Southern Cross Travel Insurance’s Privacy Policy (NZ)
About Southern Cross Travel Insurance’s Privacy Policy
We value the trust you place in us to handle your personal information (including sensitive information) the right way when we provide a product or service to you and we will always be honest and transparent about how we manage your personal information.
Southern Cross Travel Insurance is a travel insurance company operating in Australia and New Zealand.
In this Privacy Policy, when we refer to ‘Southern Cross Travel Insurance’, ‘we’, ‘our’ or ‘us’ we mean Southern Cross Benefits Limited ABN 99 133 401 939, AFS Licence 331058 trading as Southern Cross Travel Insurance.
In this Privacy Policy, when we refer to ‘you’ or ‘your’ we mean our customers and the person whose name was used in an application to purchase one of our products, who uses our products and services and who gives personal information and whom the personal information relates to.
For more information about Southern Cross Travel Insurance, please see here: www.scti.co.nz.
This Privacy Policy sets out how we manage your personal information. It describes the kinds of personal information we collect and hold, how we collect it, and why we need it including for what purpose we collect, hold, use, disclose, destroy or de-identify it.
Southern Cross Travel Insurance and its operations in New Zealand are bound by the Privacy Act 2020 (New Zealand) including the Information Privacy Principles (IPPs) and its Codes of Practice.
We are dedicated to having an up-to-date Privacy Policy. This Privacy Policy will be reviewed at least annually to ensure our privacy obligations are met.
The contents of this Privacy Policy may change from time to time, without notice.
What is personal information & health information and why do we collect it?
We want you to know what personal information is so that you know what we collect, hold, use and disclose.
‘Personal information’ is information about an identifiable individual and includes information relating to a death maintained by the Registrar-General. It is information that can be used to identify or reasonably identify you.
Depending on the type of product or service we provide to you, we also may collect, hold, use and disclose health information. Health information means information about the health of an individual including their medical history, any disabilities, any health or disability support services they are, or have been, provided and information collected before or in the course of, and incidental to, the provision of any health service or disability support service to that individual.
Southern Cross Travel Insurance will only collect, use or disclose personal information for a lawful purpose connected with our functions or activities and the information is necessary for us to carry out that purpose. This includes allowing us to provide you with travel insurance and our travel related products and services, making a decision on your claim and assistance while you are travelling. Your health information may also be required for these purposes particularly if your claim involves a medical event and we need to provide medical assistance to you under your policy.
What if you do not provide your personal information or wish remain anonymous or have a pseudonym?
You have the option of not identifying yourself or using a pseudonym where it is lawful or practicable for SCTI to allow it. This may be when you inquire with us about a product or service, use our online services or request a quote.
If you choose to deal with us anonymously or use a pseudonym or choose not to provide us with information we have requested, we may be unable to provide you with or properly manage and administer our travel insurance product or service or provide medical or non-medical assistance whilst travelling if all or any part of the requested information is not provided.
What personal information do we collect and hold?
The kinds of personal information we collect and hold will depend on the type of product or service we provide to you.
We may collect and hold personal information (including health information) from you and this includes:
- your name, email address, date of birth, contact details and other personal details to set up a policy for you or this information of any other person you wish to insure with us;
- your travel plans;
- information to administer a product or service to you including assessing and determining a claim;
- information about your medical history and the medical history of any other person you wish to insure with us, including about pre-existing medical conditions;
- information about claims you make or wish to make under your policy;
- information about the medical history of any person that results in a claim under your policy;
- information about the type of medical assistance you require or will be provided with;
- your bank account details so that we may pay your claim; and
- details contained within identity documents provided to us including unique identifiers such as driver license numbers, passport numbers, IRD numbers of National Health Index (NHI) numbers.
How do we collect your personal information?
Southern Cross Travel Insurance will collect personal information from your directly and at various times.
We will only collect personal and health information from you in a way that is lawful and in a way that is fair and does not intrude to an unreasonable extent upon your personal affairs. We take extra care when collecting personal and health information from children and young persons. We only collect personal information from children below the age of 18 directly from their parent or legal guardian.
We set out some examples below, so that you are aware of the fact that your personal information is being collected:
- when you open and start to complete, or complete, an application form or other type of form for travel insurance;
- when you contact us in person, by phone, mail, email or online or we contact your directly;
- when you make a claim or request assistance from us; and
- when you visit our website, Facebook page, mobile application and any other pages that we operate.
When you visit our website or other digital platforms, we may also collect and use data including some of your travel data, your IP address, record your date and time of visit, the pages you visited and the device and browser you may be using.
In some circumstances, when it is not reasonably practicable to collect the personal information from you directly, we will collect personal information from third parties. This may include:
- from the primary policy holder;
- from your representative or any other person when authorised by you (for example, a joint policy holder, your legal guardian or a person with power of attorney);
- from an agency or organisation on whose behalf we are providing you with travel insurance (for example, your travel consultant, advisers, agents, brokers, employer and other representatives);
- Southern Cross Travel Insurance branded businesses and trusted business partners;
- medical practitioners, health service providers and medical authorities;
- other insurers and any insurance data collection services for the purposes of policy or claim verification and/or fraud prevention;
- third party fraud protection services and their subscribers for the purpose of fraud prevention, investigation or detection; and
- law enforcement agencies, telecommunications and digital partners and agencies, social media and any other service providers to us.
If you are the primary policy holder, we ask that you make any other people insured under your policy aware that you may disclose their personal information to us, and of this Privacy Policy.
How do we collect your health information?
Southern Cross Travel Insurance will only collect health information when it is reasonably necessary for one or more of our functions or activities and you have given your consent. We will collect health information from you directly.
In some circumstances, when it is not reasonably practicable to collect the personal information from you directly, we will collect personal information from third parties for example, medical practitioners, health service providers and medical authorities.
Other times you may provide health information to your representative, agent or other third party to then provide to us for example, when completing a policy application or during the claims process. You must provide the third party with your consent to disclose this information to us.
If we do not have your consent, we will not collect your health information subject to the exceptions under privacy law including when the collection is necessary and required by or under an New Zealand law or a court/tribunal or the collection is necessary to provide you with emergency medical assistance.
When do we notify you of the collection of your personal information?
When we collect your personal information (including your health information) from you or a third party, we will take reasonable steps to make you aware:
- of the fact that we have collected that information;
- the purpose for which the information has been collected.
- our identity and contact details as the agency collecting and holding the information;
- when personal information has been collected from a third party; and
- if the collection is required or authorised by law.
How do we use and disclose your personal information?
Southern Cross Travel Insurance will only collect, use or disclose personal information (including health information) for the purpose for which it was originally collected. This includes allowing us to provide you with travel insurance and our travel related products and services.
Your personal information may be collected, used and disclosed for the purpose of allowing us to:
- to identify you and other policy holders;
- to consider your eligibility for cover under the policy;
- to consider specific terms or conditions applying to your policy (including any pre-existing medical conditions);
- to process your application;
- to manage and administer a policy or a product and service;
- to assist you while travelling;
- to provide medical and non-medical assistance;
- to assess, investigate, process and make a determination on claims made and/or paid;
- to pay your claim;
- to manage, authenticate and update customer data;
- to design and develop new products and to improve and make changes to existing products and services;
- to improve and personalise the customer experience including our website and marketing;
- for system development and training of our staff;
- to prevent, detect and investigate any fraud including in situations where we reasonably suspect any fraud;
- to investigate and resolve complaints;
- to comply with legislative and regulatory requirements and provisions;
- to contact you from time to time, including within a reasonable time of your policy expiring or you ceasing to be covered by the policy, about products and services offered by us and our business partners;
- to conduct market analysis and research in relation to the above purposes;
- to assist with the investigations and/or recovery of any claims made and/or paid (including historical claims);
- as necessary to establish, exercise or defend a legal claim; or
- as required or authorised by law or an enforcement body.
We may use or disclose your personal information for a different purpose if, for example:
- where the different purpose is directly related to the purpose with which the information was obtained;
- where you consent to the use or disclosure of the information;
- where the source of the information is publicly available and in the circumstances, it would not be unfair or unreasonable to use or disclose the information;
- where the use or disclosure of the information is necessary and required by law; or
- the use and disclosure of the information is necessary to prevent or lessen a serious threat to public health or safety or the life or health of you or another individual.
Do we use your personal information for marketing?
From time to time, Southern Cross Travel Insurance may use personal information it holds for direct marketing regarding our products or services or request feedback for marketing or promotional purposes.
We will only use your personal information for marketing if you have consented to that use. If you or an authorised representative have provided your email address or mobile phone number to us, we will take this as your implied consent to receiving this communication until you unsubscribe or opt out.
You can choose to not provide your consent to receive marketing information by unsubscribing or opting out from receiving direct marking communication by using the unsubscribe function in our email or text marketing communications or alternatively, you can contact us and let us know you no longer wish to receive this communication.
We do not use or disclose health information for the purposes of direct marketing.
Who do we disclose your personal information to?
Unless otherwise permitted by law, we will only disclose to, or share your personal information for the purposes described above with the following:
- the policyholder or other individuals covered under your policy;
- your representative or any other person when authorised by you (for example, your legal guardian or a person with power of attorney);
- medical practitioners and/or health service providers;
- emergency assistance service providers;
- third parties contracted by us to perform our services, provided any use of your personal information by that third party is limited to the relevant service;
- to third parties associated with your policy (for example, your travel consultant, advisers, agents, brokers, employer and other representatives);
- our reinsurers and their agents;
- our actuaries;
- Southern Cross Travel Insurance branded businesses and trusted business partners and service providers (for example, mailing houses, actuaries, research and insight agencies, investigators, translators, data processing and matching services, data analysis services, data monetization services, information broking services, business consulting services, marketing and research services and information technology services);
- our professional advisors including lawyers accountants, tax advisors and auditors;
- regulatory or government bodies for the purpose of resolving customer complaints or investigations;
- other insurers on their specific request or for the purpose of fraud prevention, investigation or detection;
- third party fraud prevention services and their subscribers for the purposes of fraud prevention, investigation or detection; or
- any other person in accordance with the law.
This is not an exhaustive list and if you have any questions on who we disclose your information to, please contact us.
Do we disclose your personal information (including health information) overseas?
In certain circumstances, we may disclose your personal information (or your health information if reasonably necessary) to business partners and service providers who are located outside of New Zealand.
The circumstances where your personal information may be disclosed overseas include:
- to manage and authenticate your personal information;
- to improve our products and services;
- to administer your policy;
- to process and assess your application;
- to process and assess your claim;
- to provide you with medical and non-medical assistance while travelling; or
- if disclosure is required or authorised by law.
The business partners and service providers we may disclose your personal information to are generally located in New Zealand and Australia and the geographical areas in which you have or are travelling to.
Before we disclose your personal information held by us overseas, we will take reasonable steps to ensure the overseas third parties we disclose your personal information to are required to protect the information in a way that provides comparable safeguards to those provided under New Zealand privacy law including via contractual agreements or where the overseas third party is subject to laws of another country with comparable safeguards.
However, in some circumstances, the overseas third party may not be required to protect your personal information in the same way we do, that is, in a way that provides comparable safeguards to those under New Zealand privacy laws.
When you purchase a product or service with us, you consent to us sending your personal information to overseas third parties if required and as described in this Privacy Policy.
How do we secure and store your personal information?
Southern Cross Travel Insurance takes reasonable steps to protect the personal information (including health information) it holds from loss, unauthorised access, use, modification or disclosure and other misuse. This includes security safeguards in place to manage artificial intelligence systems.
There are different ways we store your personal information. These include in our computer systems or databases, in paper and electronic form and by our service providers located overseas including data centres, software providers, other technology-related service providers, lawyers and accountants.
If we need to disclose your personal information to a third party, we will do everything reasonably within our power to prevent unauthorised use or disclosure of your personal information.
Our technical security safeguards include:
- security measures for system access;
- encrypting data;
- antivirus and anti-malware software;
- strong passwords; and
- firewalls and intrusion detection systems.
Our organisational security safeguards include:
- targeted privacy training;
- internal policies, standards and procedures on privacy security risk, artificial intelligence and notifiable data breaches;
- access to personal information is limited to authorised employees;
- confidentiality requirements for all employees and third parties.
When we no longer need your personal or health information we hold for any purpose for which the information may lawfully be used, we will take reasonable steps to destroy the information or ensure the information is de-identified in a manner that preserves your privacy.
Whilst we are committed to protecting your personal information and having security measures in place, there is always a risk in data transmission and security especially when you or we transmit data over the internet.
How can you access to and correct your personal information (including health information)?
We are committed to taking reasonable steps to ensure the personal information (including your health information) we collect, use and disclose is accurate, up-to-date, complete and not misleading.
If your personal information or health information has changed or you believe the information we hold is not accurate, up-to-date, complete or misleading, please notify us using the contact details set out in the ‘How to contact us?’ section below.
You can request access to your personal information or correction of your personal information by contacting us. This includes your health information..
If a charge is applicable to providing you with access or correcting your personal or health information, we will disclose these charges to you before providing you with the requested information.
You can request information from us on whether we hold any of your personal and health information and we will write to you with a notice to confirm whether we do or do not hold the personal and health information.
We will respond to your request for access or correction as soon as reasonably practicable and no later than 20 working days after the day we received your request. We will notify you if we require an extension to this timeframe to respond to your request. If your request is urgent, we will consider your request and the reason stated for its urgency when determining the priority to be given to responding to it.
If your request for access is accepted, we will write to you with a notice setting out the way the information is to be made available, the charge applicable (if any) to providing you with access and the mechanism available to make a complaint about the charge payable (if any).
If your request for access is refused or we impose conditions, we will write to you with a notice setting out the reasons for the refusal and the mechanism available to make a complaint if you wish.
When requesting the correction of your information, you are entitled to provide us with a statement of the correction sought and request us to attach the Policy to the information.
If your request for correction is accepted, we will write to you with a notice setting out that we have corrected or will correct your personal information.
If your request for correction is refused, we will write to you with a notice setting out the reasons for the refusal, your entitlement to provide a statement of the correction sought and to request that it be attached to the information and the mechanism available to make a complaint if you wish.
If we are not willing to correct the information as requested, and you have provided us with a statement of the correction, we will take reasonable steps to ensure the statement is attached to the information in a manner that ensures that it will always be read with the information and write to you with a notice on our decision to attach the statement.
How can you let us know of your privacy concerns or lodge a complaint?
If you have any concerns about the way Southern Cross Travel Insurance handles your personal information, please contact us.
If you believe we have not met our privacy obligations and wish to make a complaint about an alleged breach of the Privacy Act 2020 (NZ), please direct your complaint to our Privacy Officer. Their contact details are set out in the ‘How to contact us’ section below. We have a complaints process including an internal and external dispute resolution process.
If you are not satisfied with the resolution of your complaint or how we have dealt with your complaint, you may wish to refer the complaint to the Privacy Commissioner. Their details are as follows:
Office of the Privacy Commissioner
Post: PO Box 10 094, Wellington 6143
Telephone: 0800 803 909
Email: enquiries@privacy.org.nz
Website: www.privacy.org.nz
If you have any queries about how we handle your personal information (inclusive sensitive and health information) or this Privacy Policy, please contact us. Our details are as follows:
Address: Level 1, Te Kupenga, 155 Fanshawe Street Auckland, 1010
Telephone: 0800 800 571 (+64 9 979 6593 from overseas) (Monday – Friday 8:30am – 5:00pm)
Email: info@scti.co.nz
Date of last updated version: June 2025
Date of next review: June 2026