Vulnerable Client Policy

At NewSure Insurance Brokers ABN 70 088 689 070, we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

This Privacy Policy describes our current policies and practices in relation to the collection, handling, use and disclosure of personal information. It also deals with how you can complain about a breach of the privacy laws and how you can access the personal information we hold and how to have that information corrected.

What information do we collect and how do we use it?

When we arrange insurance on your behalf, we ask you for the information we need to advise you about your insurance needs and management of your risks. This can include a broad range of information ranging from your name, address, contact details, age to other information about your personal affairs including your assets, personal belongings, financial situation, health and wellbeing. We provide any information that the insurers or intermediaries who we ask to quote for your insurances and premium funding require to enable them to decide whether to insure you and on what terms or to fund your premium and on what terms.

Insurers may in turn pass on this information to their reinsurers. Some of these companies are located outside Australia. For example, if we seek insurance terms from an overseas insurer (e.g. Lloyd’s of London), your personal information may be disclosed to the insurer. If this is likely to happen, we inform you of where the insurer is located, if it is possible to do so.

When you make a claim under your policy, we assist you by collecting information about your claim. Sometimes we also need to collect information about you from others. We provide this information to your insurer (or anyone your insurer has appointed to assist it to consider your claim, eg loss adjusters, medical brokers etc) to enable it to consider your claim. Again this information may be passed on to reinsurers.

From time to time, we will use your contact details to send you direct marketing communications including offers, updates and newsletters that are relevant to the services we provide. We always give you the option of electing not to receive these communications in the future. You can unsubscribe by notifying us and we will no longer send this information to you.

What if you don’t provide some information to us?

We can only fully advise you and assist in arranging your insurance or with a claim, if we have all relevant information. The insurance laws also require you to provide your insurers with the information they need in order to be able to decide whether to insure you and on what terms. You have a duty to disclose the information which relevant to the insurer’s decision to insure you.

When do we disclose your information overseas?

If you ask us to seek insurance terms and we recommend an overseas insurer, we may be required to disclose the information to the insurer located outside Australia. For example, if we recommend a policy provided by Lloyd’s of London, your information may be given to the Lloyd’s broker and underwriters at Lloyd’s of London to make a decision about whether to insure you.

We will tell you at time of advising on your insurance if they are overseas and in which country the insurer is located. If the insurer is not regulated by laws which protects your information in a way that is similar to the Privacy Act, we will seek your consent before disclosing your information to that insurer.

Australian and overseas insurers acquire reinsurance from reinsurance companies that are located throughout the world so in some cases your information may be disclosed to them for assessment of risks and in order to provide reinsurance to your insurer. We do not make this disclosure. This is made by the insurer (if necessary) for the placement for their reinsurance program.

We may also disclose information we collect to the providers of our policy administration and broking systems that help us to provide our products and services to you. These policy administration providers and broking systems may be supported and maintained by organisations in New Zealand, the Philippines and Vietnam and your information may be disclosed to those organisations. Please note that the Privacy Act and Australian Privacy Principles may not apply to these organisations.

Family Violence, Supporting Vulnerable Clients and Financial Hardship Policy

This Family Violence, Supporting Vulnerable Clients and Financial Hardship Policy (Policy) has been developed to comply with National Insurance Brokers Association (NIBA) Insurance Brokers Code of Practice (the Code) and sets out how NewSure Insurance Brokers identifies and supports vulnerable Clients, including those affected by Financial Hardship and Family Violence.

For the purposes of this Policy, any reference to “Clients” includes clients of NewSure Insurance Brokers as well as any other individual entitled to Financial Hardship support under the Code.  This could include individuals who we are seeking to recover money from as we believe they have caused damage to an insured Client.

NewSure Insurance Brokers is committed to exercising greater care when dealing with vulnerable Clients.  A person may be vulnerable due to a range of factors, including:

1. age;
2. disability;
3. mental health conditions;
4. physical health conditions;
5. family violence;
6. language barriers;
7. cultural background;
8. Aboriginal or Torres Strait Islander status;
9. remote location; or
10. financial distress.

1 . POLICY STATEMENT

NewSure Insurance Brokers has a long-standing commitment to conducting its business with honesty and integrity and remains committed to full compliance with the Code and informing Clients and employees about information and assistance available to vulnerable people, including those experiencing Financial Hardship and Family Violence.

This policy and the NewSure Insurance Brokers internal policy and training programs assist employees to:

1. Identify and understand if a Client may be vulnerable;
2. determine how best, and to what extent, they can support a vulnerable Client;
3. take account of a Client’s particular needs or vulnerability; and
4. engage with a vulnerable Client with sensitivity, dignity, respect and compassion. This may include arranging additional support and referring the Client to specialised people or services.

NewSure Insurance Brokers may need to be flexible and vary the approach based on individual circumstances, including providing more personalised support to help navigate our processes and working within any processes and procedures.

2. FAMILY VIOLENCE

In Australian law, ‘Family Violence’ is defined as:

“violent, threatening or other behaviour by a person that coerces or controls a member of the person’s family or causes the family member to be fearful.”

Family Law Act 1975 (Cth), section 4AB.

Family Violence means much more than physical violence.  It includes:

• emotional abuse, psychological abuse, sexual abuse, financial or economic abuse; and
• damage to property.

The way employees deal with Clients who may be affected by Family Violence should facilitate, rather than act as a barrier to identifying Family Violence and improve the experience of those affected by Family Violence.

The aim of the Policy is to ensure that whenever Family Violence is identified or suspected, the safety of the Client affected by Family Violence and their family is protected.

NewSure Insurance Brokers recognises that Family Violence is unacceptable in any relationship and Clients experiencing Family Violence will be treated with dignity and respect.

The support of Clients experiencing Family Violence and their family is the highest priority.  Clients who indicate or disclose Family Violence are able to access support from NewSure Insurance Brokers that is appropriate to their circumstances.

3.   ASSISTING CLIENTS

NewSure Insurance Brokers can assist vulnerable Clients, including those experiencing Financial Hardship or Family Violence by:

• ensuring safe and confidential communication in light of individual circumstances;
• helping to set up new insurance policies;
• helping to arrange access to financial hardship support; and
• referral to specialist support services.

<These assistance measures may be expanded and varied depending on what our insurance partners have established.> ++ OPTIONAL DELETE IF NOT REQUIRED – Insert if acting under a binding agreement ++

In circumstances where the issue is complex or unable to be dealt with by the primary person who took the call, it is to be immediately referred to the Compliance Team for consideration.

The Client must be informed of this action.

4.  THIRD PARTIES

If NewSure Insurance Brokers are advised or we identify that a client or potential client requires support from a third party (eg: lawyer, interpreter, or friend) we will make reasonable accommodations to allow for this.

5.  FINANCIAL HARDSHIP

Financial Hardship occurs when Clients experience difficulty in meeting their financial obligations to NewSure Insurance Brokers.

The support NewSure Insurance Brokers can offer does not include support with paying the premiums under an insurance policy we have issued.

If a Client informs NewSure Insurance Brokers or we identify, that they are experiencing Financial Hardship, we will provide them with:

• if appropriate, contact details for the National Debt Helpline – 1800 007 007.

6.     TRAINING

Training is tailored to all employee roles within the business and the degree of contact they have with Clients.

NewSure Insurance Brokers will aim to ensure that all employees and have been trained and receive ongoing training so that they:

• are aware of NewSure Insurance Brokers policies and procedures when they are engaging with vulnerable Clients;
• identify vulnerable Clients, including those affected by Family Violence;
• deal appropriately and sensitively with vulnerable Clients; and
• apply the Family Violence & Supporting Vulnerable Clients policy and related policies and procedures relevant to their role in dealing with Clients.

Training is aimed at assisting employees to reduce the impact of vulnerability and Family Violence on Clients.

7.  REPORTING

Any notification of Vulnerability or Financial Hardship received by a member of staff must be reported to either the General Manager or the Operations Manager in writing within two business days.

8.    SUPPORT SERVICES AND RESOURCES