QBE LMI's privacy assurance
Personal information means any information or an opinion about an identified individual, or an individual who is reasonably identifiable.
For information on how QBE LMI handles your credit-related personal information, please refer to the QBE LMI Credit Reporting Policy.
Kinds of personal information we collect and hold
QBE LMI collects personal information when it:
- provides lenders' mortgage insurance and for related business activities like reinsurance, and securitisations,
- engages agents, contractors and suppliers, and
- pursues marketing prospects and opportunities.
The kinds of personal information collected can be quite broad and includes loan application information, contact details (including your telephone number and email address) and identification information, financial information and supporting documentation (including credit and employment history), transaction history information, banking details, personal references and employment information.
QBE LMI may also collect sensitive information about you, including health information and information about your membership of professional associations.
For legal reasons and subject to our obligations under the Australian Privacy Principles, information collected may be retained by QBE LMI after a transaction or relationship has concluded.
In holding your personal information, QBE LMI uses a variety of physical and electronic security measures, including restricting physical access to its offices to protect your personal information from misuse, interference or loss, and from unauthorised access, modification and disclosure.
How personal information is collected and held
Wherever it is possible and practical to do so, QBE LMI collects personal information from you directly. For example, we may collect your personal information when you contact us by telephone, when you send us a letter or email or when you submit or give us a completed form.
When offering lenders' mortgage insurance, QBE LMI usually collects your personal information from lender banks, credit unions, building societies, mortgage brokers or originators (each a "mortgage lender"). In those circumstances, the mortgage lender collects your personal information from you and then provides it to us. QBE LMI may also collect your personal information from publicly available sources of information.
Your personal information is held in secure environments including computer systems and databases, paper records and telephone recordings. We may utilise related companies, agents and third-party suppliers for data storage services.
What happens if you do not provide your information to QBE LMI
The information collected when QBE LMI offers lenders' mortgage insurance to a mortgage lender is required under the Insurance Contracts Act 1984 (Cth) (“Insurance Contracts Act”) and is necessary for QBE LMI to undertake its business. If you do not provide the information requested, then QBE LMI will not be able to issue insurance to the mortgage lender. As a result, the mortgage lender may not be able to provide the mortgage to you.
Purposes for collecting, holding, using and disclosing your personal information
When QBE LMI offers lenders' mortgage insurance to a mortgage lender, QBE LMI collects, holds, uses and discloses your personal information to:
- assess the risk of:
o providing lenders' mortgage insurance to the mortgage lender
o you defaulting on your obligations to the mortgage lender
o you being unable to meet a liability that might arise under a guarantee, in respect of mortgage finance given (or to be given) by the mortgage lender to another person
- administer or vary any lenders' mortgage insurance cover provided, including dealing with claims, recovery of proceeds and enforcing the mortgage in the place of the mortgage lender
- conduct risk assessment and management involving securitisation, credit scoring, portfolio analysis, reporting, fraud prevention and claim recovery, and
- comply with legislative and regulatory requirements including under the Privacy Act and the Insurance Contracts Act as amended from time to time.
QBE LMI may also use your personal information for such other purposes as may be permitted under the Privacy Act.
When engaging suppliers, agents, and contractors, QBE LMI will use fair means to obtain the necessary personal information required to satisfy QBE LMI’s requirements given the nature of the contract.
When QBE LMI pursues marketing prospects and other opportunities, QBE LMI may, subject to the Privacy Act, also collect, hold, use and disclose your personal information so that we may contact you and provide you with updated news and communications and information about our services (for example about property seminars we may be hosting). If you are our business partner, we may also use your personal information to contact you about our products.
Disclosure of your personal information (who the information may be disclosed to)
Where information is collected for lenders’ mortgage insurance purposes, QBE LMI may disclose your personal information to:
- our related companies, whether in Australia or overseas, for processing (specifically in the Philippines)
- the mortgage lender
- credit reporting and ratings agencies
- other mortgage insurers
- parties for the purpose of securitisation
- a guarantor or potential guarantor
- our service providers in Australia and overseas, including India and the Philippines (including marketing companies, data consultants and IT contractors)
- to parties for the purposes of fraud prevention
- our agents, contractors, and external advisers
- your legal and financial advisers
- government and other regulatory bodies
- mercantile agents if you default on your obligations to the lender
- payment system operators, and
- other financial institutions and credit providers.
Generally, and in relation to lenders’ mortgage insurance, QBE LMI may also need to exchange information between contractors, suppliers and, depending on the nature of the information from other credit providers, advisors. If necessary, QBE LMI will also share your information with a credit reporting body.
Where information is collected for marketing prospects and other opportunities, QBE LMI may disclose your personal information to our service providers (including marketing companies, data consultants and IT contractors) and to our related companies whether in Australia or overseas (specifically in India and the Philippines).
Please refer to the QBE LMI Credit Reporting Policy for further information on default reporting.
Likely overseas disclosures
In some instances, our service providers and related companies to which we disclose personal information may be located overseas. The countries in which these service providers and related companies are located may vary from time to time, but include the Philippines, India, Ireland, the USA, China and countries in the European Union.
Where personal information has been disclosed to an overseas recipient, there is a possibility that in certain cases that recipient may be required to disclose it under a foreign law. Where this occurs, such disclosure is not a breach of the Act.
Access, corrections and complaints
Our aim is to always have accurate, complete, up-to-date and relevant personal information. When you deal with us, you should check the information we hold about you is correct.
If you think we have not handled your personal information correctly, you can make a complaint with our Customer Care team, the Office of the Australian Information Commissioner (OAIC) or, in certain circumstances, the Australian Financial Complaints Authority (AFCA). We recommend you contact us first so we can try and resolve your complaint effectively and efficiently as generally, the OAIC and AFCA will refer you back to us if you have not already complained to us.
Our Customer Care team will contact you to acknowledge your complaint and provide you with a unique reference number. You will have the opportunity to explain why you are unhappy with how we have handled your personal information and provide information to support your complaint. Our Customer Care team will review your concerns, taking into account all relevant information including relevant privacy requirements and work with you to try and resolve your complaint.
If you are not satisfied with the outcome of your complaint, you can take your complaint further including to the:
Australian Financial Complaints Authority (AFCA)
AFCA can consider certain privacy complaints. You should contact AFCA to check if they can help you.
Phone: 1800 931 678
Mail: Australian Financial Complaints Authority, GPO Box 3, MELBOURNE VIC 3001
Date prepared: 7 May 2021
Date effective: 7 May 2021