Howden Insurance Brokers (S.) Pte. Limited (“HIB”) recognizes its obligations under the Personal Data Act 2012 legislation (PDPA) and all relevant data protection laws governing the collection, use and disclosure of personal data for the purpose for which the individual has given consent to.
1. Purpose of Collection
The personal data collected by HIB includes all personal data provided, or to be provided, to HIB by you and/or your insured persons or from other sources, for the purpose(s) as specified in HIB’s Data Protection Policy. HIB shall be able to contact you via telephone calls, text messages, faxes, mails or emails for this purpose.
2. Disclosure and transfer of Personal Data
HIB may disclose personal data belonging to you and/or your insured persons for the purposes specified in HIB’s Data Protection Policy to the parties below:
a) HIB employees;
b) HIB affiliates and related corporations
c) Insurers and agents
d) Medical professionals and institutions;
e) Local or overseas service providers to provide us with services such as printing, mail distribution, data storage, data entry, marketing and research, disaster recovery or emergency assistance services;
f) Parties that assist us to investigate, administer and adjudicate claims;
g) Financial institutions;
h) Industry associations;
i) Regulators, law enforcement and government agencies
These parties may be sited in Singapore or elsewhere in the world and in this regard, you consent to the transfer of your data outside of Singapore. Transfer of your personal data will only be made for one or more of the purposes specified in HIB Data Protection Policy.
3. Direct Marketing
HIB may use your personal data to send you direct marketing communications about our insurance products or our related services. This may be in the form of email, post, SMS, telephone or targeted online advertisements. HIB limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.
Our processing of your personal data for direct marketing purposes is based on our legitimate interests, but where opt-in consent is required by law we may seek your consent where applicable. You have a right to prevent direct marketing of any form at any time - this can be exercised by following the opt-out links in electronic communications, or by writing to us using the details below.
4. Withdrawal or refusal of consent to the collection, use and disclosure of personal data
You may refuse or withdraw your consent for HIB to collect, use, disclose and transfer your personal data and/or your insured persons’ personal data by giving HIB reasonable notice so long as there are no legal or contractual restrictions preventing you from doing so.
If you withdraw your consent for HIB to use your personal data for your and/or insured persons’ insurance matters, this will affect HIB’s ability to provide you and/or your insured persons with the products and services that you and/or your insured persons asked for or have with it.
5. Access, correction and erasure rights
You can request access to any personal data of yours and/or your insured persons that HIB has, and request to know how it is being used and disclosed for the last 12 months to the extent that your right is allowed by law. HIB may charge a reasonable fee for access to your and/or your insured persons’ personal data.
You also have the right to request correction of your and/or your insured persons’ personal data. HIB shall respond to an access or correction request within 30 days. In the event HIB is unable to respond to an access or correction request within 30 days from the time the request is made, HIB shall inform you and/or your insured person in writing by when it will be able to respond to your request.
You can ask us to erase your personal data, but only where:
- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent);
or
- following a successful right to object; or
- it has been processed unlawfully; or
- to comply with a legal obligation to which HIB is subject.
We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims;
There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances where we would deny that request.
6. Accuracy of Personal Data
You will ensure that any personal data disclosed by you and/or your insured persons are accurate. You shall give HIB notice in writing as soon as reasonably practicable should there be changes to those personal data.
7. A copy of HIB’s Data Protection Policy can be found on the Group website and you have deemed to have read the same.
8. You shall otherwise use reasonable efforts to assist HIB to comply with the relevant Personal Data Protection Act 2012 legislation and all relevant data protection laws.
You may make your request to withdraw your consent, access or correct your personal data by writing to:
Data Protection Officer
Howden Insurance Brokers (S.) Pte. Limited
61 Robinson Road
#07-01 Robinson Centre
Singapore 068893
Or email: [email protected]