Data Privacy Statement

Leadenhall group of companies are committed to protecting your privacy and is in compliance with the General Data Protection Regulation (EU 2016/279).

This Data Privacy Statement covers the Personal Data practices of Leadenhall Asia Limited hereafter called “LHA”. It explains how LHA processes and protects the Personal Data information we collect, how we meet our obligations regarding data protection and the rights of our customers in respect of their Personal Data in compliance with the Personal Data (Privacy) Ordinance (Cap.486 “PDPO”) in Hong Kong.

The objective of PDPO is to protect the privacy rights of a person in relation to personal data (Data Subject).

LHA and its associated companies is fully committed to compliance with the requirements of the PDPO.

We are required to maintain certain personal data about individuals for the purposes of satisfying our operational and legal obligations. We recognise the importance of correct and lawful treatment of personal data as it helps to maintain confidence in our organisation and to ensure efficient and successful outcomes when using this data.

Please read this document carefully, as it contains important information relating to the information you have given/ will give us.

The types of personal data that we may process includes information about current, past and prospective employees, clients and customers, suppliers and other organisations with whom we have dealings.

Personal data may consist of data kept on paper, computer or other electronic media; all of which is protected under PDPO.

1. Principles

   We endorse and adhere to the Six Data Protection Principles which are summarised as follows:

   DPP1 - Data Collection Principle

   Personal data must be collected in a lawful and fair way, for a purpose directly related to a function /activity of the data user.

   Data subjects must be notified of the purpose and the classes of persons to whom the data may be transferred.

   Data collected should be necessary but not excessive.

   DPP2- Accuracy & Retention Principle

   Practicable steps shall be taken to ensure personal data is accurate and not kept longer than is necessary to fulfil the purpose for which it is used.

   DPP3 - Data Use Principle

   Personal data must be used for the purpose for which the data is collected or for a directly related purpose, unless voluntary and explicit consent with a new purpose is obtained from the data subject.

   DPP3 - Data Use Principle

   Personal data must be used for the purpose for which the data is collected or for a directly related purpose, unless voluntary and explicit consent with a new purpose is obtained from the data subject.

   DPP4 - Data Security Principle

   A data user needs to take practicable steps to safeguard personal data from unauthorised or accidental access, processing , erasure, loss or use.

   DPP5 - Openness Principle

   A data user must take practicable steps to make personal data policies and practices known to the public regarding the types of personal data it holds and how the data is used.

   DPP6 - Data Access & Correction Principle

   A data subject must be given access to his/her personal data and allowed to make corrections if it is inaccurate.

   • the information which relates to a living person and can be used to identify that person and
   • it exists in a form in which access or processing is practicable

   Data means any representation of information (including an expression of opinion) in any document, and includes a personal identifier.

   Employees and agents of LHA who obtain, handle, process, transport and store personal data for us must adhere to this principles / ordinance at all times.

2. How we use data

   Insurance Underwriting

   We examine the potential risk in relation to your (and/or a third party’s) prospective policy so that we can:

   • consider whether to accept the relevant risk;
   • make decisions about the provision and administration of insurance and related services for you (and members of your household);
   • validate your (or any person or property likely to be involved in the policy or claim) claims history (at any time, including upon application for insurance, in the event of an accident or a claim, or at a time of renewal) including any pre-existing medical conditions you may have.

   Management Information

   We analyse insurance and other markets for the purpose of:

   • portfolio assessment;
   • risk assessment;
   • performance reporting;
   • management reporting.

3. Handling of personal data

   LHA will through appropriate management and the use of strict criteria and controls:

   • publicly disclose its policies and practices in relation to personal data, including the types of personal data held by the data user and the main purpose for which personal data is used.
   • except with the express and voluntary consent of the data subject, only process personal data for the original purposes for which it was collected or a directly related purpose.
   • personal data collection will be for a lawful purpose and directly related to a function or activity of the data user and not excessive in relation to that purpose.
   • ensure that personal data retained is accurate, not retained longer than necessary, where corrected notified to data users who were previously supplied the inaccurate data, is stopped being not used if reasonable grounds exist that the data is inaccurate.
   • where requested, provide data subjects with confirmation as to whether or not their personal data is held and, if required, provide a copy of the personal data.
   • only transfer personal data outside of Hong Kong to countries that have laws substantially similar to, or which serve the same purpose as the PDPO

4. Access to personal data

   All individuals are entitled to:

   • ask whether their personal data is held
   • request access to their personal data
   • request correction of any inaccuracies in their personal data

   Any person who wishes to exercise this right should make a request in writing to:

   Chief Executive Officer
   Leadenhall Asia Limited
   48th Floor,
   Lee Garden One,
   33 Hysan Avenue,
   Causeway Bay,
   Hong Kong.
   Email: contact@leadenhall-asia.com

   We aim to comply with requests for access to personal information as quickly as possible but will ensure that it is provided within 30 days of receipt of a written request unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request.