UTF Fire and Security

Privacy

 

COLLECTION
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.

In collecting personal information the company will take reasonable steps to ensure the individual knows that it is Chubb that is collecting the information; why the information is being collected; who will receive the information in normal circumstances; any legal requirements governing the information; how the individual can access their personal information held by Chubb; and what the consequences would be if the individual did not provide the information sought.

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:
• Required for health or other emergency reasons
• To investigate suspected fraud or unlawful activity
• It is required or authorised by law
• It is required for law enforcement
• To operate its business effectively

DATA QUALITY
Chubb will take reasonable steps to ensure that the personal information it uses is accurate, complete and up-to-date.

DATA SECURITY
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.

OPENESS
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 
b) Apply in writing to:

Privacy Officer
P O Box 1955
Ashfield NSW 2131

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:
• could pose a possible threat to life or health
• could cause an unreasonable impact on the privacy of others
• would be in response to a frivolous or vexatious request
• relates to existing or anticipated legal proceedings which could be prejudiced as a result
• relates to existing or anticipated commercial negotiations involving Chubb, and Chubb’s legitimate commercial interests could be prejudiced as a result
• is in any way unlawful
• could in any way prejudice law enforcement or security
• could prejudice the prevention, detection or investigation of seriously improper conduct, either within or external to Chubb’s operations.

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.

IDENTIFIERS
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:
• It is required for health or other emergency reasons
• It is required to investigate suspected fraud or unlawful activity
• It is required or authorised by law
• It is required for law enforcement

ANONYMITY
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 New Zealand without the consent of the individual unless:
• Chubb reasonably believes that the recipient of the information is subject to a law, binding scheme or contract providing substantially similar protection of personal information as provided for under New Zealand's Information Privacy Principles
• The transfer is necessary for the performance of a contract between Chubb and the individual, or for the implementation of pre-contractual measures taken in response to the individual’s request  
• The transfer is necessary for the performance or conclusion of a contract between Chubb and a third party that is in the interests of the individual concerned 
• The transfer is for the benefit of the individual; it is impractical to obtain the individual’s consent and, if it was, the individual would be likely to give it. 
• Chubb has taken reasonable steps to satisfy itself that the recipient of the information will manage the information consistent with this policy.

SENSITIVE INFORMATION
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:
• It is required by law
• It will prevent or lessen life or health threatening situations and it is not possible or practical to gain the individuals consent 
• The collection is necessary in relation to a legal or equitable claim.

COMPLAINTS
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
b) Apply in writing to:

Privacy Officer
P O Box 1955
Ashfield NSW 2131

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: 
• The name and contact details of the complainant
• The date the complaint was received 
• The nature of the complaint and the Chubb business unit involved 
• Details of the person(s) investigating the complaint 
• The outcome of the investigations 
• The dates and details of all contacts made with the complainant

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.