Last updated - September 2021
For all other personal information collected by QBE, the privacy practices of each local QBE entity will be explained in separate privacy policies which are made available to you when you first contact us in your location and when your personal information is first collected by that relevant QBE entity.
‘Personal information’ is any information from which individual persons can be identified, directly or indirectly.
For more information on the privacy practices and policies of the QBE Group entity in your region, please see applicable local QBE privacy policies which apply in addition, for example:
- US – QBE NA Privacy Statement and Notice for California Residents
- NZ - Privacy & your personal information
This website is operated by QBE Insurance (Australia) Limited who will, for the purposes of relevant data protection laws (including the EU General Data Protection Regulation (“GDPR”)), be the primary data controller of your personal information.
There may also be other QBE entities responsible for your personal information, such as the QBE entity that first collects personal information from or about you. For example, for personal information collected on other QBE websites, the QBE entity operating the relevant website will be the data controller of your personal information; if you are a supplier, the QBE entity to whom you provide services will be the data controller of your personal information.
- what personal information we collect and when and why we use it;
- how we share personal information within QBE and with our service providers, regulators and other third-parties;
- explaining more about direct marketing;
- transferring personal information globally;
- how we protect and store personal information;
- legal rights available to help manage your privacy;
- how you can contact us for more support.
WHAT PERSONAL INFORMATION WE COLLECT AND WHEN AND WHY WE USE IT
Persons We Collect Information From
We may collect personal information from anyone who may visit our website or otherwise provide personal information via our website.
Personal information we collect automatically and use if you use our website
When you visit the website, our server automatically collects certain browser or device generated information, including but not limited to your:
- IP address;
- date, time and duration of your visit;
- browser type;
- operating system; and
- page visits.
We may use this automatically collected information for aggregated analytical purposes but we do not use it to try to uniquely identify you as an individual and we do not associate it with the information you provide voluntarily. However, we may use this information to associate you with the organisation you work for, or to understand the approximate geographic area you may be visiting the website from.
Personal information we collect and use if you provide it to us
If you are an investor in QBE, you will have provided basic personal information when dealing with shares or other securities in QBE.
In using our website, you may voluntarily provide personal information to us in the following ways:
- by signing up for news alerts (including those from any of our third-party partners where we notify you and you confirm in advance), newsletters or other forms of communication;
- by registering for an event or webinar;
- by corresponding with us by phone, e-mail or otherwise using the contact details provided on our website;
- when making an enquiry with us.
Typically, the personal information you give us may include name, address, e-mail address, phone number, and any personal details required to resolve any inquiry.
Legal basis for using your personal information
The following is an overview of our purposes for using your personal information. Please remember that additional information may be provided to you in a separate notice or contract or where you access any of our other websites or online products or services. We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
- you have consented to the processing (for example, where you consent to the placing of cookies on our websites, or where you proactively sign-up for a QBE newsletter);
- we need to use your personal information to comply with a relevant legal or regulatory obligation that we have.
If you would like to find out more about the legal basis for which we process personal information, please contact us.
We use the personal information we collect to:
- allot shares, maintain a register of our shareholders and members, and communicate with those members (through reports, meetings etc.);
- improve our websites based on how you and other users interact with our content;
- customise or personalise our websites to users' needs (for example, by showing content or language which is relevant to your geographic location);
- correspond with website users to resolve their queries or complaints; and
- send you marketing communications (e.g. newsletters), where it is lawful for us to do so.
SHARING PERSONAL INFORMATION WITH OTHERS
We share your personal information in the manner and for the purposes described below:
- within QBE Group, where such disclosure is necessary to provide you with our products and/or services and/or to manage our business;
- with third party service providers (who will operate under our instructions) who help manage our business and assist us in providing information or services to you (for example, suppliers of relationship management or marketing solutions or third party IT service providers to manage and improve the website. These third parties may need access to your information and will have agreed to confidentiality restrictions and obligations to use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us); or
- with government organisations and agencies, law enforcement and regulators if needed to comply with applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.
If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third-party purchaser of our business or assets.
When we work with third parties, we make clear to them the importance we place on privacy, data security and the standards we expect to be upheld. We include provisions in applicable contracts with third parties to comply with privacy laws and the QBE Group Code of Ethics and Conduct applies to anyone who represents QBE in any capacity.
TRANSFERRING PERSONAL INFORMATION GLOBALLY
QBE is a group with affiliates, divisions and offices situated throughout the world, and it will therefore be necessary, from time to time, to pass your information between QBE locations internationally. A full list of our locations is available here: https://www.qbe.com/about-qbe
Accordingly, your personal information may be transferred and stored in regions and countries outside the EU or your country of residence, including Australia, Asia Pacific, New Zealand, Pacific Islands, India, North America and within Europe, including QBE's services company located in the Philippines which provides sales, claims administration and other services to the Group, and/or to any other countries where QBE entities operate or may operate in the future, each of which may be subject to different standards of data protection to your country of residence.
We will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end:
- we will ensure any transfers within QBE Group are covered by an agreement entered into by members of QBE (an intra group data transfer agreement) which contractually obliges each member of QBE to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within QBE (this agreement incorporates the EU Commission approved Standard Contractual Clauses, where needed to ensure that EU personal information receives the same level of protection as if it remained within the EEA). We may also rely on other mechanisms provided for by all applicable privacy laws to ensure any personal information transferred within our group of companies complies has adequate safeguards and is compliant with such laws;
- if/where we transfer your personal information outside QBE or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information in accordance with all applicable privacy laws; or
- where we receive requests for information from law enforcement or regulators or when required to do so by law, we carefully validate these requests before any personal information is disclosed.
EXPLAINING MORE ABOUT DIRECT MARKETING
How we use personal information to keep you up to date with our products and services
We may use personal information to let you know about our products and services that we believe will be of interest to you (for example, where you have signed up for one of our newsletters). We may contact you by email, post, or telephone or through other communication channels that you agree to be contacted through. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
How you can manage your marketing preferences
To protect privacy rights and to ensure you have control over how we manage marketing with you:
- we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
- you can ask us to stop direct marketing at any time by following the "unsubscribe" link you will find on all the email marketing messages we send you. Alternatively, you can contact us at https://www.qbe.com/contact-us. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email); and
We recommend you routinely review the privacy policies or notices and preference settings that are available to you on any social media platforms as well as your preferences within any account you may have with us.
HOW WE PROTECT AND STORE YOUR INFORMATION
We take the security of the information we collect seriously. We have implemented and maintain technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned.
Measures we take include:
- placing confidentiality requirements on our staff members and service providers;
- following strict security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it; and
- using secure communication transmission software (such as "transport layer security" or "TLS") that encrypts all information you input on our website before it is sent to us. TSL is an industry standard encryption protocol for the financial services industry (recommend by PCI DSS and relevant regulators) and this ensures that the information is reasonably protected against unauthorised interception.
However, in relation to our website, it is important to remember that no website can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect User IDs and passwords, please take appropriate measures to protect this information.
Storing your personal information
In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements (for example, certain records are kept for 7 years after the completion of a policy or claim).
Where we have obtained your personal information in order to provide you with marketing information for our products and services (including QBE newsletters), your personal information will be stored by us only as long as you do not change your mind to receive such materials from QBE.
In other specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
A cookie is a small text file containing small amounts of information which is downloaded to/stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website.
LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY
You may access or request correction of the personal information that we hold about you by contacting us. There are some circumstances in which we are not required to give you access to your personal information. There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
If you wish to exercise any of the rights detailed in this section, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Under EU laws, some of the following additional rights may be available:
- Right to access personal information
A right to request that we provide you with a copy of your personal information that we hold and you together with how and on what basis your information is processed.
- Right to rectify or erase personal information
A right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.
Request that we erase your personal information in limited circumstances where:
- it is no longer needed for the purposes for which it was collected;
- you have withdrawn your consent (where the data processing was based on consent - for example where you have provided your consent to receive marketing newsletters, you can withdraw this consent at any time);
- following a successful right to object (see right to object);
- it has been processed unlawfully; or
- to comply with a legal obligation to which QBE is subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defense of legal claims.
- Right to restrict the processing of personal information
Ask us to restrict your personal information, but only where:
- its accuracy is contested, to allow us to verify its accuracy;
- the processing is unlawful, but you do not want it erased;
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction, where:
- we have your consent;
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
- Right to transfer of personal information
Ask us to provide your personal information to you in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
- Right to object to the processing of personal information
Object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
- Right to object to how we use personal information for direct marketing purposes
Request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
- Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
Ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union. We may redact data transfer agreements to protect commercial terms.
You have the right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. If you are in Australia, you may contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
PRIVACY AT QBE
Privacy at QBE is governed centrally through our Group Compliance team and our Group Privacy Officer, who reports to the Chief Compliance Officer, who reports to the Group General Counsel and Company Secretary. The Group Privacy Officer is responsible for the Group Privacy Framework (summarised here) which seeks to ensure that there are robust and effective privacy practices, procedures and systems in place across the global business. The Group Privacy Officer chairs QBE’s internal Global Privacy Council. QBE’s Global Privacy Council ensure that there is adequate consideration and review of the privacy risks and implications related to international activities that cross all segments of our business, this includes undertaking privacy impact assessments to identify and mitigate privacy risks.
QBE provides mandatory compliance training to ensure our employees and management understand all relevant laws, regulations and internal policies and how to apply and adhere to them in their daily work. The compliance training course content includes topics such as data protection, collection/storage/security of personal information, sensitive information, the QBE privacy impact assessment process and dealing with data breaches.