Phoenix Risk Management Pty Ltd (ABN 67 121 681 927) trading as Putney Insurance Group is Corporate Authorised Representative No. 000456222 of Sirius Insurance Pty Ltd (AFSL 550 946, ABN 60 606 142 027). We are committed to protecting your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This policy explains how we collect, use, disclose and safeguard your personal information.
1. What Personal Information We Collect
We collect personal information that is reasonably necessary for us to provide insurance broking and related financial services. The types of information we may collect include:
- Full name, date of birth and contact details (address, phone, email)
- Business name, ABN, industry, and turnover details
- Information about your assets, vehicles, employees, and business activities
- Claims history, prior insurance arrangements, and loss experience
- Financial information required to assess premium affordability or payment plans
- Sensitive information such as health details (where relevant to personal accident or travel insurance), only collected with your consent or as required by law
- Website usage data (cookies, IP address, browser type) through our website
Where practicable, we collect information directly from you. We may also collect information from third parties such as insurers, underwriting agencies, other brokers, and publicly available sources.
2. How We Use Your Personal Information
We use your personal information to:
- Assess your insurance needs and arrange appropriate cover on your behalf
- Obtain quotations from, and place policies with, insurers and underwriting agencies
- Manage and administer your insurance policies throughout their life
- Assist with and advocate on your behalf during claims
- Comply with our legal and regulatory obligations (including AFSL requirements, anti-money laundering obligations, and court orders)
- Communicate with you about your policies, renewals, and relevant insurance news
- Improve our services and conduct internal business analysis
- Respond to enquiries and resolve complaints
3. Disclosure of Your Personal Information
To arrange and manage your insurance, we routinely disclose your personal information to third parties. These recipients may include:
- Insurers and underwriting agencies: to obtain quotations, bind cover, and manage claims
- Reinsurers: who provide risk capital to the insurers that cover you
- Loss adjusters and assessors: who investigate and assess claims
- Legal and other professional advisers: engaged to assist with claims or compliance matters
- Other insurance intermediaries: such as wholesale brokers or Lloyd's correspondents, where required to place specialist cover
- Premium funding providers: if you choose to fund your premiums
- Our service providers: including IT, cloud hosting, and administration partners who process data on our behalf under confidentiality obligations
- Regulatory and government bodies: such as ASIC, AFCA, and the ATO, where required by law
We do not sell your personal information to third parties for marketing purposes.
4. Overseas Disclosure
Some insurers, reinsurers, and service providers with whom we deal are located outside Australia, including in the United Kingdom (Lloyd's of London market), Europe, North America, and Asia. Where we disclose your information to overseas recipients, we take reasonable steps to ensure those recipients handle your information in a manner consistent with the APPs. In some cases, we may rely on your consent or on the fact that disclosure is required or authorised by Australian law.
By providing us with your information and engaging our services, you acknowledge that your personal information may be transferred to and held in countries outside Australia.
5. Security of Personal Information
We take reasonable steps to protect the personal information we hold from misuse, interference, loss, and unauthorised access, modification, or disclosure. These steps include physical security measures, access controls, encrypted communications, and staff training on privacy obligations.
We retain personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by law (typically a minimum of seven years for financial services records). When information is no longer required, we take reasonable steps to destroy or de-identify it.
6. Direct Marketing
We may use your contact details to send you information about insurance products, risk management insights, and other services we consider relevant to you. You may opt out of receiving marketing communications at any time by contacting us (see Section 9 below) or by using the unsubscribe link in any marketing email.
7. Cookies and Website Analytics
Our website uses cookies and similar technologies to improve user experience and understand how visitors interact with our site. This may include analytics data collected by third-party services such as Google Analytics. You can configure your browser to refuse cookies; however, some website features may not function correctly if cookies are disabled.
We do not use cookies to identify you personally unless you have provided us with your details through a form on our website.
8. Access and Correction
You have the right to request access to the personal information we hold about you, and to request correction of information that is inaccurate, incomplete, or out-of-date. We will respond to access and correction requests within a reasonable time (generally 30 days). In some circumstances, we may be unable to provide access for example, where doing so would unreasonably impact the privacy of another person, or where the information is subject to legal professional privilege. If we decline your request we will give you written reasons.
There is no charge for making a request, although we may charge a reasonable fee to cover the cost of retrieving and copying records.
9. Complaints
If you believe we have breached the APPs or the Privacy Act 1988, you may lodge a complaint with us using the contact details below. We will acknowledge your complaint promptly and investigate it in accordance with our internal complaints handling procedure, aiming to resolve all complaints within 30 days.
If you are not satisfied with our response, you may escalate your complaint to:
-
Australian Financial Complaints Authority (AFCA)
Free, independent dispute resolution for financial services complaints.
Phone: 1800 931 678 | Website: www.afca.org.au -
Office of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992 | Website: www.oaic.gov.au
10. Changes to This Policy
We may update this Privacy Policy from time to time. The current version will always be available on this page, with the effective date noted at the top. We encourage you to review this policy periodically.
Privacy Officer Contact Details
Phoenix Risk Management Pty Ltd (ABN 67 121 681 927)
trading as Putney Insurance Group
Corporate Authorised Representative No. 000456222 of
Sirius Insurance Pty Ltd, AFSL 550 946, ABN 60 606 142 027
Enquiries: Use our contact form
Phone: 1300 227 123
Offices:
QLD: Suite 188, 42 Manilla St, East Brisbane QLD 4169
NSW: G14, 1-15 Barr Street, Balmain NSW 2041
VIC: 3/14 Arthur St, Preston VIC 3072