Privacy Policy

Privacy This Privacy Policy sets out how Insurance & Membership Services Limited, ABN 59 057 159 743 (IMS) collects, stores, uses and discloses personal information. IMS is committed to protecting your privacy in accordance with the Privacy Act 1988, the Health Records and Information Privacy Act 2002, and regulations and policies thereunder. This policy describes our current policies and practices in relation to the handling and use of personal information. Where required by law, we will provide you privacy information (in the form of a Privacy Notice or other privacy disclosure documentation) specific to the products or services you want to obtain from us or specific to your dealings with us. What is ʻpersonal informationʼ? 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; and
• whether the information or opinion is recorded in a material form or not.

What kinds of personal information do we collect and hold? The personal information collected and maintained by IMS generally includes your name, date of birth, gender, address, contact details and information specific to the product or service you decide to purchase from us, such as details of any property being insured, or your dealings with the specific IMS business. For some policies, we also collect and maintain your sensitive information. This includes information about your health, genetics, membership of any trade unions or professional associations and any criminal convictions you may have. For employment applications, we collect your name, address, contact details, current and past employment information, educational qualifications and professional associations. We also collect information about and proof of your residency status, the name and contact details of your referees and other information required for recruitment purposes. Where we seek your consent to conduct a background check, we also collect details of your proof of identity from you. How do we collect your personal information? Where it is possible, we collect your personal information directly from you in person, in writing, over the telephone, by facsimile, through our online services (including our virtual online assistant and any online chat functions) and/or by electronic messages. In some circumstances, we may also collect it from:

• your agents or representatives, for example your insurance broker, your legal advisers, your family member who applies for a policy that covers you or is instructed by you to deal with us;
• third parties who you have asked to provide your personal information to us, including your referees and your insurer;
• our agents and service providers;
• insurers and insurance reference bureaus;
• people who are involved in a claim or assist us in assessing, investigating, processing or settling claims, including third parties claiming under your policy, witnesses, medical service providers, external claims data collectors and verifiers, and your employer;
• third parties who may be arranging insurance cover for a group that you are a part of;
• law enforcement, dispute resolution, statutory and regulatory bodies;
• publicly available sources such as the Internet and telephone directories; and/or
• the general public when it is unsolicited and may be relevant to a particular policy or fraud investigation.Unless we are required or permitted by law to collect sensitive information about you, we will only do so by obtaining your consent.

If you nominate individuals to be covered by your insurance policy, you should direct them to this Privacy Policy and make them aware of the content of any privacy notice we provide you. If you decide to complete an online application form, the information that you enter into the online form will only be collected by us if you submit your online application. If at any stage you cancel your application prior to submitting your application, the information you have entered up to that point will be automatically deleted. Website tracking We may collect information about your visit to our site to assist us to measure and improve our website. Examples of information that we collect include: day and time of your visit, whether you have visited our website previously, whether you used a search engine to find us and some geographical information about what country and state you are in. We use Google Analytics to collect visitor information so that we can better understand how to improve our products and services for you. One of the primary methods used by this tool is the placement of cookies. Cookies are small information files that an end user’s web browser places on their computer when a website is visited. For information on disabling these cookies, please go to the privacy settings section within your browser. In addition to the session cookie, Google Analytics uses other data collection methods such as appending query strings to an image request. We store the data generated by Google Analytics securely and do not share it with third parties. We also use other external companies for the following purposes:

• for web hosting services for this website; and/or
• to gather non-personal information (using cookies) in order to evaluate the website’s effectiveness, for example online marketing activities.

Email We retain the content of any email that you send to us if we believe we have a legal requirement to do so. Your email message content may be monitored by our employees for security issues, including where email abuse is suspected; our response to you may be monitored for quality assurance issues. For what purposes do we collect, hold and use your personal information? We collect, hold and use your personal information for the purposes of providing our products and services and managing our business. This may include:

• arranging and administering insurance;
• assessing risks and underwriting insurance;
• assessing, investigating, processing and settling claims, including managing workers compensation return to work programs;
• marketing our services and products and those of our related companies, brokers, intermediaries and business partners that may interest you;
• conducting customer research and analytics in relation to our service and products, and improving our service and products;
• handling complaints and disputes;
• training our employees, agents and representatives;
• detecting, investigating and preventing fraud;
• identifying and contacting individuals who do business with us; and/or
• assessing and processing employment applications.
• Personal information (including sensitive information) collected for workers compensation claims will only be used in connection with the business of providing workers compensation claim services or for purposes required by workers compensation regulators or by law.

Who do we disclose your personal information to and why? IMS may, from time to time, provide you with information about products and services offered by COTA Australia, COTA Insurance, members of the COTA Federation, other affiliates of IMS and the products and services which we have designed and developed for people 50 and over. Unless you request otherwise you authorise COTA to contact you with information which we think may be relevant or of interest to you. We may disclose your personal information to others for the purposes specified in the section above. This may include disclosure to:

• • our related companies;
  • our distributors and agents;
  • insurers and reinsurers;
  • insurance reference bureaus;
  • government, law enforcement, dispute resolution, statutory, regulatory or enforcement bodies and agencies;
  • loss adjusters and assessors;
  • repairers and suppliers;
  • investigators and recovery agents;
  • medical and health service providers, case managers and rehabilitation consultants;
  • our advisers (including legal, actuary and accounting advisers) and service providers, including marketing organisations and debt collecting agents;
  • professional and other organisations;
  • parties that we have an insurance scheme in place with under which you purchased your policy, such as a financier or motor vehicle manufacturer or dealer;
  • the agent and contractor of any of the third parties above; and/or
  • other parties as required by law.

We may also disclose your personal information (but not sensitive information) to others we have business arrangements with to enable them to offer their products and services to you. We will not disclose your sensitive information for any purpose, other than the purpose for which it was collected, or a directly related secondary purpose, unless you otherwise consent. Disclosure to overseas recipients In some instances, your personal information might be disclosed to other companies, business partners, reinsurers and service providers (including providers of our virtual online assistant and any online chat function) that may be located overseas. The countries in which these recipients may be located will vary from time to time, but may include Canada, Germany, New Zealand, United Kingdom, United States of America and other countries where we engage service providers or subcontractors. We regularly review the security of our systems used for sending personal information overseas. Any information disclosed may only be used for the purposes of collection detailed previously and for system administration. Direct marketing and your privacy From time to time, we may use your personal information to advise you about or offer you other products or services that may be relevant and of interest to you. If you do not want to receive these offers from us (including product or service offerings from us on behalf of intermediaries and/or our business partners), please email [email protected] or call the telephone number in the ‘Contact Us’ section of our website. In some instances, we may disclose your personal information (but not sensitive information) to others we have business arrangements with to enable them to offer their products and services to you. We do not use or disclose sensitive information for the purposes of direct marketing. Personal information, which is not sensitive information, that is collected for workers compensation insurance will not be used or disclosed to others for direct marketing, customer or market research purpose unless required by the regulator. How do we hold your personal information? We may hold your personal information in a number of ways, including:

• in our computer systems or databases, which may involve storing data on storage or computer systems provided by third party suppliers;
• in paper records; and/or
• in telephone recordings.

Where it has been collected from our or your agent, or our service providers, they may also hold copies of your personal information. Where it has been collected for the purposes of providing a product or service, the product or service provider, including underwriting, may also hold copies of your personal information. We may combine personal information we receive about you with other information we hold about you. This includes information received from third parties and information collected for different products and services. Links to external sites We may include links to external sites that we consider contain content relevant to the information that you were seeking from us. Where these links occur, we accept no responsibility for the accuracy of the content, the privacy or security of those sites or your reliance on any information contained within any such site. Contacting us about access to, and correction of, your personal information IMS aims to ensure that your personal information is accurate, up to date, complete and relevant. You can seek access to and correct your personal information by contacting us. If you would like to seek access to, or revise, your personal information, or feel that the information we currently have on record is incorrect or incomplete, please contact us using the following contact details: Phone 1300 1300 50 8.30am to 5.00pm CST Monday – Friday Email [email protected] You may not access or correct personal information of others unless you have been authorised by their express consent or otherwise under law, or unless they are your dependents under 16 years. If you do not agree to the above or will not provide us with personal information, we may not be able to provide you with our services or products, process your application or issue you with a policy. In cases where we do not agree to give you access to some personal information, we will give you reasons why. Making a complaint If you believe that we have interfered with your privacy in our handling of your personal information, you may lodge a complaint by contacting us on the above contact details or in writing to: The Compliance Officer Insurance & Membership Services Limited GPO BOX 1127, ADELAIDE, SA 5001 Or by email to: [email protected] We will respond to your query or complaint as soon as possible and will try to resolve any complaint within 14 working days. If this is not possible, we will contact you within that time to let you know how long we estimate it will take to resolve your complaint. Any unresolved complaints should be referred to the Privacy Commissioner. In Australia: Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW 2001 www.oaic.gov.au If you would like to make a complaint about IMS, its products or its services, you should first contact us with your complaint by phone or in writing using one of the contact methods detailed below: In writing to: The Complaints Officer Insurance & Membership Services Limited GPO BOX 1127, ADELAIDE, SA 5001 Or by email to: [email protected] By phone on: 1300 1300 50 (Mon–Fri 9am-5.30pm EST) We will investigate the matter(s) raised and respond to your query or complaint directly as soon as practical and will try to resolve any complaint within 14 working days. If this is not possible, we will contact you within that time to let you know how long we estimate it will take to resolve your complaint. If you are unhappy with the resolution of your complaint or with the way that IMS has handled your complaint you can request that the complaint be escalated further. Depending on the specific nature of the complaint it will be escalated to the appropriate internal or external channel. Details of the appropriate channel and process will be provided to you at the time of escalation, based on your specific situation and the type of complaint being made. If you continue to feel that your complaint has not been resolved you may be able to refer the matter to the Australian Financial Complaints Authority (AFCA) subject to its Terms of Reference or the Office of the Australian Information Commissioner. The contact details for these bodies are as follows: Australian Financial Complaints Authority GPO Box 3 Melbourne VIC 3001 1800 931 678 www.afca.org.au Dealing With Other People We will only ever speak to the policyholder regarding any specific policy held with us. If you wish your spouse or partner to deal with your policy then please let us know. Other people will not be able to cancel a policy as we will have to speak to the policyholder(s) regarding a cancellation of cover. We will, in exceptional circumstances, deal with other people regarding your policy provided we have your permission. Additional Products When you take out other policies with us, your details will be passed to the appropriate provider as shown below: General Insurance Products Including Home, Contents, Motor, Landlords, Caravan and Trailer – Allianz Australia Boat Insurance – Club Marine Travel Insurance – nib Travel Services Changes to this Privacy Policy We may make changes to this Privacy Policy from time to time for any reason. We will publish changes to this Privacy Policy on this website.