BHSIC Personal Data Protection Principles
The very nature of BHSIC’s business is such that the collection, use and disclosure of personal information is fundamental to the products and services we provide. We work hard to respect and maintain personal privacy and accordingly align this policy with the Personal Data (Privacy) Ordinance (Cap.486) (“PDPO”) when collecting, holding, processing or using Personal Data in Hong Kong. We are equally committed to ensuring that all our employees and agents uphold these obligations. Under the PDPO, BHSIC is bound to the following principles with respect to your Personal Data:
Principle 1 – Collection of Personal Data
We will only collect Personal Data that is necessary for and directly related to our provision of insurance products and services (including, but not limited to processing your insurance application, arranging a contract of insurance with you, managing your account with us or handling a claim made under a contract of insurance) and the other purposes of our collection of Personal Data as set out in our Personal Information Collection Statement (“Primary Purpose”).
We will only collect Personal Data by lawful and fair means. Personal Data is collected when you complete an insurance proposal form, make a claim under a contract of insurance with us, or when you use or visit our website and submit other information (including Personal Data) to us.
Some information is collected automatically when you visit our website because your IP address needs to be recognized by the server. We may use the IP address information to monitor and analyze how parts of our website are used.
At or before the time we collect Personal Data from you, we will take practical steps to ensure you are aware of: a) the purposes for which the Personal Data is collected and used; b) the classes of persons to whom we may transfer the Personal Data; c) whether it is obligatory or voluntary for you to provide the Personal Data; d) if it is obligatory for you to provide the Personal Data, the consequences for you if Personal Data is not provided; e) your rights to request access to and to request the correction of the Personal Data; and f) the name and address of the individual to whom any such request may be made.
Principle 2 – Use of Personal Data
We will only use Personal Data for a purpose other than the Primary Purpose of collection (a “Secondary Purpose”) if: a) the Secondary Purpose is directly related to the Primary Purpose of collection; or b) you consent to the use or disclosure; or c) the Secondary Purpose is direct marketing and we will give you the express opportunity at the time of first contact to decline to receive any further direct marketing communications; or d) any of the relevant exemptions under the PDPO apply.
We may share Personal Data we have collected with the persons set out in our Personal Information Collection Statement.
Principle 3 – Data Quality
We will take practical steps to ensure that the Personal Data we collect, use or disclose is accurate, complete and up to date, having regard to the purpose (including any directly related purpose) for which the Personal Data is or is to be used. Please refer to Principle 6 below for details on how you can obtain and correct any Personal Data relating to you that we may hold.
We will retain your Personal Data for only as long as is necessary for the purposes set out in Principles 1 and 2 above as well as for purposes set out in the below Personal Information Collection Statement in compliance with all statutory and regulatory requirements in Hong Kong concerning the retention of personally identifiable information. We will take reasonable steps to destroy or permanently de-identify Personal Data if it is no longer needed for such purposes.
Principle 4 – Data Security
We will take all practical steps to ensure that Personal Data we hold is protected against unauthorized or accidental access, processing, erasure or other use. We provide a highly secure online infrastructure for activities conducted via our website, including SSL (secure socket layer) encryption, IDS (intrusion detection system) and the use of firewalls and anti-virus software. We also adopt stringent security procedures with the use of user ID and passwords, time stamping and audit trails for all transactions, together with a dedicated internal transaction security policy. Our online infrastructure is closely monitored and maintained, with data backup and data recovery procedures and mechanisms.
Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Data you might have with us has been compromised), please immediately notify us.
Principle 5 – Openness
Principle 6 – Access and Correction
Under the PDPO, you have the right (subject to certain exemptions) to:
Subject to certain exemptions under the PDPO, we will grant access to and correct Personal Data as requested by you. If we hold Personal Data about you and you are able to establish that the Personal Data is not accurate, complete and up to date, we will take reasonable steps to correct your Personal Data so that it is accurate, complete and up to date. We will provide reasons for any denial of access or a refusal to correct Personal Data.
Your requests to access or correct your Personal Data will be actioned within 40 days of our receipt of your request and copies of the requested Personal Data or Personal Data so corrected will be posted to your current address.
We may use some of the Personal Data we collect to send marketing material to our customers, but only in accordance with the PDPO. If we intend to use your Personal Data for direct marketing purposes or provide your Personal Data to third parties for direct marketing purposes, we will inform you of that in the Personal Information Collection Statement at the time we collect your personal data. We will provide you an opportunity to opt out of receiving direct marketing materials at that time. If you don’t opt out at that time but later decide you no longer wish to receive direct marketing, you may ask us to further cease any direct marketing by contacting us at the address below.
If you would like to access a copy of your personal data, correct or update your personal data, or have a complaint or want more information about how BHSIC manages your personal data, please contact BHSIC’s Privacy/Compliance Officer at firstname.lastname@example.org.