Privacy Policy

Privacy and Spam Policy

Our Commitment

Carollo Horton and Associates Pty Ltd is committed to providing you with the highest levels of client service. We recognise that your privacy is very important to you. We bound by the Australian Privacy Principles under the Privacy Act 1988.  Our aim is to both support and ensure that we comply with these principles. Further information on privacy in Australia may be obtained by visiting the website of the Office of the Federal Privacy Commissioner at http://www.privacy.gov.au

 

Carollo Horton and Associates Pty Ltd believes that this Privacy Policy discloses how the personal information you provide to us and our representatives, is collected, used, held, disclosed and disseminated.

Carollo Horton and Associates Pty Ltd is required to meet particular legislative and regulatory requirements. In order to provide a comprehensive insurance broking service to you, we are required to collect certain personal information from you.

  • Providing you with the relevant product or service
  • Managing and administering the product or service
  • Protecting against fraud

 

Your Personal Information

As an insurance broking organisation we are subject to certain legislative and regulatory requirements which necessitate us to obtain personal information about you, including Privacy Amendment (Enhancing Privacy Protection) Act 2012and Corporations Act 2001. Detailed below is some of the information you are required to provide:

  • your name, date of birth, current addresses, telephone/mobile/fax numbers, e-mail address;
  • information regarding your dependents and family commitments
  • Your occupation, employment history, details family commitments, social security eligibility, health information or other information the organisation considers necessary.
  • your financial needs and objectives;
  • your assets and liabilities (current and future), income, expenses; and
  • Your insurance details.

 

How We Collect Personal Information

Carollo Horton and Associates Pty Ltd collects personal information in a number of ways, including:

  • directly from you, when you attend a face-to face interview;
  • directly from you, when you provide information through a data collection form;
  • directly from you, when you provide information by phone;
  • directly from you via an email or the internet; and
  • Directly from insurance companies and other product issuers once authorisation has been provided by you. You have a right to refuse us authorisation to collect information from a third party.

 

How We Use Your Personal Information

The information in this document details how we comply with the Privacy Act including:

  • What is the purpose?
  • Who is my information disclosed to?
  • What law requires collection?
  • What are the consequences?

 

Primarily, your personal information is used in order to provide comprehensive and/or limited insurance services to you. We may also use the information that is related to the primary purpose and it is reasonable for you to expect the information to be disclosed.

It is a legislative requirement that we keep all personal information and records for a period of 7 years. Should you cease to be a client of ours, we will maintain your personal information on or off site in a secure manner for 7 years. After this, the information will be destroyed in a secured manner.

 

Ensure Your Personal Information Is Correct

Carollo Horton and Associates Pty Ltd takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. To ensure we can maintain this level of accuracy and completeness, we recommend that you:

  • inform us of any errors in your personal information as soon as possible; and
  • Update us with any changes to your personal information as soon as possible.

 

Access to Your Personal Information

You have a right to access your personal information, subject to certain exceptions allowed by law. We ask that you provide your request for access in writing (for security reasons) and we will provide you with access to that personal information. Access to the requested personal information may include:

  • providing you with copies;
  • providing you with the opportunity for inspection; or
  • Providing you with a summary.

 

If charges are applicable in providing access to you, we will disclose these charges to you prior to providing you with the information.

 

Some exceptions exist where we will not provide you with access to your personal information if:

  • providing access would pose a serious threat to the life or health of a person;
  • providing access would have an unreasonable impact on the privacy of others;
  • the request for access is frivolous or vexatious;
  • the information is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
  • providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
  • providing access would be unlawful;
  • denying access is required or authorised by or under law;
  • Providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.

 

Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal.

 

Using Government Identifiers

Although in certain circumstances we are required to collect government identifiers, such as your tax file number, Medicare number or pension card number, we do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.

 

Dealing with us anonymously

You can deal with us anonymously where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.

 

Your sensitive information

Without your consent we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record.

This is subject to some exceptions including:

  • the collection is required by law; and
  • When the information is necessary for the establishment, exercise or defence of a legal claim.

Personal Information will be treated as confidential information and sensitive information will be treated highly confidential.

 

Complaints Resolutions

Please contact our Privacy Officer if you wish to complain about any breach or potential breach of your privacy rights. Your complaint will be responded to within 7 days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Privacy Commissioner.

 

Spam Act

Spam is a generic term used to describe electronic ‘junk mail’- unwanted messages sent to a person’s email account or mobile phone. In Australia, spam is defined as ‘unsolicited commercial electronic messages’.

‘Electronic messaging’ covers emails, instant messaging, SMS and other mobile phone messaging, but not cover normal voice-to-voice communication by telephone.

From time to time, we may provide you with direct marketing material. This will include articles and newsletters that may be of interest to you. If, at any time, you do not wish to receive this information any further, you may contact us with this request. We will endeavour to meet your request within 2 weeks. We maintain a Register for those individuals not wanting direct marketing material.

If you provide inaccurate or incomplete information we may not be able to provide you with the products or services you are seeking.

 

When We Disclose Your Personal Information*

In line with modern business practices common to many financial institutions and to meet your specific needs we may disclose your personal information to the organisations described below.

The Corporations Act 2001 has provided the Australian Securities and Investments Commission with the authority to inspect certain personal information that is kept on our files about you.

For the purposes set out above, we may disclose your personal information to organisations outside Carollo Horton and Associates Pty Ltd. The organisations to which we disclose information may include:

  • insurance providers and other product providers in order to manage or administer your product or service;
  • compliance consultants to ensure that our representatives are meeting our compliance standards;
  • contractors or temporary staff to handle workloads during peak periods;
  • mailing houses;
  • insurance reference bureaus and loss adjusters
  • your professional advisers, including your solicitor or accountant as authorised by you;
  • information technology service providers to maintain, review and develop our business systems, procedures and infrastructure including testing or upgrading our computer systems;
  • Government and regulatory authorities and other organisations, as required or authorised by law, for example, to government or regulatory bodies for the purposes related to public health or safety, the prevention or detection of unlawful activities or to protect public revenue.
  • another authorised representative of Carollo Horton and Associates Pty Ltd if necessary;
  • a potential purchaser/organisation involved in the proposed sale of our business for the purpose of due diligence, corporate re-organisation and transfer or all or part of the assets of our business.
  • Product planning and development advisers
  • Where you have given your consent including your legal advisers
  • a new owner of our business that will require the transfer of your personal information

In addition, our employees and the outsourcing companies/contractors are obliged to respect the confidentiality of any personal information held by Carollo Horton and Associates Pty Ltd.

Carollo Horton and Associates Pty Ltd takes its obligations to protect your information seriously, this includes when we operate throughout Australia and overseas, as part of our operations some uses and disclosures of your information may occur outside your State or Territory and/or outside of Australia. In some circumstances we may need to obtain your consent before this occurs.

In the event of that we propose to sell the business, we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them.

 

How We Store and Secure Your Personal Information

We keep your personal information in your client file. These files are accessible to authorised personnel only and are appropriately secured out of hours.

Your personal information may also be held on our computer database which is not cloud based. All computer-based information is protected through the use of access passwords.  Data is backed up regularly and stored securely off site. Other measures taken are:

  • Confidentiality requirements for our employees
  • Security measures for systems access
  • Providing a discreet environment for confidential discussions

Personal information will be treated as confidential information and sensitive information will be treated highly confidential.

Carollo Horton and Associates Pty Ltd complies with the provisions of the Spam Act when sending commercial electronic messages.

Equally importantly, Carollo Horton and Associates Pty Ltd makes sure that our practices are in accordance with the Australian Privacy Principles in all activities where they deal with personal information. Personal information includes our clients contact details.

 

Internal Procedure for dealing with complaints

The three key steps Carollo Horton and Associates Pty Ltd follows:

  • Consent – Only commercial electronic messages are sent with the addressee’s consent – either express or inferred consent.
  • Identify – Electronic messages will include clear and accurate information about the person and the Carollo Horton and Associates Pty Ltd that is responsible for sending the commercial electronic message.
  • Unsubscribe – We ensure that a functional unsubscribe facility is included in all our commercial electronic messages and deal with unsubscribe requests promptly.

 

Consented to such communications

Commercial messages will only be sent to you when you have given consent. This may be express consent – a direct indication that it is okay to send the message, or messages of that nature or inferred consent based on our business or other relationship with you and your conduct.

 

Comply with the law regarding viral messages

Carollo Horton and Associates Pty Ltd ensures that Commercial Communications that include a Forwarding Facility contain a clear recommendation that the Recipient should only forward the Commercial Communication to persons with whom they have a relationship, where that relationship means that person could be said to have consented to receiving Commercial Communications.

 

Comply with the age sensitive content of commercial communication

Where the content of a Commercial Communications seeks to promote or inspire interaction with a product, service or event that is age sensitive, Carollo Horton and Associates Pty Ltd takes reasonable steps to ensure that such content is sent to Recipients who are legally entitled to use or participate in the product service or event

We encourage you to check our website regularly for any updates to our Privacy Policy.

Contact Details

Privacy Officer: Susan Carollo
Address: PO Box 3308, Wheelers Hill VIC 3150
Telephone : 1300 227 655
E-mail: contact@carollohorton.com.au
Web site: www.carollohorton.com.au

 

Dated: May 2019

FSG

The financial services referred to in this financial services guide (FSG) are offered by:

 

Carollo Horton and Associates Pty Ltd ABN 85 235 271 160

54 Henderson Rd, Rowville, VIC 3178

03 9562 0032 | 1300 227 655

contact@pharmacyinsurance.com.au

 

This FSG sets out the services that we can offer you. It is designed to assist you in deciding whether to use any of those services and contains important information about:

  • the services we offer you.
  • how we and others are paid.
  • any potential conflict of interest we may have.
  • our internal and external dispute resolution procedures and how you can access them.
  • arrangements that are in place to compensate clients for losses.

 

Further information when personal advice is given

We will provide you with further information whenever we provide you with advice which takes into account your objectives, financial situation and needs. This information may include the advice that we have given you, the basis of the advice and other information on our remuneration and any relevant associations or interests. This information may be contained in a statement of advice (SOA).

When you ask us to recommend an insurance policy for you, we will usually only consider the policies offered by the insurers or insurance providers that we deal with regularly. In giving you advice about the costs and terms of recommended policies, we have not compared those policies to all policies available.

 

Product disclosure statement

If we offer to arrange the issue of an insurance policy to you, we will also provide you with, or pass on to you, a product disclosure statement (PDS), unless you already have an up to date PDS from the insurer. The PDS will contain information about the particular policy, which will enable you to make an informed decision about purchasing that product.

 

From when does this FSG apply?

This FSG applies from 11 June, 2019 and remains valid unless a further FSG is issued to replace it. We may give you a supplementary FSG. It will not replace this FSG but will cover services not covered by this FSG.

 

How can I instruct you?

You can contact us to give us instructions by post, phone or email on the contact number or details mentioned on page 1 of this FSG.

 

Who is responsible for the financial services provided?

Carollo Horton & Associates Pty Ltd is responsible for the financial services that will be provided to you or through you to your family members, including the distribution of this FSG. Carollo Horton & Associates Pty Ltd holds a current Australian Financial Services Licensee no:503725 . The contact details for Carollo Horton & Associates Pty Ltd are on the front of this FSG.

 

What kinds of financial services are you authorised to provide to me and what kinds of financial product/s do those services relate to?

Carollo Horton and Associates Pty Ltd is authorised to advise and deal in general insurance products to wholesale and/or retail clients under its Australian Financial Service Licence. All our brokers are authorised to provide advice and deal in all general insurance products. We will do this as your broker unless we tell you otherwise.

 

Will I receive tailored advice?

Maybe not in all cases. For example, if an insurer offers a renewal of a policy, we will automatically renew your insurance policy with the insurer, unless you have asked us to give you advice about your insurance needs for the next
insurance term.  This does not apply to some project specific, short term or non-renewable policies. We will tell you when this is case.
However, we may need information about your personal objectives, details of your current financial situation and any relevant information, so that we can arrange insurance policies for you, issue insurance policies to you or to give you advice about your insurance needs. We will ask you for the details that
we need to know.
In some cases, we will not ask for any of this information. If we do not ask, or if you do not give us all of the information we ask for, any advice you receive may not be appropriate to your needs, objectives and financial situation.
You should read the warnings contained in any SOA, or any other warnings that I/we give you, carefully before making any decision about an insurance policy.
Where we provide you with advice about your insurance arrangements, that advice is current at the time that we give it. We will review your insurance arrangements when you inform us about changes in your circumstances.

However, we may need information about your personal objectives, details of your current financial situation and any relevant information, so that we can arrange insurance policies for you, issue insurance policies to you or to give you advice about your insurance needs. We will ask you for the details that we need to know.

In some cases, we will not ask for any of this information. If we do not ask, or if you do not give us all of the information we ask for, any advice you receive may not be appropriate to your needs, objectives and financial situation.

You should read the warnings contained in any SOA, or any other warnings that I/we give you, carefully before making any decision about an insurance policy.

Where we provide you with advice about your insurance arrangements, that advice is current at the time that we give it. We will review your insurance arrangements when you inform us about changes in your circumstances.

 

Contractual Liability and your insurance cover

Many commercial or business contracts contain clauses dealing with your liability (including indemnities or hold harmless clauses). Such clauses may entitle your insurers to reduce cover, or in some cases, refuse to indemnify you at all. You should seek legal advice before signing and accepting contracts. You should inform us of any clauses of this nature before you enter into them.

 

What information do you maintain in my file and can I examine my file?

We maintain a record of your personal profile, including details of insurance policies that we arrange or issue for you. We may also maintain records of any recommendations or advice given to you.
Carollo Horton & Associates Pty Ltd will retain this FSG and any other FSG given to you as well as any SOA or PDS that we give or pass on to you for the period required by law.

 

Do you have a Privacy Policy?

We are committed to implementing and promoting a privacy policy, which will ensure the privacy and security of your personal information. A copy of our privacy policy is available on request. A copy is also available on our website, www.carollohorton.com.au/Privacy-Policy. If you wish to look at your file, please ask us. We will arrange for you to do so.

 

How will I pay for the services provided?

For each insurance product, the insurer will charge a premium that includes any relevant taxes, charges and levies. We often receive a payment based on a percentage of this premium (excluding relevant taxes, charges and levies) called commission, which is paid to us by the insurers. However, in some cases we will also charge you a fee. These will all be shown on the invoice that we send you. You can choose to pay by any of the payment methods set out in the invoice. You are required to pay us within the time set out on the invoice. If you pay by credit card, we will charge you a non-refundable credit card fee as shown on the Tax Invoice. This reimburses us for the bank interest and extra bank charges, and internal time generated for credit card use.

If there is a refund or reduction of your premium as a result of a cancellation or alteration to a policy, or based on a term of your policy (such as a premium adjustment provision), we will retain any fee we have charged you. We will also retain commission depending on our arrangements with the insurer, or charge you a cancellation fee equal to the reduction in our commission.

When you pay us your premium, it will be banked into our trust account. We retain the commission from the premium you pay us and remit the balance to the insurer in accordance with our arrangements with the insurer. We will earn interest on the premium while it is in our trust account or we may invest the premium and earn a return. We will retain any interest or return on investment earned on the premium you pay us and remit the balance to the insurer in accordance with Carollo Horton & Associates Pty Ltd’s arrangements with the insurer.

 

How are any commissions, fees or other benefits calculated for providing the financial services?

Our commission will be calculated based on the following formula:

X = Y% x P

In this formula:

X = Our commission

Y% = the percentage commission paid to us by the insurer. Our commission varies between 0 and 30%.

P = the amount you pay for any insurance policy (less any government fees or charges included in that amount).

Any fees that we charge you will be disclosed on the Tax Invoice. We do not often pay any commissions, fees or benefits to others who refer you to us or refer us to an insurer. If we do, we will pay commissions to those people out of its commission or fees (not in addition to those amounts), in the range of 0 to 50% of its commission or fees.

Our employees that will assist you with your insurance needs will be paid a market salary, performance bonus or share of the commission and fees from 0 – 50%.

If we give you personal advice, we will inform you of any fees, commission or other payments we, my/our associates or anyone referring you to us (or me/us to any insurer) will receive in relation to the policies that are the subject of the advice.

See below for information on our association and commission.

 

Do you have any relationships or associations with the insurers who issue the insurance policies or any other material relationships?

Carollo Horton & Associates Pty Ltd is a shareholder of Steadfast Group Limited (Steadfast. Steadfast has exclusive arrangements with some insurers and premium funders (Partners) under which Steadfast will receive between 0 – 1.5% commission for each product arranged by us with those Partners.
These payments are used to operate Steadfast. Depending on the operating costs of Steadfast (including the costs of member services provided by Steadfast to us and other Steadfast shareholders) and the amount of total business we place with the participating Partners in any financial year, we may receive a proportion of that commission at the end of each financial year.
As a Steadfast shareholder we have access to member services including model operating and compliance tools, procedures, manuals and training, legal, technical, banking and recruitment advice and assistance, group insurance arrangements, product comparison and placement support, claims support and group purchasing arrangements. These member services are either
funded by Steadfast, subsidised by Steadfast or available exclusively to Steadfast shareholders for a fee.

You can obtain a copy of Steadfast’s FSG at www.steadfast.com.au

If we arrange premium funding for you we may be paid a commission by the premium funder. We may also charge you a fee (or both). The commission that we are paid by the premium funder is usually calculated as a percentage of your insurance premium (including government fees or changes). If you instruct us to arrange or issue a product, this is when we become entitled to the commission.  Our commission rates for premium funding are in the range of
NIL to 5% of funded premium. When we arrange premium funding for you, you can ask us what commission rates we are paid for that funding arrangement compared to the other arrangements that were available to you. The amount of our commission and any fee that we charge will be set out in the
premium funding contract.

 

What should I do if I have a complaint?

1. Contact Carollo Horton and Associates Pty Ltd at the address noted at the beginning of this FSG and tell us about your complaint. We will do our best to resolve it quickly.

2. Carollo Horton & Associates Pty Ltd is a member of the Australian Financial Complaints Authority (AFCA). If your complaint cannot be resolved to your satisfaction by us, you have the right to refer the matter to the AFCA. AFCA can be contacted at:

Mailing address – Australian Financial Complaints Authority, GPO Box 3, Melbourne, VIC 3001

Ph – 1800 931 678

Fax – 03 9613 6399

Email – info@afca.org.au

Website – www.afca.org.au

 

What arrangements are in place to compensate clients for losses?

Carollo Horton and Associates Pty Ltd confirms that it has arrangements in place to ensure it continues to maintain Professional Indemnity insurance in accordance with s.912B of the Corporations Act 2001 (as amended). In particular our Professional Indemnity insurance, subject to its terms and conditions, provides indemnity up to the Sum Insured for Carollo Horton and Associates Pty Ltd and our authorised representatives / representatives / employees in respect of our authorisations and obligations under our Australian Financial Services Licence. This insurance will continue to provide such coverage for any authorised representative / representative / employee who has ceased work with Carollo Horton and Associates Pty Ltd for work done whilst engaged with us.

Any questions?

If you have any further questions about the financial services Carollo Horton and Associates Pty Ltd, please contact us. Please retain this document for your reference and any future dealings with Carollo Horton and Associates Pty Ltd.

 

Version 3.0 – Dated: 11 June 2019