us, but please note that if you don’t permit us to collect, use and/or disclose your personal information we may be unable to provide you with the products we administer or our services.
As we’re a financial services company, we generally need sufficient information to identify you before we can provide you with any of the products we administer and most of our services. However, you can deal with us anonymously or use a pseudonym in limited circumstances, such as to obtain an indicative quote as a potential customer or to obtain general information about the products we administer or our services.
Disclosing your personal information
We may disclose your personal information to other parties, as permitted by law, though only in respect of the product or service you have applied for or which we have provided to you, including:
- insurance companies and reinsurers
- people authorised to act on your behalf, including your financial advisers
- superannuation trustees and administrators
- service providers who assist us with providing the products we administer and our services including:
- medical practitioners, medical occupational experts and other allied health professionals
- claims assessors and investigators
- our lawyers, valuers and contractors
- other financial institutions, such as auditors and accountants
- dispute resolution bodies
- information technology providers and administration services, mailing houses and marketing organisations
- government, statutory or regulatory bodies
- law enforcement bodies and tax authorities
- organisations who assist us to review and improve the products we administer, as well as our services and systems.
We will not disclose your personal information to parties not associated with the product or service that you have applied for or which we have provided to you. This includes not providing the information provided to us under an application for insurance for one insurer’s product to the insurer of another product administered by us.
Disclosing your personal information outside of Australia
Our core business and our partner companies are primarily located in Australia. However, depending on the product or service you have applied for, or we have provided to you, we may share and store your personal information with parties that are located outside of Australia. Currently, these include companies with operations located in the United States of America and the United Kingdom.
When we share your information with companies with operations overseas, we take reasonable precautions to protect your personal information and we remain ultimately responsible for your privacy security.
Accessing and updating your personal information
We take reasonable steps to ensure that the personal information we collect is accurate, up to date and complete. You have the right to access and update the personal information we hold about you at any time, subject to any legal restrictions or exemptions, by contacting us on the ‘contact us’ details listed below. This includes at application stage, and at the time of any claim or complaint. You can also access any reports we’ve received from independent service providers that we’ve relied upon in assessing your application, claim or complaint.
Before discussing and releasing personal information to you, we need to confirm your identity in order to protect your personal information. To do that, we may ask for appropriate proof of identification or ask you a series of identity questions. We may also charge you a reasonable fee to correct or access your personal information, such as for photocopying fees. If you request any of your plan documentation from us, we’ll provide this to you promptly and (if requested) electronically.
Generally, we’ll provide access to and/or correct the information we hold about you unless:
- we consider there is a good reason under the Privacy Act 1988 or other relevant law to refuse your request;
- we reasonably determine that your information should be provided directly to your doctor, instead of to you;
- the release of the information may be prejudicial to us in relation to a dispute about your insurance cover or your claim, or in relation to a complaint; or
- we reasonably believe the information is commercial-in-confidence.
If we don’t agree with you that the information we hold should be accessed or corrected, and we will not disagree unreasonably, we’ll let you know the type of information withheld and the reasons in writing. We’ll also provide details of our complaints process should you wish to take the matter further.
If there are delays from third parties in obtaining permission to release information to you – which exceed any time frames we’ve given you or under the Code – we’ll let you know before the end of that time frame.
Storing and protecting your personal information
We store your personal information in a number of ways such as on secure servers and in electronic and paper form.
The security of your personal information is important to us and we take reasonable precautions to prevent unauthorised access, modification or disclosure, loss or misuse. We have a robust security environment supported by a range of physical and digital precautions and policies that we regularly review and test. Our security measures include firewalls, encryption and secure socket layer technology.
Where we no longer require your personal information, we’ll take reasonable steps to destroy or permanently de-identify that information. However, there are legal and regulatory obligations and precedents to retain records about customers for certain periods of time and for this reason we may refuse to permanently delete some or all of your personal information if you ask us to.
Usage of cookies on our websites
Cookies are designed to help personalise your experience of our websites and can also help us learn about how people use our website to improve the products we administer and our services.
Some of the information we collect on our website, such as your location or activity, IP address and device identifiers, is collected using cookies. You can choose to accept or disable cookies using your computer settings; however, this may impact your personalised experience of our website.
We analyse the personal information we collect to improve the products and services we administer. Subject to our marketing and insurers’ rules, we may tell you about other products and services that we consider may be of interest to you. We may disclose your personal information to other companies who help us market these products and services. If you don’t wish to receive information on other products and services offered by or through us, you may opt out of receiving marketing communication by contacting us.
If you have a complaint about how we handle personal information we’d like an opportunity to make it right. Please contact us on the details below to share with us your concerns and we’ll work with you to resolve the issue.
If you’re not satisfied with the resolution of your complaint, then you can raise your concern with the Office of the Australian Information Commissioner at oaic.gov.au/privacy or by calling 1300 363 992.
For general inquiries or to obtain copies of records or make a complaint to our privacy officer.
Call us: 1300 090 188
Email us: firstname.lastname@example.org
Write to us: The privacy officer, NEOS Life, GPO Box 239, Sydney, NSW 2000
Last updated: 28 April 2022