Privacy Policy
Table of contents:
- 1. Details of this Privacy Policy
- 2. Collection of Personal Information
- 3. Use of Personal Information
- 4. Consent
- 5. Disclosure of Personal Information
- 6. Union Medical Benefit Society Limited (UniMed) policy holders
- 7. Monument Insurance
- 8. Storage and security of your Personal Information
- 9. Retention of your Personal Information
- 10. Accuracy, and your right to Access and Correct
- 11. Mandatory reporting of notifiable privacy breaches
- 12. Changes to our Privacy Policy
- 13. How to make a privacy complaint
1. Details of this Privacy Policy
The Education Benevolent Society Incorporated (trading as HealthCarePlus) is an incorporated society and a registered charity, that offers membership benefits to members of Member Unions to improve the physical, mental, and financial health and wellbeing of union members and their whānau (Membership Benefits).
HealthCarePlus respects your privacy rights and is committed to ensuring that we protect and deal with these rights in accordance with the Privacy Act 2020 (Privacy Act).
In this policy (Privacy Policy), each reference to HealthCarePlus (which includes terms such as ‘we’, ‘our’ and ‘us’) means The Education Benevolent Society Incorporated, trading as HealthCarePlus.
In this Privacy Policy, the following additional terms are defined:
- HealthCarePlus Members means individuals that have registered with us and become HealthCarePlus members;
- Partners and Advisors means third party providers of products and services and advisors who provide advice in relation to those products and services, with whom we engage to provide Membership Benefits to you;
- Member Union means a union that is a member of Education Benevolent Society Incorporated
- Personal Information means information about an identifiable individual;
- Service Providers means other third parties who provide additional services, including (but not limited to) mobile applications, which support the products and services provided by our Partners and Advisors, as part of the Membership Benefits available to Members;
- UniMed means Union Medical Benefit Society Limited;
- UniMed Members means HealthCarePlus Members who hold policies with UniMed; and
- Monument means Monument Insurance, which is part of the Gallagher group of companies and is licensed by the Financial Markets Authority (FMA) to provide advice on life and health insurance products.
This Privacy Policy sets out how HealthCarePlus collects, uses, stores, and discloses your Personal Information. We will not use or share Personal Information that we collect, except as set out in this Privacy Policy (or otherwise as permitted or required by law). This Privacy Policy does not limit or exclude any of your rights under the Privacy Act.
By applying to become a HealthCarePlus Member, receiving Membership Benefits, or by otherwise providing your Personal Information to us, you permit us to collect, use, store, and disclose your Personal Information in accordance with this Privacy Policy.
This Privacy Policy may continue to apply to you and your Personal Information even if you are not actively receiving Membership Benefits, or after your relationship with us has come to an end. It also applies to Personal Information collected during any interaction with us, even if you are not yet registered as a HealthCarePlus Member.
This Policy should be read in conjunction with our website Terms of Use, which can be found here. You may also wish to view our constitution / rules as an incorporated society, which can be found on the Register of Incorporated Societies here. This policy does not apply to personal information collected by us in relation to grants/scholarships, which is covered by a separate policy.
2. Collection of Personal Information
HealthCarePlus collects your Personal Information in the following four ways:A. When you apply to become a HealthCarePlus Member
When you apply to become a HealthCarePlus Member, we will ask you to provide certain forms of Personal Information, which may include (but is not limited to) your name, age, gender, date of birth, contact details, confirmation of your relationship status and number of dependent children, place of work, union membership status, and your Ministry of Education Employee number (if applicable).
B. Information we collect from others
We may collect your Personal Information from:
- others where you have authorised us to do so, such as where you are a member of a Member Union and have authorised that Member Union to provide your information to us;
- our Partners, Advisors, and Service Providers that we have entered into contractual arrangements with and/or work with to provide Membership Benefits to you; and/or
- information that is publicly available.
We may also collect Personal Information from our Partners and/or Advisors which results from an escalated complaint made by a Member that our Partner and/or Advisor considers we ought to know about (in accordance with the terms of our contractual relationship with that Partner / Advisor).
C. Information collected through your contact, interaction and/or engagement with us
When you directly provide us with Personal Information in the course of your contact, interaction and/or engagement with us, we will collect and store this Personal Information. This includes information provided to us through our website, the My HCP Portal, social media accounts that we operate, in person, by email, phone and/or post.
D. Information that we collect automatically
We do not collect personally identifiable information from your use of our website. However, we collect information from your device to understand how you use our website and to improve Membership Benefits.
This website information is collected by:
- Using cookies;
- Collecting website use information; and
- Analytical and tracking tools that we operate.
You may be able to disable cookies by configuring your browser settings. However, if you disable cookies, you may not be able to use all of the features on our website.
3. Use of Personal Information
We will not use or disclose your Personal Information except in accordance with this Privacy Policy and the Privacy Act. The Personal Information we hold about you will only be used for purposes directly related to our activities, and when it is necessary for or directly related to these activities.
We may use your Personal Information for reasons including, but not limited to:
- to carry out our functions as an incorporated society and charity;
- to provide you with Membership Benefits, our website, newsletter, education resources, and referral services;
- to advertise and market Membership Benefits, and the products and services of our Partners, Advisors, and Service Providers, to you;
- to consider any form you submit to us, including any application to become a Member;
- to verify your identity;
- for administrative purposes, such as validating union membership;
- to communicate with you, including responding to requests, inquiries, feedback, or concerns, including those made via social media accounts that we operate;
- to improve our website, Membership Benefits, and to receive your feedback on the products and services of our Partners, Advisors and Service Providers;
- to perform our obligations under any contractual arrangement that we may enter into;
- for statistical and research purposes (on an anonymised basis);
- to protect and/or enforce our legal rights and interests, including defending any claim; and
- for any other purpose authorised by you, or the Privacy Act.
4. Consent
If there are other purposes which are not directly related and other than those discussed above for which we propose to use your Personal Information, we will notify you and request your consent to the proposed use(s).
We will always give you the option to decline to provide your Personal Information, cancel your membership with us and/or opt out of receiving future communications from us. However, if you choose not to provide your Personal Information, this may affect our ability to carry out our general functions and we may be unable to provide Membership Benefits to you.
Unless you ask us not to, we may contact you to tell you about new Membership Benefits and/or changes to this Privacy Policy.
If you are a Member who is not currently receiving products and services from our Partners, Advisors and/or Service Providers, but you have not terminated your membership, we will continue to correspond with you about Membership Benefits unless you ask us not to. If you ask us not to, you may not be informed of, or able to take advantage of, Membership Benefits.
You can opt out of receiving future communications from us by contacting us on the details provided at section 9 of this Privacy Policy, or alternatively through the My HCP Portal.
5. Disclosure of Personal Information
We do not sell, rent, or exchange Personal Information to any third party.Certain limited forms of Personal Information (such as your name, contact details, Member status, and union membership) may be disclosed to third parties for the purposes outlined above at section 3, and for directly related purposes. Some of these parties may include, but are not limited to:
- our Partners, Advisors and Service Providers with whom we conduct ordinary business as set out at sections 6 and 7 below;
- relevant third-party providers of other products and services where those third parties have a business relationship or other association with HealthCarePlus as set out at section 6 below;
- professional advisors, such as insurers and auditors; and
- Government and other regulatory authorities, where required or authorised by law.
We may use and disclose aggregated anonymised information to improve the quality of our website, Membership Benefits, for statistical and market research purposes, and as part of our obligations under any contractual arrangement. This aggregated information is not associated with any individual person.
We may use and disclose this data in aggregate form as a statistical measure, but not in a manner that would identify any individual personally. We may also receive aggregated anonymised information from our Partners, Advisors, and Service Providers which is used for statistical and reporting purposes.
6. Union Medical Benefit Society Limited (UniMed) policy holders
This section of our Privacy Policy applies to UniMed Members (including Members who apply to become a UniMed policy holder). If this does not apply to you, please skip to section 7.
If you are a Member who applies for, or a UniMed Member who holds, a UniMed policy, we may receive certain forms of Personal Information from UniMed.
In addition to the Personal Information that we already hold about you as a Member, the Personal Information that we may receive from UniMed includes (but is not limited to) your status as a policyholder and details on any UniMed policy you hold.
We recommend that you review UniMed’s Privacy Statement, which can be found here.
As a UniMed Member, you will be able to access certain bundled products and services provided in conjunction with our Partners, Advisors, and Service Providers, including but not limited to offerings from Clearhead and Synergy Health. If you are eligible to receive these bundled products and services through our Partners, Advisors, and Service Providers, we may share certain Personal Information (such as your name and contact details) with these Partners, Advisors, and Service Providers for the purposes of them contacting you to activate any account and/or to receive those products and services.
7. Monument Insurance
We are partnered with Monument which provides personalised financial advice to HealthCarePlus Members who have sought financial advice on life and health insurance products.
You can request to receive financial advice and/or to speak to a financial advisor through our Website. When Monument contacts you, you can decline to provide your Personal Information to Monument.
We recommend that you review Monument’s Privacy Policy, which can be found here.
8. Storage and security of your Personal Information
We will take reasonable steps to protect your Personal Information against unauthorised access or disclosure while it is held by us.
Personal Information is stored within HubSpot, a customer software platform that we use. Although your Personal Information will be primarily collected and processed in New Zealand, HubSpot operates on a global basis. This means that your Personal Information may be stored outside of New Zealand. We recommend that you review HubSpot’s Privacy Policy, which can be found here.
We have strong contractual relationships with our Partners, Advisors, and Service Providers, some of which are located outside of New Zealand. If at any time we need to send Personal Information outside of New Zealand, we will ensure that existing contractual relationships are in place, or otherwise enter into a binding contractual relationship with an overseas party confirming that it will protect Personal Information in a way that provides comparable safeguards to those provided under the Privacy Act.
Member details
If you are a Member, you are responsible for your My HCP Portal login details, including your email address and password. You are responsible for all actions taken using your Member login. You should not share your login details with anyone else.
Partners, Advisors, and Service Providers
If you are a Member that enters into a transaction with a Partner, Advisor, or Service Provider for the provision of products and services, we are not responsible for the provision of those products and/or services, or the storage and security of your Personal Information that is collected and stored by that Partner, Advisor, or Service Provider.
9. Retention of your Personal Information
We will retain your Personal Information for as long as it is required for the purpose/s for which it was collected, or otherwise as required by law.
If you are a Member who is not currently receiving products and services from our Partners, Advisors and/or Service Providers, but you have not terminated your membership, you will remain as a Member and we will retain your Personal Information until you decide to cancel your membership with us.
We regularly review the data we hold. In most cases, once Personal Information is no longer required, we will securely destroy it or otherwise delete all identifying details so that only anonymised, aggregated data is retained.
10. Accuracy, and your right to Access and Correct
We will take reasonable steps to ensure that any information we collect or hold is accurate, complete, relevant, up to date, and not misleading. It is your responsibility to let us know if the Personal Information which we hold about you needs to be corrected or updated.You have the right to ask for a copy of any Personal Information we hold about you and ask for it to be corrected if you believe it is incorrect. We may impose a reasonable charge for access and/or correction requests in accordance with the Privacy Act.
If you would like to request a copy of the Personal Information we hold about you, or to have it corrected, please contact us on the below details:
Email: admin@healthcareplus.org.nz
Post: Privacy Officer HealthCare Plus, PO Box 11-059, Manners Street, Wellington, 6142
Alternatively, if you are a Member you can access and update some of the Personal Information we hold about you by logging into the My HCP Portal.
11. Mandatory reporting of notifiable privacy breaches
If your Personal Information is involved in a privacy breach which we reasonably believe is notifiable or must be reported in accordance with the Privacy Act (“Notifiable Privacy Breach”), we will inform the affected individual/s and report the Notifiable Privacy Breach to the New Zealand Office of the Privacy Commissioner.
12. Changes to our Privacy Policy
We may update our Privacy Policy from time to time. If we make a material change to this Privacy Policy, we will inform Members via email of the changes. If you are not a Member, or you have elected to not receive communications from us, we will inform you of the changes by posting the updated Privacy Policy to our website.
The updated Privacy Policy will apply from the date that we email you and/or upload the updated policy to our website.
Your continued membership and/or receipt of Membership Benefits constitutes your acceptance of our updated Privacy Policy, and any Personal Information collected or held by us will be subject to the updated Privacy Policy.
13. How to make a privacy complaint
If you wish to make a complaint in relation to your handling of your Personal Information by us, please contact our Privacy Officer on the details provided at section 10. The complaint will be investigated and responded to as soon as practicable, and in accordance with the time frames set out in the Privacy Act.
You may also contact the Office of the Privacy Commissioner if you are unsatisfied with how we have handled your Personal Information, or your complaint.