Privacy Policy Statement
Statement of policy
It is our policy and priority to safeguard any information provided by our customers and website users. We pledge to meet fully, and where possible, exceed internationally recognized standards of personal data privacy protection in complying with the data protection principles and all relevant provisions under the Hong Kong Personal Data (Privacy) Ordinance. In doing so, we enforce high standards of compliance on data privacy protection.
When we collect personal data from individuals, we will provide them with a Personal Information Collection Statement ("PICS") on or before the collection in an appropriate format and manner.
Statement of practice
Kinds of Personal Data Held
Four main categories of personal data are held in Sun Life Hong Kong Limited (“Sun Life”).
- Policy/ Pension scheme records, which include records containing information supplied by the applicants of a policy or pension scheme (e.g. contact details, demographic data, financial details, health history, identification numbers, employment details, etc.) or supplied by the authorizing parties;
- Personnel records, which include job applications, staff personal details, agents personal details, job particulars, bank account details, details of salary, commission, bonus, payments, benefits, leave and training records, group medical and life insurance records, pension scheme participation, performance appraisals, license, and disciplinary records, etc.;
- Other records, which include administration and operational files, personal data provided to Sun Life and its related companies for participating in promotional activities, or customer surveys, data matching records, research records, investigation records by any law, regulation or court order, etc.;
- Records collected from our websites, which include the visitor’s IP address, information about the number of new and repeat visitors, records of how long the visitors visit, the geographic location of the visitors and similar details, records of how many users visit advertisements promoting our products and services that appear on other company websites. All such information is collected in an aggregate and anonymous format. You are not required to provide personal information to use our websites, unless a feature requires it.
Main Purposes of keeping Personal Data
Personal data held in:
- Policy/ Pension scheme records are kept for the purposes of: (i) processing and evaluating the application of a policy or pension scheme (ii) administering and providing services in relation to the product the policy owner or the scheme participant holds; (iii) processing and investigating claims; (iv) conducting customer surveys; (v) researching and designing financial, insurance or pensions products for customer use; (vi) selecting and participating in reward, loyalty or privileges program and related service; (vii) contacting the policy owner or scheme participant for the above purposes; (viii) purposes which are directly related to the above purposes; (ix) complying with applicable laws, regulation or court order; and (x) contacting the policy owner or scheme participant with marketing information regarding Sun Life and third party pensions, financial and insurance products.
- Personnel records of employees and agents are kept for recruitment and human resource management purposes, including: (a) processing and evaluating job application; appointing employees or agents; (b) facilitating and administering employment or agent contract; (c)administering registration, renewal, cancellation of registration in relation to insurance and MPF intermediary license with regulatory bodies such as the Hong Kong Federation of Insurers (“HKFI”) or its successor and the Mandatory Provident Fund Authority (“MPFA”) including without limitation reporting of training record and responding to their enquiries; (d)administering all aspects of employment or agency relationship with Sun Life, including without limitation, accounting, auditing, regulatory and tax requirements; (e)enrolling in and administering employee or agent in pension and retirement fund scheme; (f) providing with group medical and life insurance and other benefits as provided by Sun Life; (g) performing Sun Life’s obligations and enforcing its rights under the agreement, including without limitation any post-termination debt recovery; (h) performing appraisals and disciplinary actions; (i) purposes which are directly related to the above purposes.
- Other records are kept for various purposes which vary according to the nature of the record. We would specify the purposes as and when we collect such personal data.
- Records collected from our websites are kept for improving our websites’ performance and functionality, create a better experience for our visitors and measure the response to web marketing campaigns.
In addition to the Main Purposes stated above, we intend to use your personal data in direct marketing of Sun Life products and services. However, we will only do so where we have your written consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
- your name, contact details, other products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by us from time to time may be used in direct marketing of our products and services; and
- the products and/or services offered by entities of the Sun Life Group may be marketed where permitted by law.
However, we will not provide your personal data to third parties for their use in direct marketing without your express consent to the same.
Should you subsequently not wish us to continue using your personal data for direct marketing as described in this paragraph, you may exercise your opt-out right by notifying us. Please write to us per the contacts details as stated below in the data access and correction section.
Please read our online privacy statement for details of the data security and data protection measures of information we receive and collect when you visit our websites.
Outsourcing arrangements
Sun Life may engage service providers to process personal data on our behalf. All Sun Life service providers are bound by contractual duty to keep confidential any data they come into contact with against unauthorized access, use and retention.
Protection measures
Sun Life takes appropriate steps to protect the personal data we hold against loss, unauthorized access, use, modification or disclosure. Only our authorized staff will be permitted to access personal data collected.
Retention
Sun Life maintains and executes 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 Sun Life in accordance with our record management policy.
Disclosure of personal data
For policy or pension scheme record, Sun Life may disclose your personal data (a) to third parties who provide services in Hong Kong or elsewhere which assist Sun Life to carry out the above purposes, including but not limited to claims investigators, medical advisors, medical service providers, emergency assistance service providers, reinsurers and professional advisors (provided that such contractors are required to keep all such personal data confidential and may only use the personal data to provide those services); (b) to your bank for payment purposes; (c) to your insurance broker (if any); (d) to Sun Life’s insurance agents and MPF intermediaries; (e) to Sun Life’s related companies including pensions services provider, insurance companies and financial services companies; (f) to the Hong Kong Federation of Insurers (or any similar association of insurance companies) or its successor and its members; (g) to any person to whom Sun Life or its related companies (inside or outside Hong Kong) is under an obligation to make disclosure under the requirements of any law, regulation or court order binding on or applying to or to which Sun Life or its related companies (inside or outside Hong Kong) is subject to, or under and for the purposes of any guidelines issued by regulatory or other authorities with which Sun Life or its related companies (inside or outside Hong Kong)is expected to comply; and (h) as otherwise required or permitted by law. Sun Life may also use and disclose your personal data in other ways with your consent or as otherwise required or permitted by law.
For personnel records of employees, Sun Life may disclose your personal data to (a) any agent, contractor, or third party service provider who provides administrative, telecommunications, computer or other services to Sun Life in connection of its business; (b) any companies within the Sun Life Financial group of companies for internal purposes and direct marketing of products and services provided by those companies; (c) persons seeking employee references (in circumstances where the express consent of the employee has been obtained); (d) any person to whom Sun Life is compelled to make disclosure under the requirements of any law binding on or applying to or to which Sun Life or its related companies (inside or outside Hong Kong) is subject to, or under and for the purposes of any guidelines issued by regulatory or other authorities with which Sun Life or its related companies (inside or outside Hong Kong) is expected to comply; and (e) third parties involved in a possible reorganization or sale of all or part of Sun Life or its business or assets. If you as an employee have queries on this matter, please contact the Chief Human Resources Officer, Sun Life Hong Kong Limited, 16/F, Cheung Kei Center Tower A, No. 18 Hung Luen Road, Hunghom, Kowloon, Hong Kong.
For personnel records of agents, Sun Life may disclose your personal data to (a) third parties who provide services which assist Sun Life to carry out the permitted purposes, including without limitation legal advisors, insurance providers, private investigators and debt collection companies; (b) the HKFI or (its successor) and its members, MPFA and other regulators; (c) the pension and retirement fund scheme provider; (d) related companies of Sun Life; and government authorities and agencies as required or permitted by law.
For other records, Sun Life would specify the disclosure parties as and when we collect such personal data.
Data access and correction
For policy records – You should make your data access request or data correction request to Sun Life by sending a written request to The Manager, Customer Service Centre, Sun Life Hong Kong Limited, G/F, Cheung Kei Center Tower B, 18 Hung Luen Road, Hunghom, Kowloon, Hong Kong. When handling a data access or correction request, Sun Life will check the identity of the requester to ensure that he/she is the person legally entitled to make the data access or correction request. A reasonable fee may be charged for the processing of any such requests.
For pension scheme records – You should make your data access request or data correction request to BestServe, Sun Life’s pension scheme’s administrator, by sending a written request to The Manager, Pension Administration, BestServe Financial Limited, 10/F, One Harbourfront, 18 Tak Fung Street, Hunghom, Kowloon, Hong Kong. When handling a data access or correction request, BestServe will check the identity of the requester to ensure that he/she is the person legally entitled to make the data access or correction request. A reasonable fee may be charged for the processing of any such requests.
For personnel records of employees – You should make your data access request or data correction request to Sun Life by sending a written request to Chief Human Resources Officer, Sun Life Hong Kong Limited, 16/F, Cheung Kei Center Tower A, No. 18 Hung Luen Road, Hunghom, Kowloon, Hong Kong. When handling a data access or correction request, Sun Life will check the identity of the requester to ensure that he/she is the person legally entitled to make the data access or correction request. A reasonable fee may be charged for the processing of any such requests. Please note that even when your request is granted, we will only allow you to access your own personal data and not other information or that of other employees.
For personnel records of agents – You should make your data access request or data correction request to Sun Life by sending a written request to Sales Personnel Department, Sun Life Hong Kong Limited, 2/F, Cheung Kei Center Tower A, No. 18 Hung Luen Road, Hunghom, Kowloon, Hong Kong. When handling a data access or correction request, Sun Life will check the identity of the requester to ensure that he/she is the person legally entitled to make the data access or correction request. A reasonable fee may be charged for the processing of any such requests.
For other records – You should make your data access request or data correction request to our Data Privacy Officer by sending a written request to The Data Privacy Officer, 16/F, Cheung Kei Center Tower A, No. 18 Hung Luen Road, Hunghom, Kowloon, Hong Kong. When handling a data access or correction request, Sun Life will check the identity of the requester to ensure that he/she is the person legally entitled to make the data access or correction request. A reasonable fee may be charged for the processing of any such requests.
Enquiries
Should you have any queries regarding our personal data privacy policy and practice, please address them to our Data Privacy Officer by writing to The Data Privacy Officer, 16/F, Cheung Kei Center Tower A, No. 18 Hung Luen Road, Hunghom, Kowloon, Hong Kong.
Last updated: 7 October, 2020
