Privacy Policy

1. Purpose

This policy sets out how Kiwi Life Cover Limited will collect, use, manage, store, protect, retain and destroy private personal information.

2. Scope

This policy applies to Kiwi Life Cover Limited, its Director, employees, contractors, authorised representatives and any Financial Advisers operating under the Kiwi Life Cover Limited Financial Advice Provider licence. In this policy, Kiwi Life Cover Limited may also be referred to as “we”, “us”, “our” or “our personnel”.

3. Personal Information

Kiwi Life Cover Limited provides financial advice and related support services to clients. To provide these services, we collect, hold and use personal information, including information needed to understand client needs, objectives, financial position, insurance history, underwriting requirements and advice suitability.

Kiwi Life Cover Limited is committed to protecting personal information and applying sound privacy standards in the collection, storage, use, disclosure and disposal of personal information.

Privacy at Kiwi Life Cover Limited is subject to the Privacy Act 2020 and the Information Privacy Principles, which govern the collection, handling, use, disclosure, storage and correction of personal information.

4. Policy statement

Personal information in Kiwi Life Cover Limited’s care will be managed carefully, respectfully and securely, as if it were our own.

5. Procedures

Collection of Personal Information

Kiwi Life Cover Limited will collect personal information only where it is reasonably necessary for our business functions and for providing financial advice and related services.

We will make clients aware that personal information is being collected, the purpose for collection, who it may be shared with, and their rights to access and request correction of that information.

We may collect personal information during client onboarding, needs analysis, advice preparation, application and underwriting processes, policy servicing, claims support and ongoing reviews. Information may be collected face-to-face, by phone, video call, email, forms, electronic file notes, recorded conversations where applicable, or through product provider systems and adviser technology platforms.

We must record adequate information about personalised financial advice services provided to retail clients. Client records must be able to demonstrate compliance with Code Standard 5 and include copies of information and documents provided to, or received from, clients in connection with personalised services.

Kiwi Life Cover Limited will comply with obligations under the Privacy Act 2020, including obligations relating to use and disclosure of personal information and protecting that information from loss, unauthorised access, misuse, modification or disclosure.

Storing, Accessing and Availability of Personal Information

Kiwi Life Cover Limited will maintain reasonable safeguards to protect personal information against loss, misuse, unauthorised access, unauthorised use, inappropriate disclosure, modification or destruction.

We will provide individuals with access to their personal information where required or appropriate and respect their right to request correction of factually incorrect information.

Physical documents must be kept secure, including when there is a business need to take them outside Kiwi Life Cover Limited premises.

Electronic information must be kept secure through appropriate passwords, access controls, device security, secure storage, regular backups where applicable and reasonable information security practices.

Kiwi Life Cover Limited may use cloud-based systems and software to manage and store client information. Cloud computing means hardware or software delivered as a service over the internet.

Kiwi Life Cover Limited will acknowledge and respond to requests for personal information within 20 working days of the request being made, unless an exception under applicable law applies.

Where a person asks for correction of personal information held by Kiwi Life Cover Limited, we will respond to that request and advise the resulting action. This may include correcting factual information or attaching a statement of correction to the information held.

Use and Maintenance of Personal Information

Kiwi Life Cover Limited will only use or disclose personal information for the purposes for which it was collected, or for directly related purposes, unless we have consent or are otherwise permitted or required by law.

We will take reasonable steps to ensure information is accurate, complete, relevant and up to date for the purpose it is used. We may ask clients to confirm or update information to help maintain quality records.

Kiwi Life Cover Limited uses personal information to provide financial advice services, arrange insurance applications, support underwriting, service existing policies, assist with claims and meet legal, regulatory and compliance obligations.

We may share personal information with relevant product providers, underwriting teams, claims teams, compliance support providers, technology providers and professional advisers where this is necessary to provide our services or meet our obligations.

Kiwi Life Cover Limited will support product providers and other authorised parties who receive personal information from us to protect that information appropriately.

Archiving and Destruction of Personal Information

Kiwi Life Cover Limited will maintain and apply retention and disposal practices for personal information that are consistent with this policy, legal requirements and good record-keeping practice for financial advice services.

6. Privacy Incidents

A privacy incident includes a privacy breach, near miss, unauthorised access, loss of information, inappropriate disclosure or any action where Kiwi Life Cover Limited may not have complied with privacy legislation or this policy.

Employees and contractors will endeavour to resolve privacy incidents at source with affected parties where appropriate and must promptly report incidents to the Privacy Officer.

Kiwi Life Cover Limited will maintain clear processes for recording, managing, escalating and responding to privacy incidents, with clear lines of responsibility.

All privacy incidents will be recorded by Kiwi Life Cover Limited. Affected parties will be notified as soon as practicable where the incident is serious and likely to cause harm, unless a legal exception applies or notification may create a risk to health or safety.

7. Responsibilities for Personal Information

Kiwi Life Cover Limited has the following roles and responsibilities embedded in the business.

The Director is responsible for ensuring the business understands the importance of protecting client information through good monitoring, secure systems, file management and privacy practices.

The Director will model sound privacy practices and ensure privacy is treated as a core part of Kiwi Life Cover Limited’s culture and customer outcomes approach.

Kiwi Life Cover Limited has nominated its Director as Privacy Officer. The Privacy Officer is the point of contact for privacy matters and oversees privacy-related complaints, investigations and responses, including any matters involving the Office of the Privacy Commissioner.

All employees and contractors must ensure this policy is followed within their area of responsibility. They must consistently collect, use, store and destroy privacy-related information in accordance with this policy and report privacy incidents to the Privacy Officer.

• maintain good privacy behaviours;
• promote privacy at work;
• participate in privacy training where required;
• report all privacy breaches and near misses to the Privacy Officer; and
• identify and escalate privacy risks.

8. Further Obligations

Kiwi Life Cover Limited will:

• train and inform employees and contractors about this policy and require the principles to be applied when fulfilling their roles;
• protect the privacy of employees and contractors where applicable; and
• regularly review business processes relating to the collection, recording, access, use, storage, disclosure and destruction of personal information to ensure they remain relevant and reflect good practice.

9. Authorisation hierarchy

Kiwi Life Cover Limited will maintain clear levels of authorisation and controlled access to client information on a need-to-know basis.

Copies of original documents must be scanned, archived and filed with relevant forms so they can be retrieved if required by a regulator, external auditor, product provider or for internal compliance purposes. Documents may be held in secure digital archive format.

10. Controls

11. Related policies

• Code of Conduct Policy
• Product Provider Selection Policy
• Complaints Handling Policy
• Conflicts of Interest Policy
• Information Systems Security Policy
• Record Keeping Policy

12. Other references

• Privacy Act 2020
• Information Privacy Principles
• Financial Markets Conduct Act 2013
• Financial Markets Conduct Regulations 2014
• Code of Professional Conduct for Financial Advice Services
• Credit Contracts and Consumer Finance Act 2003, where applicable
• Consumer Guarantees Act
• Fair Trading Act 1986

13. Review

This policy and supporting procedures will be reviewed at least annually or whenever a significant change, incident, business process change, legislative change or regulatory event makes review necessary.

14. Approval