1 May 2024
Towers Watson Australia Pty Ltd believes strongly in protecting the privacy of the individuals we deal with in all aspects of our business.
This Privacy Policy outlines the policy of Towers Watson Australia Pty Ltd (ABN 45 002 415 349) (“WTW”) on how we manage personal information held by us in the course of conducting our business. It applies to WTW and its Australian subsidiary companies.
WTW is bound by the Australian Privacy Principles under the Privacy Act 1988 (Commonwealth).
Why is personal information collected by WTW?
WTW collects personal information to provide a broad range of services. Personal information, including contact details, is collected so that we may provide:
- administration consulting, communications and website services for employee benefit (or superannuation) plans, so that we can properly administer the plans, including activities such as paying members' benefits, and providing appropriate advice to individuals and plan sponsors
- financial planning advice to individuals that is suited to their needs, and
- consulting services, including information and advice on actuarial, communication, investment, insurance, technology, human capital, organisational surveys, and management consulting matters, and information about our services, to trustees, employers and other entities.
What personal information is held by WTW?
Personal information held about individuals may include a person’s name, title, occupation, contact details, gender, date of birth, tax file number (TFN), health information, beneficiary information, salary, contribution and bank account details in relation to their membership of an employee benefit plan, or other information in relation to the provision of financial planning or organisational survey services.
We may hold personal medical information relating to an individual’s insurance cover under their employee benefits plan or any disability claim made under that plan. If such a disability claim is made, we may also receive information from the individual’s employer in relation to their employment history and workers compensation or other statutory disability claims.
In the event of the death of a person who is a member of a plan, their dependants or legal personal representative may be asked to provide details of the individual’s Will and their dependants, to enable the benefit to be paid.
Other personal information may also be required where it is necessary to do so in order to comply with the law or to enable WTW to fulfil its obligations to a person.
How is personal information collected?
Personal information is provided to WTW from many sources, including current and former plan members, survey participants. potential beneficiaries, plan trustees, plan administrators, employers, insurers, the Australian Taxation Office and other service providers we deal with.
If an individual is a member of an employee benefits plan and has provided their employer with their TFN, the employer is required by law to provide the TFN to us for the plan.
Sensitive information, such as information relating to a person’s state of health or medical history, is collected or kept by us only with the individual’s consent. This information will be used only for the purposes to which the individual has consented or as required by law.
What happens if personal information is not provided?
If personal information is not provided, in the case of administering employee benefit plans, this may result in individuals not being enrolled in plans, or not being able to make certain contributions, or their benefits being incorrect or reduced. Plan insurers many be unable to provide individuals with insurance cover, or their disability claims may not be able to progress. In the case of financial planning, organisational survey and consulting services, not having personal information may result in us being unable to provide the services requested of us, or our services having to be limited. Also, without sufficient personal information, we may not be able to contact you, for example if we need to respond to an enquiry or complaint you make.
If an individual wishes to access their personal information on a benefit plan’s Member Centre, a “cookie” is sent to their web browser when they log in. Cookies are small data files that enable the information they see to be personalised. They cannot read information off a hard drive. If an individual’s browser is set to refuse cookies, they will be unable to use the Member Centre.
Note that it is not possible for individuals to deal anonymously with us. Benefit plans must be able to identify individuals in order to pay their benefits and our financial planners and consultants must be able to identify them to provide them with financial services. For the same reason it is not possible for individuals to deal with us using a pseudonym.
Who may have access to personal information?
Keeping the confidentiality of information we handle in the course of our business is fundamental to achieving our business objectives and maintaining our reputation. We are bound by legal obligations of confidentiality to our clients.
WTW may provide other parties, such as other companies in the WTW group, plan trustees, WTW’s outsourced plan administrator, employers, insurers, actuaries, auditors, legal advisers, and other consultants, with access to personal information where it is necessary to conduct its business as summarised above. Personal information may also be disclosed to the Australian Tax Office, the Australian Transaction Reports and Analysis Centre, and other statutory bodies where this is required or authorised by law. Instances where personal information may be provided or handled by other parties include:
- Where benefits are transferred or rolled over to another superannuation arrangement, personal information will be provided to the trustee, administrator or provider of the new arrangement.
- If a member applies for a disability benefit from a benefit plan administered by WTW, health information may (with the member’s consent) be provided to the plan’s insurer, legal advisers, medical advisers, claims assessors and other consultants so they can assess or provide advice in respect of the claim.
- Personal information (including health information) may also be provided to a benefit plan’s insurer so they can calculate and price members’ insured benefits, to assess whether to provide a member with insurance cover, or to assess and pay a death claim in respect of an insured member.
- Other businesses that provide services to WTW, including document storage, printing and collating companies, and secure destruction companies, may receive personal information as part of providing those services.
- WTW provides certain benefit plan administration services via an outsourced arrangement with Australian Administration Services Pty. Limited('AAS'). In certain circumstances AAS may disclose personal information to third parties and/or related bodies corporate. For more information, please refer to AAS's Privacy Policy, available on its website.
- Certain information may be provided to the spouse or former spouse of a member of a benefit plan where required under the Family Law Act 1975.
Each of the organisations WTW deals with is required to keep the personal information it receives confidential and not use it for any unauthorised purpose.
What does WTW do to keep personal information secure?
WTW is committed to keeping personal information secure and takes steps to protect your information from loss, misuse or unauthorised access. These measures include physical and electronic security, and a comprehensive business continuity/disaster recovery plan.
Individuals can only access their personal benefit plan information online via the benefit plan’s Member Centre using their Member ID and password. They should ensure that they use a password that is difficult for other people to guess and that they keep it secure at all times.
Commonwealth legislation includes requirements for how long personal information must be held. WTW complies with these requirements.
How can you access your personal information?
Individuals are generally entitled to access all the personal information that WTW holds about them. If you believe that the personal information that WTW holds is not accurate, complete or up-to-date, you are entitled to request that the information be amended.
In some circumstances, and subject to the law, medical and other reports relating to a disability claim may not be made available directly to you, but may be released via your treating medical practitioner. We may not be able to release certain information, for example, where we are prohibited from doing so under the Family Law Act.
Members of benefit plans administered by WTW should follow their benefit plan’s procedures for accessing their personal information or dealing with issues related to privacy. Plan administrators can be contacted on either of the WTW phone numbers below or via your plan’s helpline. A copy of the benefit plan’s privacy policy is also available free of charge on request, or can be downloaded from the plan’s website.
Other individuals for whom WTW provides services, and who wish to gain access to their personal information, find out more about how WTW protects the privacy of individuals, or who believe their privacy has been breached should contact WTW’s Privacy Officer at either the address shown below, or via email.
If you are not satisfied with the response you receive, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC), who can be contacted at:
Director of Privacy Case Management
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
Contact
For further information please contact your WTW consultant or Actuary:
Melbourne 03 8681 9800
Level 32, 385 Bourke Street, Melbourne VIC 3000
Sydney 02 9285 4000
Level 16, 123 Pitt Street, Sydney NSW 2000
Email: aust_privacy@wtwco.com
