This Privacy Notice describes how Willis Towers Watson handles personal information about You which Willis Towers Watson collects in connection with the services Willis Towers Watson provides. It also explains certain legal rights You have in connection with Your personal information which is handled by Willis Towers Watson. This Privacy Notice may be revised from time to time to reflect changes in law or changes in Willis Towers Watson's business operation. This Privacy Notice was last updated on 27 April 2020.
1. What is the purpose of this Privacy Notice, and does it apply to me?
This Privacy Notice explains how Willis Towers Watson handles personal information about You. Unless otherwise stated in any other notices provided to you, this Privacy Notice will apply to You if You directly or indirectly benefit from the services Willis Towers Watson provides (typically consultancy and solutions for human capital and benefits, and/or risk consulting and technology) in Thailand.
1.1 This Privacy Notice will apply to You if Willis Towers Watson obtains Your personal information in connection with Willis Towers Watson's business activities.
1.2 Please note that this Privacy Notice does not apply to You if You are:
1.2.1 an employee, contractor, or any other type of worker engaged by Willis Towers Watson.
1.2.2 a visitor to any website which is maintained by the Willis Towers Watson Group (including the Willis Towers Watson Group's main website at http://www.wtwco.com and the online tools accessible from there), in which case the collection of any personal information about You will be subject to the separate website privacy notice for the relevant website. Unless specifically stated otherwise, the website privacy notice applicable to all website maintained by the Willis Towers Watson Group can be found at: http://www.wtwco.com/th-th/notices/global-website-privacy-notice
1.3 Nothing in this Privacy Notice alters any existing relationship between You and Willis Towers Watson, or creates any new relationship between You and Willis Towers Watson. Nothing in this Privacy Notice affects any right You have under any applicable law which regulates the way in which Willis Towers Watson handles Your personal information.
2. Who is responsible for the handling of my Personal Information?
Towers Watson Thailand (Limited) will be responsible for ensuring that Your personal information is handled properly.
Towers Watson Thailand (Limited) is located at 9th Floor, Metropolis Building, 725 Sukhumvit Rd, Khlong Tan Nuea, Watthana, Bangkok 10110, Thailand.
Telephone: +66 2239 9000
3. What Personal Information about me does Willis Towers Watson collect?
Personal information collected by Willis Towers Watson will vary depending on many factors, but may include a broad range of personal information, including personal information of a sensitive nature such as details of Your bank account, finances, and information concerning Your health.
3.1 The type and amount of personal information about You which Willis Towers Watson collects may include any combination of the following:
3.1.1 Your contact details such as name, postal address, email address, and telephone number;
3.1.2 Your gender, date/place of birth, marital status, dependents, nationality, country of residence, occupation, hobbies, habits, and other similar demographic information;
3.1.3 Your unique identifiers such as bank account number, credit card number, national Identification number, passport number, and driver's licence number;
3.1.4 Information about Your finances, such as details of Your income, assets, investments, debts, creditworthiness, tax status, and existing pension/insurance arrangements;
3.1.5 Information about Your physical and mental health, including Your medical history, description of illness or injury suffered, and any specific treatment received;
3.1.6 Information about You which Willis Towers Watson is obliged to check for legal or regulatory reasons, such as information relating to Your identity, any directorship of companies You hold, and Your criminal history (including allegations of crimes);
3.1.7 Other information about You which Willis Towers Watson handles in connection with the services Willis Towers Watson provides to You or a client of Willis Towers Watson, such as Your personal circumstances that need to be described in arranging any services for You or a client of Willis Towers Watson, details of events in which You are involved, and facts and circumstances involving You in respect of which Willis Towers Watson is asked to advise a client; and
3.1.8 Other information about You which Willis Towers Watson collects as part of its day-to-day business operation, such as information about Your visit to Willis Towers Watson office, Your attendance at meetings and events hosted by Willis Towers Watson, and Your correspondence with Willis Towers Watson's employees, advisors and consultants.
3.2 Please note that personal information which Willis Towers Watson collects may include sensitive information such as Your racial/ethnic origin, religious/philosophical/political views or affiliations, membership of trade union or professional/trade association, sex life, criminal record, and health.
3.3 Willis Towers Watson will collect Your personal information only if and to the extent it is necessary for one or more of the purposes described in Section 4 below.
3.4 Willis Towers Watson will collect Your personal information during such time when it is necessary for one or more of the purposes described in Section 4 below (e.g. upon set up of benefits administration, commencement of or during the provision of services where personal information is required).
4. Why does Willis Towers Watson collect your Personal Information?
Willis Towers Watson collects personal information mainly to provide Willis Towers Watson's services (e.g. to provide risk management advice, consultancy and solutions relating to human capital and benefits, and/or risk consulting and technology), but Willis Towers Watson also collects personal information for a variety of other related business purposes.
4.1 Willis Towers Watson collects and uses Your personal information primarily for the following purposes:
4.1.1 to provide services which You personally request (e.g. where You request Willis Towers Watson to provide services for Your domestic purpose or Your business purpose);
4.1.2 to provide services which You did not personally request but is nevertheless arranged for Your benefit (e.g. where Your employer asks Willis Towers Watson to arrange health plan, pension plan, or other forms of employee benefits, or where Your employer asks Willis Towers Watson to provide certain types of consultancy and solutions relating to human capital and benefits, and/or risk consulting and technology); and
4.1.3 to provide services which You did not personally request but were requested by Willis Towers Watson's client and requires Willis Towers Watson to interact, directly or indirectly, with You (e.g. where you submit a benefit claim and we are required to administer the claim under the relevant benefits).
4.2 Willis Towers Watson also collects and uses Your personal information for the following related purposes:
4.2.1 where applicable, to enable other specialist risks advisors, pension providers, banks and other lenders (including premium finance providers), health professionals, lawyers, accountants, auditors, consultants, and other like third party professional advisors and service providers to provide their services (to the extent their involvement is inherent in or necessary in connection with the services provided by Willis Towers Watson);
4.2.2 to enable affiliates of the Willis Towers Watson Group and non-affiliated third party services providers (e.g. IT services providers, administrative support service providers, etc.) to provide services that directly or indirectly support Willis Towers Watson's business operation and the services provided by Willis Towers Watson;
4.2.3 to comply with legal or regulatory requirements imposed on Willis Towers Watson or a client of Willis Towers Watson (including the requirement to conduct 'Know-Your-Client' checks, anti-money laundering/sanctions screening, and other like due diligence checks);
4.2.4 to improve or develop the products and services Willis Towers Watson provides to Willis Towers Watson's clients in general (e.g. improving internal business processes, providing analysis on trends in the market, devising ways to simplify/streamline the service provision, designing new types of products/services, etc.); and
4.2.5 to contact You and generally maintain the relationship between You and Willis Towers Watson in connection with the services provided by Willis Towers Watson, and to keep You informed about the products, services, and opportunities offered by Willis Towers Watson and other members of the Willis Towers Watson Group which might be of interest or benefit to You.
4.3 For the purpose of improving or developing Willis Towers Watson's products and services (see Section 4.2.4 above), Willis Towers Watson may use Your personal information to create and analyse statistical data, and the outcome of such analysis might be shared with third parties. However, such analysis will be conducted solely on an aggregated and anonymous basis and under no circumstance will any specific personal information relating to You or any information from which You could be identified be included in such analysis.
4.4 Your personal information will be used for relationship maintenance/marketing purpose (see Section 4.2.5 above) only if You are Yourself a client of Willis Towers Watson or if You are the business contact at Willis Towers Watson's client (i.e. You fall within the category of persons described in Section 5.2.1 or 5.2.2 below). For further information regarding Willis Towers Watson's direct marketing practice, please refer to Section 7 below.
5. How does Willis Towers Watson obtain Your Personal Information?
Personal information handled by Willis Towers Watson is typically provided by a client of Willis Towers Watson. However, depending on the circumstances, Willis Towers Watson might collect personal information from other third parties who are relevant to the services Willis Towers Watson provides, and Willis Towers Watson might also collect personal information directly from You.
5.1 Where Willis Towers Watson is required to handle Your personal information, Willis Towers Watson generally obtains Your personal information indirectly from a client of Willis Towers Watson (typically a company, partnership, public authority, or other like body corporate) which receives services that affect You. For example, Willis Towers Watson might indirectly receive Your personal information from a client of Willis Towers Watson where the client asks Willis Towers Watson to:
5.1.1 arrange any program that benefits the client's directors, officers, employees, customers, guests, visitors, or other persons that interact with the client;
5.1.2 arrange pensions and other employee benefits for directors, officers, and employees of the client;
5.1.3 provide consultancy and solutions relating to human capital and benefits (e.g. managing Your retirement benefits), and/or risk consulting and technology;
5.2 Occasionally, it will be necessary for Willis Towers Watson to obtain Your personal information directly from You. For example, this could be the case where:
5.2.1 You are employed or otherwise engaged by a client of Willis Towers Watson and Your job involves any direct interaction with Willis Towers Watson (e.g. if You are a Risk Manager or a Finance Director of a client of Willis Towers Watson, and You are involved in making service purchase decisions);
5.2.2 You directly interact with Willis Towers Watson as a client of Willis Towers Watson in respect of Your own business, profession, or trade (e.g. where You act as a sole trader, sole practitioner, or business proprietor and receive Willis Towers Watson's services in connection with Your business needs);
5.2.3 You are an individual to be insured by a client of Willis Towers Watson or a participant/beneficiary of any insurance, pension, or other benefit/ services and Willis Towers Watson is required to collect Your personal information directly from You in order to make the necessary arrangements for/ provide the necessary services to Willis Towers Watson's client;
5.2.4 Willis Towers Watson needs to talk to You or correspond with You in order to provide risk management consultancy or other advisory services to Willis Towers Watson's clients.
5.3 Depending on the circumstances, Willis Towers Watson may also obtain Your personal information from other sources such as:
5.3.1 publicly accessible registers and databases (such as registers of companies/directors, bankruptcy, and court judgments), credit reference agencies, providers of identity verification services, providers of insurance claims validation services, operators of insurance fraud and other business risk screening databases, and other like providers of due diligence services; and
5.3.2 where applicable, underwriters, actuaries, (re)insurers, other brokers, claims handlers, surveyors, loss adjustors/assessors, accident investigators, specialist risks advisors, pension providers, banks and other lenders (including premium finance providers), health professionals, lawyers, accountants, auditors, consultants, and other third party professional advisors and service providers, as well as third parties that have referred You to Willis Towers Watson and other like third parties who interact with Willis Towers Watson in connection with the services Willis Towers Watson provides.
6. Do I have to give my Personal Information to Willis Towers Watson or allow Willis Towers Watson to handle my Personal Information?
You do not have to provide personal information requested by Willis Towers Watson, and You do not have to allow Willis Towers Watson to handle Your personal information. However, such refusal can potentially disadvantage You and additionally, Willis Towers Watson might handle Your personal information regardless of Your wishes where the law allows Willis Towers Watson to do so.
6.1 It is not mandatory for You to provide any personal information Willis Towers Watson asks You to provide or for You to consent to Willis Towers Watson handling Your personal information in any particular way. You can also at any time revoke any consent You give in respect of the processing of Your personal information by Willis Towers Watson if You change Your mind.
6.2 However, if You:
6.2.1 refuse to provide Your personal information which Willis Towers Watson requests;
6.2.2 do not consent to Willis Towers Watson handling Your personal information in accordance with this Privacy Notice; or
6.2.3 revoke any consent regarding the handling of Your personal information by Willis Towers Watson which You have previously given, then such refusal or revocation of previously given consent might prevent Willis Towers Watson from performing its services, and this might in turn, depending on Your circumstances, adversely affect You (e.g. through delays in providing services to You, delays or inability to provide You with management of Your retirement and employment benefits).
6.3 If You consent to the collection and processing of Your personal information by Willis Towers Watson but later revoke Your consent, Willis Towers Watson will endeavour to comply with Your request but there may be circumstances where Willis Towers Watson will not be able to comply with Your request (e.g. if You revoke Your consent to the disclosure of Your personal information to third parties, Willis Towers Watson will not be able to 'undo' a disclosure that has already taken place).
6.4 Additionally, where there is a relevant legal exemption that applies to the way in which Willis Towers Watson collects and processes Your personal information, Willis Towers Watson reserves the right to rely on such legal exemption to collect and process Your personal information regardless of Your wishes but only if and to the extent it is necessary to do so for one or more of the purposes described in Section 4 above.
7. Does Willis Towers Watson use my Personal Information for Marketing?
Willis Towers Watson does not engage in direct marketing that targets consumers in general. However, depending on Your relationship with Willis Towers Watson, You might receive marketing communications from Willis Towers Watson. Where this is the case, Willis Towers Watson will always respect Your marketing preference.
7.1 If You are Yourself a past or current client of Willis Towers Watson (or a prospective client referred to Willis Towers Watson by a third party), or if You are a Willis Towers Watson's business contact at a past, current, or prospective client of Willis Towers Watson, You might from time to time receive marketing communications from Willis Towers Watson, e.g. information regarding a new product or service offered by Willis Towers Watson, or invitation to a seminar or conference hosted by Willis Towers Watson which might be of interest to You (see Section 4.4 above).
7.2 Where Willis Towers Watson sends any such marketing communication to You, Willis Towers Watson will ensure that such marketing communications are sent in compliance with the applicable laws, and in particular, ensure that there is an easy way for You to stop receiving (i.e. "opt-out" from) such marketing communications in the future.
7.3 Willis Towers Watson will also comply with any applicable law that specifically regulates the use of Your personal information for direct marketing purposes.
7.4 Willis Towers Watson will never sell, rent, or otherwise share Your personal information with operators of marketing databases, or any other non-affiliated third party solely for such third party's own marketing purposes without Your prior consent (or the prior consent of the relevant client of Willis, where applicable). For further clarification regarding how Willis Towers Watson shares Your personal information with third parties, please see Section 8 below.
8. Does Willis Towers Watson share my Personal Information with third parties?
Willis Towers Watson shares personal information with third parties mainly to provide its services (e.g. to provide risk management advice, or to provide consultancy and solutions for human capital and benefits, investment and/or risk consulting and technology), but Willis Towers Watson also shares personal information for a variety of other related business purposes.
8.1 Willis Towers Watson will share Your personal information with third parties only if and to the extent it is necessary and appropriate for one or more of the purposes set out in Section 4 above. Specifically, Willis Towers Watson may share Your personal information with the following types of third parties:
8.1.1 where applicable, risks advisors, pension providers, banks and other lenders (including premium finance providers), health professionals, lawyers, accountants, auditors, consultants, and other like third party professional advisors and service providers, as well as third parties that have referred You to Willis Towers Watson (to the extent their involvement is inherent in or necessary in connection with any of the services provided by Willis Towers Watson);
8.1.2 clients of Willis Towers Watson who receive services which is arranged for Your benefit, or otherwise requires Willis Towers Watson to interact, directly or indirectly, with You (to the extent sharing of Your personal information with such clients is necessary and appropriate in the context of the relevant services Willis Towers Watson provides, see Section 4.1.2 and Section 4.1.3 above – such a client may, depending on the circumstances, be Your employer);
8.1.3 affiliates of the Willis Towers Watson Group and non-affiliated third party services providers (e.g. IT services providers, administrative support service providers, etc.) that provide services that directly or indirectly support Willis Towers Watson's business operation and the services provided by Willis Towers Watson;
8.1.4 credit reference agencies, providers of identity verification services, providers of insurance claims validation services, operators of insurance fraud and other business risk screening databases, and other like providers of due diligence services (to the extent necessary to comply with legal or regulatory requirements imposed on Willis Towers Watson or a client of Willis Towers Watson); and
8.1.5 regulators, police, courts/tribunals, and other like public authorities who have jurisdiction over Willis Towers Watson (to the extent necessary to comply with any legal or regulatory requirements imposed on Willis Towers Watson or a client of Willis Towers Watson).
8.2 Please note that where Willis Towers Watson shares Your personal information with regulators, police, courts/tribunals, and other like public authorities, Willis Towers Watson may, depending on the circumstances, be forbidden from advising You (or the relevant client of Willis) of the fact that Your personal information was disclosed to or requested by such third parties.
8.3 In all other cases, Willis Towers Watson will not share Your personal information with other third parties without Your prior consent (or the prior consent of the relevant client of Willis Towers Watson, where applicable) unless Willis Towers Watson has a legal ground on which to do so (e.g. where any applicable law allows Willis Towers Watson to do so, or where Willis is compelled to do so by a court order).
9. Does Willis Towers Watson transfer my Personal Information overseas?
Due to the international nature of Willis Towers Watson's business operation, Your personal information may be shared with third parties that are located in countries that do not have laws that protect personal information in the same way laws of Thailand do.
9.1 Your personal information may be transferred across international borders by Willis Towers Watson to affiliates of the Willis Towers Watson Group and non-affiliated third parties described in Section 8.1 above, who could be located anywhere in the world. As a minimum, such third party recipients based overseas will include other Willis Towers Watson Group companies that are based in the UK, USA, Philippines and India (who provide IT systems support and/or administrative/operational support to Willis Towers Watson).
9.2 Please note that where Willis Towers Watson shares Your personal information with other Willis Towers Watson Group companies or any other third party located overseas, Your personal information will be shared only to the extent it is necessary to allow such overseas recipients to perform their relevant task. Some overseas recipients might receive all of Your personal information (e.g. Willis Towers Watson Group companies that supports Willis Towers Watson's IT systems) whilst some overseas recipients will only receive limited amount of Your personal information (e.g. those who assist Willis Towers Watson in performing ID verification etc. will typically only receive basic personal information such as name and date of birth).
9.4 Whenever Willis Towers Watson transfers Your personal information across international borders, Willis Towers Watson will take all appropriate steps that are within Willis Towers Watson's control so as to ensure that such transfer complies with the applicable legal requirements.
10. Will my Personal Information be kept by Willis Towers Watson?
Willis Towers Watson takes the privacy and confidentiality of Your personal information very seriously. Your personal information will be protected in accordance with the strict information security standards that apply across the Willis Towers Watson Group, including Willis Towers Watson in Thailand.
10.1 Regardless of how Your personal information is kept, the privacy and confidentiality of Your personal information under Willis Towers Watson's control will be protected in accordance with the strict standards set by Willis Towers Watson Group's Information Security Policy which applies to all members of the Willis Towers Watson Group and is enforced by a dedicated team of experienced security experts.
10.2 In the unlikely and unfortunate event Your personal information under Willis Towers Watson's control becomes compromised due to any information security breach (e.g. unauthorised access, loss, or disclosure/alteration, including where this is caused by contractors), Willis Towers Watson will act promptly to identify the cause of such information security breach, and remediate and mitigate the consequences of such information security breach. Where appropriate, Willis Towers Watson will also notify You (and/or the relevant client of Willis Towers Watson, where applicable) in accordance with any applicable law which requires Willis Towers Watson to notify You about such incidents.
11. Does Willis Towers Watson monitor my interaction with Willis Towers Watson in any way?
To ensure the secure handling of Your personal information and to comply with the relevant legal and regulatory requirements, Willis Towers Watson records and monitors access to its facilities and premises, and in some cases, communications between You and Willis Towers Watson's advisors and consultants as well. Please refer to http://www.wtwco.com/th-th/notices/global-website-privacy-notice for more information.
12. Will this Privacy Notice change in the future?
12.1 This Privacy Notice was last updated on 27 April 2020. This Privacy Notice may be amended from time to time to reflect changes in law or changes in Willis Towers Watson's business operation, but where such revision becomes necessary in the future, Willis Towers Watson will notify You to the extent it is practicable for Willis Towers Watson to do so.
12.2 As a minimum, changes to this Privacy Notice will be publicised on Willis Towers Watson's website at http://www.wtwco.com/en-th/notices/privacy-notice-for-clients-thailand (through a link to 'Thailand Privacy Notice' that appears at the bottom frame of the landing page).
13. Who can I contact about my personal information?
If You wish to exercise Your legal right to access/correct Your personal information, or if You have any request, query or complaint regarding the handling of Your personal information by Willis Towers Watson, please contact Willis Towers Watson in the first place.
13.1 Under Thailand's Personal Data Protection Act B.E. 2565 (2019), You have the legal right to:
- to request access to and to receive a copy of the personal information related to you;
- to acquire personal information related to you in such a form that is generally portable;
- to object to the collection, use or disclosure of personal information related to you;
- to request for the deletion, destruction or anonymization of personal information related to you;
- to request for the suspension of the use of personal information related to you.
If You would like to exercise this right, or if You have any request, query or complaint regarding the way in which Your personal information is handled by Willis Towers Watson, please contact:
Data Protection Officer
Towers Watson (Thailand) Limited
9th Metropolis Building, 725 Sukhumvit Rd, Khlong Tan Nuea, Watthana, Bangkok 10110, Thailand.
Telephone: +66 2239 9000
13.2 You can also write to the Willis Towers Watson Global Privacy Office at privacy@wtwco.com.
13.3 Please note that Your right to access and correct/delete Your personal information could be subject to certain legal exemptions, and where any legal exemption applies, Willis Towers Watson might not be able to comply with Your request to access or correct/delete Your personal information.
13.4 Willis Towers Watson will endeavour to respond satisfactorily to Your request to access or correct/delete Your personal information, or any question, concern, or complaint regarding Your personal information You raise with Willis Towers Watson.
