This Policy outlines LB's obligation to manage and protect the personal information we hold about individuals. "Personal information" is information such as an individual’s name, gender, address and date of birth. "Sensitive information" includes information relating to an individual's health information, racial or ethnic origin, sexual preferences and criminal record. This policy is technology neutral and applies to all forms of communication. LB is bound by the current privacy legislation including the Privacy Act 1988(Cth) and Privacy Principles.
2. What type of information does LB hold?
We collect personal information to provide you with the products and services you request as well as information on other products and services offered by or through us. The type of information we hold varies depending on the type of product or service we provide to you. For example, LB will hold different information about you if you have a life insurance policy than we will hold if you have a managed investment.
In general, LB may hold the following personal information:
- date of birth
- contact details, which may include your telephone number
- your gender
If you are interested in obtaining life, trauma, or income protection insurance we may also collect the following:
- medical information that relates to the insurance
- lifestyle information that relates to the insurance.
3. How does LB collect this information?
We generally collect personal information directly from you. For example, you may deal with us on the phone, send us correspondence (by letter, fax or email) or contact us in person. Also, we will collect personal information from forms filled out by you, interviews, business documents and from other people. If the personal information that we request from you is not provided, we may not be able to process an individual's application to receive insurance cover, or interest in an investment, or provide individuals with the benefit of our services, or meet an individual's needs appropriately.
4. Why does LB collect personal information?
LB collects personal information in order to:
- provide you with our advice and our services regarding financial products and financial services;
- ensure that your needs are both acknowledged and met;
- manage the internal accounting and administration requirements of our business;
- comply with our legal obligations; and
- to help us manage and enhance our services.
5. How does LB use and disclose this information?
We use personal information for the primary purposes for which it is collected (as set out above), for reasonably expected secondary purposes which are related to the primary purposes, and in other circumstances authorised by the Privacy Act and the current privacy principles.
Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or where certain other limited circumstances apply (eg, where required by law).
We do not disclose personal information we collect to others for the purpose of allowing them to direct market their products and services. We do not use or disclose sensitive information for direct marketing purposes.
Sometimes we engage other people to perform services for us, which may involve that person handling personal information held by us. We always prohibit that person from using or disclosing personal information about you except in relation to the specific purpose for which we supply it.
6. To whom might we disclose personal information?
We may disclose your personal information to:
- financial product providers to assist in insurance and investment applications;
- consultants we engage;
- organisations involved in a transfer or sale of all or part of our assets or business (including accounts and trade receivables);
- organisations involved in managing our funding functions; and
- anyone else to whom you authorise us to disclose it.
Like other financial service companies, there are situations where we may also disclose your personal information in circumstances where it is:
- Required by law (such as to the Australian Taxation Office)
- Authorised by law (such as where we are obliged to disclose information in the public interest or to protect our interests).
We also use the information we hold to help detect and prevent illegal activity. We co-operate with police and other enforcement bodies as required or allowed by law.
We disclose personal information when we outsource certain functions, including bulk mailing, direct marketing, debt recovery and information technology support. In all circumstances where personal information may become known to our contractors, agents and outsourced service providers, there are strict confidentiality arrangements in place. Contractors, agents and outsourced service providers are not permitted to use or disclose personal information for any unauthorised purposes.
7. Management and Security of personal information
Current privacy legislation requires us to take all reasonable steps to protect the security of personal information. Our personnel are bound by a confidentiality agreement to respect the confidentiality of personal information and the privacy of individuals.
LB takes reasonable steps to protect personal information from misuse and loss and from unauthorised access, modification or disclosure, by use of physical security and restricted access to records.
We take all reasonable precautions to protect the personal information we hold about you from misuse and loss and from unauthorised access, modification or disclosure. We have a range of practices and policies in place to provide a robust security environment. We ensure the on-going adequacy of these measures by regularly reviewing them.
8. How does LB handle a request for access to personal information?
Under the current Privacy Principles you are entitled to access the information we hold about you. Where you are entitled to access, the time we require to give you access will depend on the type of information requested. If we can, we will answer your question immediately. We will also try to answer you in the same way that you ask, for example, if you telephone to ask for the information we will, if practicable, give you that information over the telephone. We will generally respond to a written request in writing.
Sometimes, we will ask that you put your request in writing, for example, where you want copies of material or access to older information or files which are not current or it is necessary for us to retain a record of your request. We may also ask you to identify yourself to our satisfaction.
In some circumstances, we may charge a fee for giving you access, which will vary but will be based on our costs (internal and external) in locating the information and the form of access you require. If we propose to charge a fee for giving access, we will give you an estimate of the fee so you can confirm that you still want us to give you access to the information. We do not impose any charge for lodging a request for access.
If we are entitled under the current Privacy Principles to refuse to give you access, we will tell you and provide reasons.
Generally we will deal with your request within 14 business days.
9. Online Marketing and Advertising
LB uses pixels, or transparent GIF files, to help manage online advertising. These GIF files are provided by our ad management partner, DoubleClick. These files enable DoubleClick to recognize a unique cookie on your Web browser, which in turn enables us to learn which advertisements bring users to our website. The cookie was placed by us, or by another advertiser who works with DoubleClick. With both cookies and Spotlight technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address. For more information about DoubleClick, including information about how to opt out of these technologies, go to http://www.doubleclick.net/us/corporate/privacy.
Personal information is shared between us and other companies with which we have a business relationship. They may provide you with information on their products and services which we consider may be of interest to you. We may disclose some of your personal information to external organisations who assist us in administering the provision of the products or services to you. For example, other organisations with which we have an arrangement for the promotion and sale of products or services offered by us. If you do not want your personal information to be used in this way, please let us know. We may also use personal information held about you to keep you informed of new products or special arrangements offered or distributed by us, or other organisations with which we have a business relationship, or to conduct marketing activities, and may disclose information about you to our service providers for this purpose. To opt-out of receiving marketing information altogether, please contact us.
We will not use identifiers assigned by the Government, such as a Tax File Number, or a Medicare number, for our own file recording services.
11. Sending information overseas
We will not send personal information to recipients outside of Australia without obtaining the individual's consent (which may be implied) or otherwise complying with the NPPs.
12. Correction and accuracy of the information
We want our records to be accurate, complete and up to date. Please tell us if any information that we hold needs correcting or is out of date. Unless we disagree with you about the accuracy or completeness of a record, we will generally correct it on request, (or suggest alternative arrangements for updating our records). If we disagree with you, we will give you our reasons.
13. How do I make further enquiries or complain about a breach of privacy?
If you require more information about the way LB manages personal information or wish to make a complaint about a breach of your privacy, please contact LB (see below for details) and ask to speak to the Chief Operating Officer.
14. How can I contact LB?
Call 13 5433 and ask to speak to the Chief Operating officer.
Write to Us
Chief Operating Officer
66-76 Moray Street
Southbank, VIC, 3006
16. More information
Information about the privacy rights of individuals and privacy obligations imposed on organisations is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au
17. Links to other websites
Our websites may contain links to websites that are not owned or controlled by us. Whilst such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours.