General Insurance Privacy Notice
from Bankwest
1. About this Privacy Notice
Bankwest is a division of the Commonwealth
Bank of Australia (ABN 48 123 123 124, AFSL
234945) (CommBank). This Privacy Notice
explains how and why CommBank, including
Bankwest and CommBank’s subsidiaries
(collectively, CommBank Group, we, us),
collects, holds, uses, and shares personal
information in relation to car and home
insurance products provided by Hollard
Insurance Partners Limited (ABN 96 067 524
216, AFSL 235030) (Hollard). Hollard is the
issuer and underwriter of those insurance
products.
2. Importance of providing
accurate information
If we ask for your personal information and
you don’t provide it to us, or the information
you provide us is inaccurate or incomplete, we
may not be able to provide you with products
or services that you are requesting, such as
helping you to obtain a quote or complete an
application for insurance.
In addition, if you do not provide accurate and
complete information in connection with your
insurance, you may not meet your responsibility
not to make a misrepresentation to Hollard
under the Insurance Contracts Act 1984 (Cth).
That could result in Hollard being unable to
provide you with products and services, and it
may affect your eligibility when making a claim.
3. What types of personal information we collect
Type of Information What kinds of personal information might be involved
Identity and contact
details
This may include your name, address, email address, phone number, and
date of birth.
Insurance Information Information in connection with your application and your policy, such as:
the risk you would like to insure; and
premiums, claims, complaints, queries or feedback, including their
status, scope, progress, and value.
Customer insights We may combine the data that we hold about you to get a more integrated
view of you as a CommBank Group customer. This includes combining
your information from internal and external sources (for example, about
other products you hold provided by the CommBank Group or our referral
partners, or census or Australian Bureau of Statistics data). We may
analyse this data to generate data insights which we may use for the
purposes described in ‘How we use your personal information’.
Behavioural information Information we generate about how you use our products, services, and
digital platforms.
Type of Information What kinds of personal information might be involved
Interactions including
call recordings
We may monitor and record calls and other interactions with us, like when
you visit a branch, or use web chat, the Bankwest website or app. We will
let you know if we are doing this.
Sensitive information There may be times where the information we collect to support you
will be sensitive information under privacy laws. The types of sensitive
information we collect may include:
health and other medical information; and
criminal history.
Information about your
personal circumstances
and relevant
information about other
policyholders
Such as other owners of the car or home you wish to insure.
4. How we collect personal information
We collect information directly from you most of the time, such as when you contact us to provide a
product or service via our digital channels, our branch network, or call centres. We may also collect
information from Hollard, in particular insurance information described in section 3.
There may also be times where we collect information about you from third parties, such as:
Type of Information Examples of third parties
Third parties acting on
your behalf or on our
behalf
A solicitor, executor, administrator, attorney, guardian, or trustee
Third party service providers who capture data on our behalf
Publicly available
sources
This may include social media platforms, particularly if you use it to make
a complaint.
5. How we use personal information
We use your personal information to develop an integrated view of you as a CommBank Group
customer, and to work with Hollard to develop and deliver general insurance products and services.
Examples of the activities we may undertake are set out below.
Purpose What use cases this might involve
Serve you as a customer We use information to provide products and services to you, including to:
manage our relationship with you;
support you with your applications, claims lodgement, and requests
while you hold a policy;
respond to complaints or other service inquiries; and
contact you to tell you about something important.
Purpose What use cases this might involve
Improve your customer
experience and our
products and services
We use your information to improve the way we and Hollard provide
products and services. For example, we may:
work with Hollard to design, price, provide, optimise, and improve
products, services, and digital features;
personalise the way content, services, and offers are presented or
delivered to you;
integrate your insurance policy with CommBank Group banking
products and services; and
review customer feedback, interactions, and how digital features are
being used.
Perform Analytics
Activities
We may develop customer insights as set out in the ‘What type of
personal information we collect’ section of this notice. We may use and
share those insights with Hollard to support the activities that we and
Hollard undertake.
Manage risk Such as to:
support the management of our information security and network
controls;
monitor and review call recordings, online chats and other business
activity for quality assurance, training and compliance purposes;
comply with our legal obligations; and
manage regulatory risk, validate information provided to us, and detect,
prevent, and investigate suspicious or fraudulent activity.
6. Disclosure
The information we hold about you may be disclosed directly to Hollard for the purposes set out in
this Privacy Notice in section 5 above. We may also share your information with other third parties,
including:
Who we share
information with
Examples of who those third parties might be
Other policyholders or
third parties entitled to
cover or benefits under
your policy
Another person named on your insurance policy
Your Authorised
Representatives
Solicitor, executor, administrator, attorney, guardian or trustee
External Service
Providers
We may share your information with our external service providers, for
instance, providers of certain outsourced functions such as technology,
mailing, and legal services, auditors, and accountants.
Dispute resolution
service providers
External dispute resolution schemes or mediators
Government and law
enforcement agencies
We may share your information with regulatory bodies, government
agencies and law enforcement bodies to comply with our obligations.
7. Marketing
From time to time, we may also use your
personal information to tell you about products
and services that you might be interested in,
including offers from our business and referral
partners, but we will stop if you tell us to.
We may contact you by various means,
including by mail, telephone, email, SMS,
push or in app notification, or other electronic
means, such as through social media, targeted
advertising, through CommBank Group
websites.
If you do not want to receive direct marketing
offers from us, you can opt-out by following the
instructions provided in the marketing message.
8. Overseas Disclosure
From time to time we may send personal
information to service providers or other third
parties who operate or hold data outside
of Australia. Where we send information
overseas, we make sure that appropriate data
handling and security arrangements are in
place. Australian law may not apply to some of
these entities. We may also send information
overseas to complete a particular transaction
or where this is required by the laws and
regulations of Australia or another country.
9. CommBank provision of
transitional services to Hollard
The home and car insurance products provided
by Hollard, are provided by a company that used
to be named Commonwealth Insurance Limited
(CIL). Ownership of CIL was transferred to
Hollard Australia in October 2022, and CIL was
renamed to Hollard Insurance Partners Limited.
To support the change in ownership, a number
of IT systems and services will be provided
by CommBank to Hollard for a transitionary
period until Hollard can migrate to separate
infrastructure and operations under its new
ownership.
During the transitional period, personal
information held by Hollard may continue to
be hosted and accessed by Hollard within the
CommBank IT environment. Hollard will have
limited access for the purposes of providing its
products and services to you.
10. Further information, including
how to access and update your
information or lodge a complaint
Go to bankwest.com.au/privacy for our Privacy
Statement. It tells you:
More about how we collect, use, store and
share your personal information;
How to access your information and correct it
if it’s wrong;
How to update your preferences about how
we contact you or ask not to receive direct
marketing; and
How to make a privacy-related complaint
(including about our compliance with the
Australian Privacy Principles) and how we’ll
deal with it.
This notice was last updated on 01 October 2022