Our Commitment

• Lockton Companies NZ Limited Partnership (‘Lockton’) is committed to providing you with the highest levels of client service and to protecting the privacy and security of your personal data.

• This notice describes how we, as an intermediary, collect and use personal data about you during and after your engagement with us, in accordance with the New Zealand Privacy Act 2020. Insurance is the pooling and sharing of risk in order to provide protection against a possible eventuality. To do this, information, including your personal data, needs to be shared between different insurance market participants. The insurance market is committed to safeguarding that information

• The Privacy Act 2020 governs how organisations and businesses in New Zealand can collect, store, use and share information. Our aim is to both support and ensure that we comply with these principles and where applicable the European Union General Data Protection Regulations (2018).

• Further information on privacy in New Zealand may be obtained by visiting the website of the Privacy Commissioner at https://www.privacy.org.nz/ (opens a new window)

• Lockton believes that this Privacy Policy discloses the purpose, and how the personal information you provide to us and our representatives, is collected, used, held, disclosed, and disseminated.

• Lockton is required to meet particular legislative and regulatory requirements. To provide advice to you, we are required to collect certain personal information from you.

• We encourage you to check our website (https://www.lockton.com/nz (opens a new window)) regularly for any updates to our Privacy Policy.

Your personal information

• As an organisation we are subject to certain legislative and regulatory requirements which may necessitate us to obtain personal information about you.

• your name, contact details, date of birth, sex, salary and job title

• information regarding your dependents and family commitments.

• your occupation, and employment history.

• your financial needs and objectives.

• your assets, liabilities, income, expenses insurances, and welfare entitlements.

How we collect personal information

Lockton collects personal information directly from you, from your employer, from publicly available information or from third parties once authorisation has been provided by you. You have a right to refuse us authorisation to collect information from a third party.

How we use your personal information

Primarily, your personal information is collected and used to provide advice or insurance related services to you or your employer. We may also use the information that is related to the primary purpose and it is reasonable for you to expect the information to be disclosed.

From time to time, we may provide you with direct marketing material. This material will be clearly identifiable as from Lockton and will include the contact details of the sender. If, at any time, you do not wish to receive this information any further, you may contact us to be unsubscribed from any future marketing material. We maintain a register for those individuals not wanting direct marketing material.

When we disclose your personal information

In line with modern business practices common to many financial institutions and to meet your specific needs we may disclose your personal information to the following organisations:

• insurance providers, and other product providers in order to manage or administer your product or service.

• compliance consultants.

• contractors or temporary staff to handle workloads during peak periods.

• loss adjusters.

• your professional advisers, including your solicitor or accountant as authorised by you.

• information technology service providers.

• government and regulatory authorities, as required or authorised by law.

• another authorised representative of Lockton if necessary.

• a potential purchaser/organisation involved in the proposed sale of our business for the purpose of due diligence, corporate re-organisation and transfer or all or part of the assets of our business. Disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them.

• a new owner of our business that will require the transfer of your personal information.

• Our employees and the outsourcing companies/contractors are obliged to respect the confidentiality of any personal information held by Lockton.

• Lockton takes its obligations to protect your information seriously, this includes when we operate throughout New Zealand and overseas, as part of our operations some use and disclosure of your information may occur outside of New Zealand. In some circumstances we may need to obtain your consent before this occurs.

How we store and secure your personal information

• We keep your personal information in your client files or electronically. These files are accessible to authorised personnel only and are appropriately secured and subject to confidentiality requirements.

• Personal information will be treated as confidential information and sensitive information will be treated highly confidential.

• It is a legislative requirement that we keep certain personal information and records for a period of 7 years. Should you cease to be a client of ours, we will maintain your personal information on or off site in a secure manner for 7 years as required by law. After this, the information will be destroyed.

Ensure your personal information is correct

Lockton takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up to date. To ensure we can maintain this level of accuracy and completeness, we recommend that you:

• inform us of any errors in your personal information; and

• update us with any changes to your personal information as soon as possible.

• If you provide inaccurate or incomplete information, we may not be able to provide you with the products or services you are seeking.

Access to your personal information

You have a right to access your personal information, subject to certain exceptions allowed by law. We ask that you provide your request for access in writing (for security reasons) and we will provide you with access to that personal information. Access to the requested personal information may include:

• providing you with the opportunity for inspection; or

• providing you with a hard or electronic copy; or

• making arrangements for you to hear or view sounds and/or images contained in documents which sounds, or visual images can be reproduced; or

• providing you with a transcript where documents are in shorthand or a codified form; or

• providing you with a summary; or

• giving you oral information about the document’s contents.

If charges are applicable in providing access to you, we will disclose these charges to you prior to providing you with the information.

Some exceptions exist where we will not provide you with access to your personal information if:

• Lockton is not satisfied as to the identity of the person requesting the information

• If we believe providing access is made under threat of physical or mental harm.

• providing access would have an unreasonable impact on the privacy of others.

• the request for access is frivolous or vexatious.

• the information is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings.

• providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations.

• providing access would be unlawful.

• denying access is required or authorised by or under law.

• providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.

Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal.

Unique Identifiers

Unique identifiers are individual numbers, references, or other forms of identification allocated to people by organisations as a way to uniquely identify the person to the organisation assigning the identifier. Examples include employee numbers, driver’s licence numbers, passport numbers, IRD numbers, or National Health Index (NHI) numbers.

Although in certain circumstances we are required to collect unique identifiers such as those outlined above, we do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.

Dealing with us anonymously

You can deal with us anonymously where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.

Your sensitive information

Without your consent we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record.

This is subject to some exceptions including:

• the collection is required by law; and

• when the information is necessary for the establishment, exercise, or defence of a legal claim.

Our website

• Lockton’s website may provide links to third party websites. The use of your information by these third-party sites is not within the control of Lockton and we cannot accept responsibility for the conduct of these organisations. Other websites are not subject to our privacy standards. You will need to contact or review those websites directly to ascertain their privacy policies.

• You may register with us to receive newsletters and other information. By doing so, your name and email address will be collected and stored on our database. We take care to ensure that the personal information you give us on our website is protected. For example, our website has electronic security systems in place, including the use of firewalls and data encryption.

• If you do not wish to receive any further information from us, or you wish to update your registration details, please email your request to us. We will endeavour to meet your request within a reasonable timeframe.

• Our website utilises cookies to provide you with a better user experience. Cookies also allow us to identify your browser while you are using our site – they do not identify you. If you do not wish to receive cookies, you can instruct your web browser to refuse them.

Third-party web tracking:

When you visit the site, we may collect internet traffic data such as IP addresses from providers of tracking services. We collect no personally identifiable information and we comply with the global Transparency and Consent Framework (TCF V2.0 (opens a new window)).

Complaints resolutions

Please contact our Chief Operating Officer if you wish to complain about any breach or potential breach of your privacy rights. Your complaint will be responded to within 2 working days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Privacy Commissioner (OPC).

Attn: Complaints / Disputes Manager

Lockton Companies NZ Limited Partnership

Level 8, 1 Albert Street, Auckland 1010

Ph: (+64) 9 300 2135

Email: info.nz@lockton.com

Spam policy

• Spam is a generic term used to describe electronic ‘junk mail’- unwanted messages sent to a person’s email account or mobile phone. In New Zealand, spam is defined as ‘unsolicited commercial electronic messages.

• ‘Electronic messaging’ covers emails, instant messaging, mobile/smart phone text (TXT) and image based messages of a commercial nature, but does not cover Internet pop-ups or voice telemarketing.

• Lockton complies with the provisions of the Unsolicited Electronic Messages Act 2007 when sending commercial electronic messages.

• Of equal importance, Lockton makes sure that our practices are in accordance with the Privacy Principles set out under the Privacy Act 2020 in all activities where they deal with personal information. Personal information includes our clients contact details.

Procedure for dealing with complaints

The three key steps Lockton follows are as follows:

• Consent – Only commercial electronic messages are sent with the addressee’s consent – either express or inferred consent.

• Identify – Commercial electronic messages will include accurate information about the person at Lockton that is responsible for sending the commercial electronic message.

• Unsubscribe – We ensure that a functional unsubscribe facility is included in all our commercial electronic messages and deal with unsubscribe requests promptly.

Comply with the law regarding viral messages

Lockton ensures that commercial communications that include a forwarding facility contain a clear recommendation that the recipient should only forward the commercial communication to persons with whom they have a relationship, where that relationship means that person could be said to have consented to receiving commercial communications.

Comply with the age sensitive content of commercial communication

Where the content of a commercial communications seeks to promote or inspire interaction with a product, service or event that is age sensitive, Lockton takes reasonable steps to ensure that such content is sent to recipients who are legally entitled to use or participate in the product service or event.