This Privacy Policy (Privacy Policy) explains how the Insurance Council of Australia Limited ABN 50 005 617 318 and the Insurance Fraud Bureau of Australia (IFBA) (collectively, ICA, we, us or our) handle, use, store and manage personal information we collect about you, whether as:
- a visitor to our website (Visitor) accessed at www.insurancecouncil.com.au (Website);
- a candidate searching for an employment or contracting opportunity with us (Jobseeker);
- an employee or agent of our member organisations (ICA Member Representative) requesting information from the member online portal known as the Insurance Fraud Bureau of Australia (IFBA Platform) to investigate insurance fraud;
- a representative of a member organisation of the ICA (ICA Member) disclosing personal information of others to us via the IFBA Platform; and/or
- an individual via any other channel such as telephone, email, mail, in person, at conferences, functions or ICA events or provided to us by a third party.
We are bound by and adhere to the Privacy Act 1988 (Cth) and the Australian Privacy Principles under that Act (Privacy Act) and the terms of this Privacy Policy.
By providing us with any sensitive information identified in this Privacy Policy or any privacy collection statement (PCS) provided to you at the time of collection of your sensitive information, you consent to our collection use, holding and disclosure of such sensitive information in accordance with and as set out in this Privacy Policy and/or PCS, as the case may be.
If you provide us with the personal information of another individual, you warrant that you have informed them of this, provided this Privacy Policy (and any relevant PCS) to them and that you have their permission to provide their personal information to us. In addition, where you have provided us with any sensitive information of another individual you warrant that you have obtained that individual’s consent for us to collect, use, hold and store their sensitive information in accordance with this Privacy Policy and any relevant PCS.
1. What kinds of personal information does ICA collect and hold?
This Privacy Policy uses the term of “personal information” which is defined in the Privacy Act and, in summary, refers to any information which can, directly or indirectly, be used to identify you (or another individual, as the case may be). When we use the term “sensitive information” it has the same meaning as in the Privacy Act.
The personal information we collect is limited to the personal information required to perform our functions and activities, including to establish and maintain our communications with you and provide the IFBA Platform, including as detailed below.
1.1. For Visitors and/or other individuals
The kinds of personal information we collect and hold about you includes:
- a) contact details such as name, email address and phone number;
- b) the personal information you provide to us on the Website (i.e. entering information into a form or contacting us via the Website);
- c) the details of your complaint submitted to us;
- d) the photographs, audio and video recordings (i.e. sensitive information) of you attending our events all supporting (or otherwise) a claim;
- e) other information provided if you otherwise contact us by phone, email, online form or mail;
- f) as an insured, name, date of birth, residential address, policy, sum insured, claims made, any fraud indicators; and/or
- g) the medical records or health information (i.e. sensitive information) of an individual in a travel insurance claim;
- h) in relation to catastrophic events the sums insured for a residential address and claim value; and
- i) other personal information that is relevant to the performance of our functions or activities.
We also collect personal information through the use of cookies (explained in the Cookies section below).
1.2. For ICA Members or ICA Member Representatives
As an ICA Member or an ICA Member Representative we collect personal information about you or you disclose personal information to us about another individual as the case may be, including:
- a) your contact details such as name, email address, phone number, ICA Member’s name; and
- b)indirectly for the IFBA Platform:
- I. the insured’s name and residential address, policy and sum insured;
- II. the date of birth of the insured;
- III. the sums insured for a residential address and claim value in event of catastrophic events;
- c) the ICA Member Representative’s name and email address for processing a request for information in the COVID 19 tool;
- d)any fraud indicators relating to the insured;
- e) the medical records or health information (i.e. sensitive information) of an individual in a travel claim;
- f) photographs, audio and video recordings (i.e. sensitive information) to support a claim; and
- g) other personal information that is relevant to the performance of our functions or activities.
1.3. For Jobseekers
As a Jobseeker the kinds of personal information about you that we collect and hold includes your contact details such as name, email address, phone number and your employment history, personal references and education qualifications.
2. Dealing anonymously or pseudonymously with the ICA
In some cases, you may deal with the ICA on an anonymous basis or using a pseudonym when making general inquiries to the ICA. However, we may require certain contact details from you in order to respond to your inquiries.
If the ICA solicits submissions or comments from individuals, or if the ICA hosts a blog or forum on the Website, individuals may use a pseudonym for publication with the submission. However, the ICA will require that the individual provide their name and contact details to the ICA, even where a pseudonym will be used for publication.
You can contact the ICA on an anonymous basis to report a suspected insurance fraud. If you provide your contact details to report a suspected insurance fraud or supply information relating to such, this personal information may be disclosed to members of the ICA.
In some cases, if you do not provide your personal information that we (or our agents) request, ICA may not be able to provide its services to you. We will inform you where this is the case.
3. How do we collect your personal information?
We collect personal information directly from you through your use of the Website, when you contact the ICA by email, telephone, mail, in person or otherwise in connection with the ICA's services, functions or activities and/or when you access and use the IFBA Platform.
Where it is impracticable to collect relevant personal information directly from you (e.g. for the IFBA Platform) we collect your personal information from third parties such as government agencies and law enforcement agencies, ICA Members provide to the ICA statistical data and personal information to report suspected insurance fraud and for the IFBA and in relation to catastrophic events.
We also have agents who collect personal information (including relevant sensitive information as noted in this Privacy Policy or a relevant PCS) from you on behalf of ICA of who provide such to us. For example, when you register yourself or other individuals for ICA's events or provide other services to the ICA in connection with its functions and activities.
4. How do we use your personal information?
We only collect personal information about you for purposes directly related to our functions or activities, including:
- a) processing and dealing with inquiries from individuals about the ICA, the insurance industry, its members or other information provided by the ICA and providing general information in response to inquiries;
- b) collecting submissions and views regarding the political, social, business, regulatory and economic environment in Australia to purposefully advocate for changes to practice and to improve outcomes for insurance customers;
- c) discussing with government and industry the impact on community following a catastrophe event to assess government recovery efforts, policy responses and relief funding payments;
- d) processing membership applications;
- e) arranging, promoting and hosting of events held or supported by the ICA;
- f) distributing registration materials for events, confirming registration, receiving speakers' papers and other presentations, providing conference papers and notices of other ICA or ICA supported events;
- g) sharing information and our newsletter services to individuals and subscribers;
- h) hosting blogs or forums on the Website;
- i) dealing with queries and responses relating to natural disasters and catastrophes;
- j) facilitating group and one to one community consultations for industry as a result of natural disasters or catastrophes;
- k) providing information in respect of its activities and those of its ICA Members;
- l) understanding the levels of underinsurance and non-insurance in a community or region;
- m) running the IFBA Platform and processing and dealing with information received from the public and ICA Members to help combat insurance fraud;
- n) storing information received from the ICA Members on the IFBA Platform to help, investigate and combat insurance fraud and track progress of investigations;
- o) promoting ICA events on the Website and elsewhere;
- p) receiving and processing applications for prospective employment or contracting opportunities at the ICA;
- q) in Policy Committees and Working Groups to note attendees of a meeting, to distribute agendas and notes of meetings, discussion papers, draft submissions or technical questionnaires to attendees of the meeting;
- r) processing and the delivery of reports to nominated ICA Member Representatives in relation to a business interruption policy query from their use of the COVID 19 tool; and
- s) to perform our other functions and activities relating to the ICA's objectives.
5. Cookies
The ICA uses "cookies" on its Website. A cookie is a small amount of information which is transferred to the hard drive of your computer and which can identify your web browser but not you. Individuals can disable their web browsers from accepting cookies. If you do so, you can still access the Website, but not all services may be available.
6. Direct Marketing
Our Website offers functionality allowing you to opt in to receive marketing and newsletter information communications from us relevant to you. We will only send you marketing and newsletter information communications when you opt in to receive them and by the means that you choose to receive them. If at any time you do not wish to receive this marketing and newsletter information from us you may unsubscribe by the opt-out option presented in the received communication.
7. Security of your personal information
Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we will take reasonable steps to protect your personal information we cannot guarantee or warrant the security of any personal information you transmit to us via the internet. We also take reasonable steps to protect your personal information once it reaches us.
8. Disclosure of your personal information
We may disclose your personal information to the following third parties (for the following purposes):
- a) ICA Members to process queries or complaints received by the ICA from individuals and/or to detect, investigate and help combat insurance fraud in the running of and providing access to the IFBA Platform;
- b) ICA Members during catastrophic events for their estimation of insurance coverage in a community;
- c) ICA Members to schedule one to one community consultations for industry such as in the event of a natural disaster or catastrophe;
- d) ICA Members to assist with determining who your insurer is, at your request;
- e) conference organisers to facilitate the operation and attendance at an event;
- f) Federal, State or Territory police authorities and agencies as authorised or required by law or a court or tribunal order;
- g) members of the ICA's policy committees and working groups1 to provide community context to policy development;
- h) with your prior consent, to media organisations and agencies and other third parties for the purpose of dissemination and publication of photographs and audio and video recordings made by the ICA, or its agents, at events;
- i) our third-party service providers to maintain the IFBA Platform; and
- j) otherwise as authorised or required by law or a court or tribunal order.
We do not knowingly disclose your personal information to any overseas recipients.
9. Accessing and correcting your personal information held by the ICA
You have the right to request access and/or to correct or update your personal information at any time by contacting us. There is no charge for making a request to access or correct your personal information, but ICA may charge a reasonable fee for responding to an access request. Prior to us processing your request you will need to provide evidence satisfactory to us of your identity.
We will respond to your request within 30 days of receiving it. If we cannot fulfil your access request or do not wish to correct your personal information, for any reason, we will write back to you and explain why.
If we do not agree to provide you access to personal information or to correct your personal information we hold about you, you may complain to us or seek review with the OAIC as set out in section 10 below.
10. Complaints
If you wish to make a complaint about an alleged breach of this Privacy Policy or the Privacy Act by us, you can contact us using the details in the “Contact Us” section (section 11) below. You will need to provide us with sufficient detail regarding your complaint and any supporting evidence.
Our Privacy Officer will investigate the issue and determine the steps to be taken to resolve the complaint. We will notify you in writing if we require any additional information and also of the outcome of the investigation. A response will usually be provided within 30 days of receipt of the complaint by the ICA.
If you are not happy with the outcome of our investigation, you may complain to the Office of the Australian Information Commissioner (OAIC). For further information about the Privacy Act or to make a complaint to the OAIC, please see their website at www.oaic.gov.au.
11. Contact Us
Any queries about this Privacy Policy, correction or access requests or privacy complaints should be addressed to:
The Privacy Officer,
Insurance Council of Australia,
Level 26, 9 Castlereagh St,
Sydney, NSW, 2000
email: [email protected]
12. Changes to this Privacy Policy
We may, from time to time, update this Privacy Policy (and any PCS) so please ensure you review it periodically for changes. If any changes are significant or substantial, we will let you know on our Website or by email if you have provided us with your email address.
Your continued use of the Website, our services, participation in our programs and activities or the provision by you of further personal information to us after notice that the Privacy Policy has been revised will be deemed to be your acceptance of (and in the case of sensitive information, consent to) the revised Privacy Policy.
This Privacy Policy was last revised on 19 July 2023
