What is personal information?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect includes names, addresses, email addresses, phone and facsimile numbers.
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
- For the primary purpose for which it was obtained
- For a secondary purpose that is directly related to the primary purpose
- With your consent; or where required or authorised by law.
Collecting and holding personal information
We generally collect a range of personal information in person, by email, in writing, by telephone, email or via our website. Our Privacy Collection Statement can be read here.
Collecting of information may happen directly though Foresters, or our aligned partners such as funeral directors, unions, industry association, strategic partners or advisers.
We may collect information when you: enquire about our products, obtain a quote, make an application, submit a claim, complete forms, provide information during a visit, have customer interactions with us where we document details of the discussion and may have voice recordings of telephone conversations or if you engage in online or social communication with us.
For employment candidates, we may collect your personal information for recruitment purposes, to manage your employment applications or your ongoing employment.
Personal information that we collect and store about you may include your full name, address, contact details, date of birth, gender, identification documents, banking details and such other information which is relevant and necessary to identify you, provide products and deliver services to you or to comply with the law. We may also collect and store sensitive information which may include health and other medical information, occupation and other information which is relevant and necessary to providing products and delivering services to you or to comply with the law.
We will collect your personal information on a recurrent basis using the above methods. We may collect information from multiple contact points and combine as part of your customer profile.
Where possible, you have the option of interacting with us anonymously or pseudonymously. We will however need to know who you are to provide you with our products and deliver our services. If you do not provide us with all the information requested in our application form, we may not be able to process your application, or provide you with our products and services.
Use and Disclosure
We may use and disclose your personal information that was collected initially by us for the primary purpose (i.e. to provide you a quote for our services) for a secondary but related purpose where you have consented to a secondary use or disclosure, or if we consider you would reasonably expect us to use or disclose your personal information for the secondary purpose, and that purpose is related to the primary purpose of collection. In the case of sensitive information, we will only use or disclose this information when directly related to the primary purpose of collection.
For example, we will disclose your personal information to:
- assess your product application
- process payments and redemptions
- assess, process and investigate any product claims or complaints
- the Financial Ombudsman service or any other relevant dispute resolution body
- the Government regulators and enforcement bodies.
The third parties we may share personal information with include: Service providers such as accounting, actuarial, legal, audit, professional advisers (banks, insurers, financial institutions, identity verification and fraud detection), IT (information technology) providers, distribution providers such as adviser platforms, marketing partners, and public relations providers.
The types of data shared with any third party may include your personal information, policy type, your account balance, any insured amount, nominated beneficiaries, or your legal personal representative. The data is shared for a range of purposes such as identity verification to open your account, ongoing administration of your account to process claims or other service requests.
We will not sell or disclosure your personal details for any other purpose that is not related to your relationship to us. We will not pass your personal information to external organisations for marketing purposes independent of us, without your permission. However, you should be aware that there may be occasions where we are required by law to pass on information to Government agencies, or where the disclosure of that information is in the public interest. In these instances, your consent will not be requested.
We may provide personal information about you to agents, contractors or other service providers who supply administrative, financial or other services to us or to you in relation to your Foresters product. We require all such agents, contractors and other service providers to comply with our standard of privacy protection.
Any government related identifiers obtained for the purposes of identification under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), such as document numbers on passports, driver licenses, and Medicare cards, will be used or disclosed only for the following purposes
(a) as required or authorised by or under an Australian law or a court/tribunal order; or
(b) where reasonably necessary for Foresters to fulfil its obligations to an Agency or an Australian State or Territory Authority; or
(c) where reasonably necessary for Foresters to verify the identity of the individual for the purposes of Foresters’ functions or activities.
How you can opt-out of marketing
Foresters may wish to offer you another product or service that we offer and which we think may be of interest to you, however you will be given the opportunity to opt out of such offers. We use a variety of marketing strategies including targeted online advertising and marketing, and we may use methods such as mail, electronic messaging, telephone, social media, and email to contact you. If you wish to opt out you can use the unsubscribe facility in emails or text messages, or log into your account with us to update your communication preferences, or contact us.
Foresters does not disclose your information to external entities for the purposes of allowing them to direct market their products or services to you.
Destroying or de-identifying information
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. Most of the Personal Information is or will be stored in client files which will be kept by us for the minimum period of time required to administer your account for a period of at least 7 years to comply with relevant law. Subsequent to this period Personal Information that is no longer required may be destroyed or de-identified as appropriate.
How we protect your information
We will securely store your personal information in a number of ways including in electronic systems and devices, in paper files kept on premises and secure storage facilities off site. Information is stored in secure data centres located in Australia. We use controls such as firewalls, intrusion detection software, access and permissions restrictions, and physical security controls to safeguard your information. Staff are trained to deal with personal information confidentially.
Disclosing information overseas
We may send and store personal information overseas but only to the extent that it is necessary to perform our functions or activities. Generally, however we do not disclose your information to a party outside of Foresters, unless that party is contracted to Foresters or its related entities to provide services or activities on our behalf. For example, organisations that facilitate the sending of emails which are located in the United States of America. We do not disclose information outside of Australia unless we take steps as are reasonable in the circumstanced to ensure that the overseas recipient will not breach the Australian Privacy Principle set out in the Privacy Act 1988 (Cth) in relation to the information. Please contact our Privacy Officer if you wish to receive an up-to-date list of the countries your information will be shared with.
Security of your personal information
We will take reasonable precautions to ensure that the personal information that we have about you is protected against any unlawful use, unauthorised access, modification or disclosure. These precautions include using appropriate technology and processes, computer and network security systems with appropriate firewalls, encryption technology and passwords for the protection of electronic files, securely destroying or de-identifying personal information if we no longer require it (subject to our legal obligations), restricting access to your personal information to our employees and those who perform services for us who need your personal information to do what we have engaged them to do, and requesting certain personal information from you when you wish to discuss any issues relating to the products and services we provide to you.
All personal information that you may provide to us on-line via our website is protected from unauthorised access by industry standard protection software. This software is reviewed from time to time and updated when necessary.
Cookies and pixels
We sometimes use cookie or marketing pixel technology on our websites to provide information and services to website visitors, to provide targeted advertising or to measure the effectiveness of advertising. Cookies are pieces of information that a website transfers to your computer’s hard disk for record keeping purposes and are a necessary part of facilitating online transactions. Most web browsers are set to accept cookies. Cookies are useful to determine overall traffic patterns through our website. If you do not wish to receive any cookies you may set your browser to refuse cookies. This may mean you will not be able to take full advantage of the services on the website.
Links to other websites
Our website may contain links to third party websites. These linked sites are not under our control and we are not responsible for the content of those sites nor are those sites subject to this Policy. Before disclosing your personal information on any other website, we recommend that you examine the terms and conditions and Privacy Policy of the relevant site. Foresters is not responsible for any practices on linked websites that might breach your privacy.
Accessing your information and ensuring it is correct
We rely on the information we hold about you to efficiently conduct our business of providing products and services. For this reason, it is very important that the information we collect from you is accurate, complete and up-to-date. If your information changes, please inform us so that we may change our records. You may request access to any of the information we hold about you. In most cases, a summary of information such as your name and address details, contact telephone numbers, policy numbers, policy cover and the products and services you have with us are freely available to you by calling us.
If you would like to request access to the personal information we hold about you, please contact our Member Service team or Foresters’ Privacy Officer. You may be required to provide further information to Foresters to identify yourself. A request for access will be responded to within 30 days of us receiving the request.
Foresters is not always required to provide you with access to your information upon your request. We may refuse you access to information in a number of circumstances such as where denying access is required or authorised by law. If we deny your request for access to, or refuse your request to correct your information, we will explain why. If you are not satisfied with our reason, you are able to lodge a complaint with us.
You have the right to request us to correct any inaccurate, out-of-date, incomplete or misleading personal information. We will update your details immediately in accordance with requirements. We will also take reasonable steps to ensure that the correction takes places across all records that hold the information.
Complaints in respect to a breach of privacy
Foresters has established a formal Privacy Complaints Procedure to deal with any complaints lodged with the company in relation to breaches of the Australian Privacy Principals or the Privacy Act 1988. If you have a complaint about how we collect, hold, use, or disclose your personal information or if you believe Foresters has not protected your personal information as set out in this Privacy Policy you may lodge a complaint with us. It is important to follow the process so we can deal with your complaint effectively and efficiently.
Complaints can be made by phone, email or writing to the address set out below and should be directed to the Privacy Officer, who will provide you with further information about Foresters’ Complaints.
A copy of this Privacy Policy is available to download from our website. You may request a copy of our Privacy Policy in a particular form and we will take reasonable steps to provide the policy to you in that requested form.
Communicating changes to our Privacy Policy or Privacy Collection Statement
When we make changes from time to time to our Privacy Policy or Privacy Collection Statement, we will post details of the changes to our website.
Contact Details
Via our website: ‘Contact’
1800 645 326 (free call)
Email service@forestersfinancial.com.au
In writing:
The Privacy Officer
PO Box 7702, Melbourne, Victoria 3004
What if I am not satisfied with Foresters’ response?
If you are not satisfied with the outcome of your complaint to Foresters you can refer your complaint to either the Office of the Australian Information Commissioner or the Australian Financial Complaints Authority for further review.
Office of the Australian Information Commissioner
By phone: 1300 363 992
By email: enquiries@oaic.gov.au
In writing: GPO Box 5218, Sydney NSW 2001
Australian Financial Complaints Authority
By phone: 1800 931 678 (free call)
By email: info@afca.org.au
In writing: GPO Box 3, Melbourne VIC 3001