About this Policy
We at MLC Limited (MLCL) are committed to protecting your personal information. As a provider of life insurance services, respectful and appropriate use of personal information is critical to our business.
Types of personal information we collect and hold
We collect and hold a range of personal information about our customers and people from our business partners, suppliers and service providers.
The kinds of personal information that we may collect and hold may include:
- name, contact details (including address, email, phone number and social media handles), date of birth and gender;
- information about your interactions with us including complaints;
- personal information which is required to acquire a product or service from us and as may be needed during the lifecycle of that product or service;
- information required to underwrite an application for an insurance product or assess and manage an insurance claim, including previous insurance records and claims history, information about beneficiaries and nominated representatives, employment and income;
- financial details such as your tax file number and bank account details, superannuation or other insurance policy information;
- sensitive information (see “Sensitive Information” section below);
- information relating to your use of our online services (see the ‘Online services’ section below); and
- any other information we think is necessary for you or others to acquire our products or for us (or our service providers or representatives) to provide services to you.
Sometimes we need to collect and hold sensitive information about you, for example when you are applying for an insurance product. This will generally include information about your health, activities that may impact your health, your health history, fitness and physical activities. We may also give you the ability to provide your voiceprint to identify yourself to our call centres.
Sensitive information is information about a person’s health (this can include genetic or biometric information), 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 preferences or practices, criminal record, health information, genetic or biometric information.
We only collect and hold sensitive information with your consent or in other limited situations which the law allows.
How we collect personal information
We often collect personal information when you engage with us directly. For example, we might collect your personal information when you fill out a form with us, call us, meet with one of our representatives or use our website. See the ‘Online services’ section below for more information about our collection of personal information online.
Sometimes we collect information about you from other sources that may include:
- medical practitioners or medical facilities
- our representatives and distributors, insurance brokers, other insurers and reinsurers
- your relatives and representatives
- your employer our related bodies corporate
- National Australia Bank Limited (NAB) and its subsidiaries (see the section below regarding ‘Sharing of personal information with NAB Group companies’)
- service providers such as information brokers, investigators, lawyers, financial advisers, doctors and other medical and occupational experts;
- credit reporting agencies or information providers
- social media platforms (e.g. if you log in for our services using your social media profile)
- devices (including wearable devices) in relation to which you agree to provide personal information to us, and
- external dispute resolution bodies, and public sources, including statutory or government organisations, and public registers.
Why we collect personal information
We may collect, hold, use and disclose your personal information to:
- provide you with the products and services you’ve asked for or under which you may receive cover or benefits (e.g. group insurances)
- process and underwrite your application (including deciding whether or not to provide cover) or determine your eligibility under group insurances
- provide you with products and services
- administer products and services which includes answering your requests and complaints, managing claims and making payments, varying products and services, conducting market research, taking legal action relating to our products and services and managing our relevant product portfolios;
- develop and improve our products and services
- assist us in running our business including performing administrative and operational tasks (such as training and managing staff, risk management, planning, research and statistical analysis, and systems development and testing), and
- prevent or investigate any fraud or crime, or any suspected fraud or crime.
We may also collect, hold, use and disclose your personal information:
- as required by legislation or codes that are binding on us
- for any purpose for which you have given your consent, and
- to combine the information that we hold about you with information about you collected from or held by external sources to enable the development of consumer insights about you so that we can better serve you. We may also use external parties to undertake the process of creating these insights.
What if you don’t want to provide us with your personal information?
If you don’t provide your personal information to us, we may not be able to:
- provide you with the product or service you want
- manage or administer your product or service
- personalise your experience with us
- verify your identity or protect against fraud, or
- let you know about other products or services that might better meet your needs.
Direct marketing and how to opt out
Unless you opt out we may to the extent permitted by law:
- use or disclose your personal information to let you know about products and services that we believe may be of interest to you
- market our products to you through third party channels (such as social networking sites), or via other companies who assist us to market our products and services
- conduct these marketing activities via email, telephone, SMS, Instant Messaging, mail, or any other electronic or other means, including targeted advertising through MLCL or non-MLCL websites
- disclose your personal information to our related companies or to our trusted partners so they can tell you about their products and services;
- disclose your personal information to companies outside MLCL who assist us to market our products and services to you, including NAB and its subsidiaries and
- disclose your personal information to third parties such as brokers or agents, or for the purpose of connecting you with other businesses or customers.
You can let us know at any time (see ‘Contact Us’) if you wish to opt out of receiving direct marketing offers from us, or to opt out of our other use and disclosure of your personal information for direct marketing. We will process your request as soon as practicable.
You may also be able to opt out by following the instructions in particular direct marketing communications.
Disclosure of personal information
To make sure we can meet your specific needs and for the purposes described in ‘Why we collect personal information’, we may disclose your personal information to other third parties, including:
- our parent company, Nippon Life Insurance Company (Nippon) and our other related bodies corporate
- those involved in providing, managing or administering any aspect of your product or service or any product (e.g. group insurance) under which you receive or may receive benefits
- service providers such as information brokers, investigators, lawyers, financial advisers, doctors and other medical and occupational experts
- representatives of MLCL or other parties who sell our products or services;
- superannuation and managed funds organisations, and their advisers and service providers
- if your insurance is held in a superannuation product, to entities (and their representatives or service providers) involved in issuing, maintaining and providing administration support relating to these products
- medical professionals, medical facilities or health authorities who verify any health information you may provide
- reinsurers, claim assessors and investigators
- brokers or referrers who refer your application or business to us
- organisations we sponsor and loyalty program partners, including organisations we have an arrangement with to jointly offer products or have an alliance with to share information for marketing purposes
- police and other enforcement bodies and government agencies where we are required or authorised by law to help detect and prevent illegal activities
- other government or regulatory bodies (including the Australian Securities and Investment Commission and the Australian Tax Office) as requested or as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities)
- media or social networking sites that provide us with opportunities to place messages in front of you
- service providers that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems
- joint venture partners that conduct business with us
- organisations that assist with our product planning, analytics, research and development
- mailing houses and telemarketing agencies and media organisations who assist us to communicate with you
- other organisations involved in our normal business practices, including our agents and contractors, as well as our accountants, auditors or lawyers and other external advisers, and
- where you have given your consent.
Depending on the product or service we provide to you, we may disclose your personal information to organisations outside Australia, in countries such as Japan, Switzerland, France, USA, UK, New Zealand, the Philippines and India.
We may store your information in cloud or various other types of remote, networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.
Sharing of personal information with NAB Group companies
NAB and its related bodies corporate (collectively the NAB Group) either distribute or are involved in the administration, maintenance, or development of our life insurance products. MLCL is not part of the NAB Group of companies. We may share personal information with NAB Group companies so that they can distribute our products or perform other functions relating to our products that we have agreed. For example, we may share personal information with NAB Group companies so as to ensure:
- your insurance premium is calculated correctly (e.g. credit information may be required to be shared so your insurance can be calculated) and if required, payments made on your behalf
- insurance claims are paid
- insurance products are viewable to ensure your queries can be managed by relevant customer service centres
- insurance products are viewable by you through NAB online services (e.g. nab.com.au and mlc.com.au)
- MLCL and NAB Group companies can both tell you about their marketing and products offers, unless you have opted out
- effective financial management and performance reporting and tracking
- a smoother experience for you when you contact us or NAB Group companies, for example:
- NAB Group companies can transfer you to the right service centre at MLCL and vice versa;
- where appropriate, NAB Group companies can coordinate your complaint with us and vice versa; and we and NAB Group companies can provide assistance to you should you wish to speak to a NAB Group company about your MLCL products (e.g. where possible, a relevant NAB Group company may assist you by updating your contact details upon your request).
When you use our website, mobile applications, email communications, social media profiles and other online services (together, ‘Online Services’), we may collect information about your location or activity including information accessed, IP address, telephone number, device identifiers, social media profile information and whether you’ve accessed third party sites. We do this to verify you, identify ways we can improve our services for you, maintain the continuity of your online sessions, recall your details and preferences, understand you better, and for the other purposes described in this policy.
Some of the information is collected using cookies. A cookie is a piece of information that allows our system to identify and interact more effectively with your browser. The cookie helps us to maintain the continuity of your browsing session and remember your details and preferences when you return. You can configure your web browser software to reject cookies however some parts of our Online Services may not have full functionality if you do. See www.allaboutcookies.org for instructions on deleting and rejecting cookies for many common browsers.
Some of our Online Services may allow you to submit content (such as feedback and comments on our services) for public sharing. If you choose to do this, your content may be viewed by other users of the Online Services, and may be stored and disseminated on an ongoing basis by search engines and other third parties, even after you remove the content or set it to “private”. We may use your content submitted for publication for promotional purposes or any other purpose.
Storage and security of personal information
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure, including control of access to our buildings and electronic security systems, such as firewalls and data encryption on our websites.
We may store personal information physically or electronically with third party data storage providers or our service providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate steps to protect that information and restrict the uses to which they can put that information.
Your privacy rights
Accessing your personal information
You can access your personal information that we hold on request, subject to any legal restrictions or exemptions.
To request access to your personal information, please contact our Privacy Officer (see ‘Contact Us’ below). We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first.
If we decline your request for access, we will tell you why in writing. If you have concerns, you may complain. See ‘Complaints’ below.
Updating your personal information
Please contact us if your details have changed or if you think there is something incorrect with the information we hold about you.
We’ll try to accommodate your updating of information requests where we can. If we can’t, then we’ll let you know in writing. If you disagree, you may ask us to make a note of your requested correction with the information.
If you have a complaint about how we handle your personal information, we want to hear from you. You’re always welcome to contact our Privacy Officer (see ‘Contact Us’ below). We’re committed to resolving your complaint and doing the right thing by our customers.
We may request additional details from you regarding your complaint, and may need to engage or consult with other parties to investigate and deal with your issue. We’ll keep records of your request and any resolution.
If you still feel your issue hasn't been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner at www.oaic.gov.au/privacy or by calling 1300 363 992.
Reviews and updates to this policy
- there are significant changes to privacy legislation; and/or
- there are significant changes to our information handling practices, for example, due to technological advances.
Attention: The Privacy Officer, MLC Limited
Telephone: 13 22 65
The Privacy Officer
40 Mount Street
NSW 2060 AUSTRALIA
Date of preparation: 3 October 2016