Chubb has adopted and will apply the National Privacy Principles contained in the Privacy Amendment (Private Sector) Act 2000, to govern the ways in which it collects, uses and disposes of personal information that comes into its possession.
Chubb will only collect personal information that is needed for it to operate its business activities effectively. Chubb will always endeavour to obtain personal information directly from the individual concerned. When this is impracticable or not reasonable, it will collect personal information fairly and by lawful means and without being unreasonably intrusive.
Use and disclosure
Chubb will only use or disclose personal information for the purpose(s) originally explained when the information was collected and for any related purpose that would reasonably be expected by both the individual concerned and Chubb. For example, Chubb would also use the name and address of a customer who requested the installation of a monitored alarm for invoicing purposes and to advise the person concerned of new or changed products and services available from Chubb. If Chubb uses personal information it holds for direct marketing of its products or services, it will always provide the individual the opportunity, at the point of first contact and at any time afterwards at the individuals request to decline receipt of any further marketing information. Otherwise, Chubb will neither use nor disclose personal information without the person's consent, unless:
Chubb will take reasonable steps to ensure that the personal information it uses is accurate, complete and up-to-date.
Chubb will take reasonable steps to protect all personal information in its possession, to ensure integrity of the information and that it is only accessed by those people whom Chubb authorises to do so. Personal information that is no longer needed by Chubb nor required to be held by law will be destroyed by secure means, or modified so that the data cannot be traced back to the person concerned.
Chubb will place this policy on its website and will have copies available in each of its major office locations to be provided to people on request.
access and correction
A person on whom Chubb holds personal information may:
a) Contact us by email at Privacy.Officer@chubb.com.au
Chubb will take reasonable steps to confirm the identity of the person making the request and will respond within 14 days of receiving the request. However, where the request is more complex or time consuming to comply with, Chubb will provide access to the information requested within 28 days.
Chubb reserves the right to deny access to personal information if providing access:
Should giving access to personal information involve revealing evaluative information generated within Chubb in connection with a commercially sensitive decision making process, Chubb reserves the right to give the individual an explanation for the decision made rather than direct access to the relevant information.
Where there is disagreement about direct access or where direct access to personal information is impractical or inappropriate, Chubb will discuss the possible use of a mutually acceptable intermediary.
If an individual advises Chubb that personal information held on them is inaccurate, incomplete or not up to date, Chubb will take reasonable steps to update the information accordingly. Should there be a disagreement between Chubb and the individual about whether the personal information is complete or up-to-date and the individual requests, Chubb will take reasonable steps to associate a statement from the individual that the information is not correct with the relevant record(s) held by Chubb.
Chubb reserves the right to levy a reasonable charge to meet the costs of providing access to personal information, although there will be no charge for the act of making the request for access.
Chubb will always provide reason(s) should it deny access to or correction of personal information it holds.
Chubb will not use an identifier assigned to an individual by a Government Agency as its own identifier; nor will it provide such an identifier to a third party without the individuals consent, unless disclosure is necessary for Chubb to fulfill its obligations to the Agency:
Where lawful and practical, Chubb will give individuals the option of not identifying themselves when dealing with the company.
Transborder Data Flows
Chubb will not transfer personal information outside Australia without the consent of the individual unless:
Chubb will not, without the consent of the individual, collect information concerning that individual’s racial or ethnic origins; political opinions; membership of a political , professional or trade association or trade union; philosophical or religious beliefs or affiliations; sexual preferences or practices or health information unless:
Where lawful and practical, Chubb will give individuals the option of not identifying themselves when dealing with the company people wishing to complain about any aspect of Chubb's management of their personal information may either:
a) Contact us by email at Privacy.Officer@chubb.com.au
In both instances setting out full details of their complaint will be required. To help Chubb complete a quick and effective investigation, this should include as much detail as the complainant has available that will help the Privacy Officer to identify to which part of the Chubb organisation their complaint relates.
The Privacy Officer will maintain a record of all complaints received, including:
These records will be held in a secure manner by the Privacy Officer, and will only be accessible to Senior Executives of Chubb Security Holdings Limited or of the subsidiary company or operating business unit to which the complaint relates. Otherwise, they will only be made available, if required or authorised by law or to assist with any investigations carried out by the office of the Federal Privacy Commissioner.
The Privacy Officer will also be responsible for investigating privacy complaints, or for referring complaints to the designated Privacy Officer of the Chubb subsidiary company or operating business unit concerned. The latter will be responsible for advising the Privacy Officer of Chubb Security Holdings Ltd (CSHL) of the progress of their investigations and for providing a final report to the complainant with a copy to the Privacy Officer of CSHL.
All complaints will be acknowledged within seven working days and a full response given within 28 days. Where it is not possible to complete the investigation of a complaint within 28 days, the complainant will be contacted once twenty eight days have elapsed with an estimate of when the investigation will be completed.