Statement of Policy
William Russell Ltd. is an Appointed Insurance Agency of Sompo Insurance (Hong Kong) Co., Ltd. Both William Russell Ltd and Sompo Insurance (Hong Kong) Co., Ltd (We/Us) are committed to protecting the personal data of our customers. We are bound by the Data Protection Principles set out in the Hong Kong Personal Data (Privacy) Ordinance (PDPO).
When we collect personal data from individuals, we will provide them with a PICS on or before the collection.
We may amend this PPS at any time and for any reason. The updated version will be available on our website at https://william-russell.com.hk/privacy. You should check the PPS regularly for changes.
In this PPS, personal data means any data:
- relating directly or indirectly to a living individual;
- from which it is practicable for the identity of the individual to be directly or indirectly ascertained;
- and in a form in which access to or processing of the data is practicable.
Statement of Practice
1. When We Would Collect Personal Data
We collect personal data in a number of ways. The most common circumstances in which we collect personal data are listed below:
a) when you enquire about products and / or services we offer
b) when you apply for an insurance product
c) when you make a claim
2. Kinds of Personal Data Collected and Held
The types of personal data we collect from you will depend on the circumstances in which that information is collected. We may collect details:
- when you enquire about product we offer, we will collect and hold your name and contact details so we can respond to your query;
- when you apply for an insurance product, we will collect and hold your name, HKID number, date of birth, contact details and other personal data relevant to the insurance product you are applying for;
- when you make a claim, we will collect and hold your name, HKID number, date of birth, contact details and other personal data relevant to the claim you are making.
3. Main Purposes of Collecting and Holding Personal Data
The purposes for which your personal data will be collected, used and held will depend on the circumstances in which that personal data is collected.
We will inform you of the purposes for which we intend to collect, use and hold your personal data in the PICS on or before collection of your personal data.
Generally, we may use your personal data for the following purposes: (A) processing and evaluating your application or request for and any alterations, variations, cancellation, renewals and re-instatements of any insurance products and / or services offered by or through us; (B) administering your insurance policy and providing services in relation to your insurance policy; (C) any purposes in connection with any claims made by or against or otherwise involving you in respect of any products and / or services provided by us, including processing and / or investigating any claims; (D) invoicing and collecting premiums and / or outstanding amounts from you; (E) exercising any right of subrogation, if applicable; (F) conducting statistical analysis; (G) contacting you for any of the above purposes; (H) other purposes directly related to any of the above purposes; and (I) meeting the requirements to make disclosure (i) under any law binding on us; or (ii) under any applicable rules, regulations, codes or guidelines or to assist in law enforcement purposes, investigation by police or other government or regulatory authorities; or (iii) for complying with any requirements, policies or measures for using data and information within Sompo Japan Nipponkoa Holdings, Inc. (the Group) and/or William Russell Limited and Group companies (including our UK associated company of the same name [William Russell Limited]) in accordance with any Group-wide programmes from time to time for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities / misconducts; (i) other purposes directly related to the above purposes.
4. Protection Measures
We take all practicable steps to protect the personal data we hold against loss, unauthorised access, use, modification, disclosure, processing or erasure.
We provide training to our employees to ensure that our employees handle personal data properly.
We maintain and execute retention policies of records containing personal data to ensure personal data is not kept longer than is necessary for the fulfilment of the purpose for which the data is or is to be used. Different retention periods apply to the various kinds of personal data collected and held by us in accordance with policies in our internal guidelines and manuals.
6. Disclosure and Transfer of Personal Data
The third parties to whom your personal data will be disclosed and transferred will depend on the purposes for which that personal data is collected and / or used.
We will inform you of the third parties to whom your personal data will be disclosed and transferred in the PICS on or before collection of your personal data.
We may disclose and transfer your personal data to the following transferees in Hong Kong or overseas for the above-mentioned purposes: (a) third party agents, contractors and advisors who provide administrative, communications, computer, payment, security or other services which assist us to carry out the above purposes (including medical service providers, emergency assistance service providers, mailing houses, IT service providers and data processors); (b) in the event of a claim, loss adjusters, claims investigators and medical advisors; (c) in the event of default, debt collectors and recovery agents; (d) insurance reference bureaus or credit reference bureaus; (e) reinsurers and reinsurance brokers; (f) your insurance broker, if applicable; (g) our legal and professional advisors; (h) our associated companies; (i) the policyholder, when none of the insured person(s) of that policy is the policyholder, for the purpose of policy application, administration, renewal and / or claims administration (if applicable); (j) the Hong Kong Federation of Insurers (or any similar association of insurance companies); (k) the Insurance Claims Complaints Bureau and similar industry bodies; and (l) government agencies and authorities as required or permitted by law. We may also use and disclose your personal data otherwise with your consent.
In exceptional circumstances, we may be required or permitted by law to disclose personal data, for example to law enforcement authorities or to prevent a serious threat to public safety.
7. External Links
This Website may contain links to third party websites. We have no control over the content of such third party websites or the way that the operators of these websites deal with your personal data. You should review the privacy policies applicable to these third party websites to understand the ways in which these third parties may deal with your personal information.
8. Collection of Anonymous Technical Information
When you access this Website, anonymous technical information may be collected about your activities on the Website (e.g. your IP address, the date and time that you accessed the Website, information relating to your browser and operating system, the pages visited etc.).
10. Data Access and Correction
You may contact us to seek access to or seek to correct personal data which we hold about you. There are certain exemptions under the PDPO which may apply to personal data access and correction requests. We may require that you the person requesting access or correction provide suitable identification and we may charge a reasonable administration fee for complying with a data access request.
Requests for access to and / or correction of personal data held by us should be addressed to the Data Protection Officer at William Russell Limited, Suite 1304, 13/F Office Plus, No. 303 Hennessy Road, Wanchai, Hong Kong.
12. Amendments to this PPS
We reserve the right, at any time and without notice, to amend this PPS and all personal information shall be governed by the most recent version of this PPS. Any such amendment will be effective immediately upon posting.
The Global Health plans are offered by William Russell Limited and Sompo Insurance (Hong Kong) Co., Ltd., an insurance company authorised to carry on general business in Hong Kong.
William Russell Limited is an Appointed Insurance Agency of Sompo Insurance (Hong Kong) Co., Ltd., Hong Kong Federation of Insurers Agent Registration Number 14975092.