1. Policy background
Liberty Mutual Insurance Company, Australia Branch (ABN 61 086 083 605) incorporated in Massachusetts, USA (the liability of members is limited) (Liberty) is part of the Liberty Mutual Group headquartered in the United States. Liberty provides a wide range of commercial and specialist general insurance services and is authorised by the Australian Prudential Regulation Authority to write general insurance business in Australia.
We are committed to protecting the privacy of your personal information. This Privacy Policy explains the main ways Liberty protects your privacy and how Liberty complies with the Australian Privacy Principles, which form part of the Privacy Act 1988 (Cth).
This Privacy Policy applies to any personal information you provide to Liberty directly and any personal information Liberty collects about you from other sources such as the insured, intermediaries or brokers.
Key terms
Personal information is information or opinion that allows others to identify you. It includes your name, date of birth, gender, contact, financial and other information.
Sensitive information is personal information that includes information or an opinion about your racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union membership or associations, sexual orientation or practices, criminal record, health or genetic information, or some aspects of biometric information.
2. Why Liberty collects personal information
Liberty collects your personal information:
- to administer our client relationship with you (as an insured, broker, or intermediary);
- if you are a prospective employee of Liberty; or
- to provide you the products and services Liberty offers. This may include offering policies of insurance, risk management and claims handling. Liberty may use your personal information to check whether you are eligible for a product or service, provide you with a product or service or help manage the product or service. This can occur in the context of issuing insurance quotes and policies of insurance, underwriting policies of insurance and managing claims and complaints.
Liberty also collects your personal information to:
- develop and identify products and services that may interest you, by conducting product and service research and sharing your information with Liberty’s related entities for them to be able to offer you products and services;
- establish and administer alliances and other arrangements with third parties (discussed below) in relation to the promotion, administration and use of Liberty’s respective products and services;
- track your use of our website, products and services to enhance user experience; and
- facilitate events, meetings and activities when you visit any of our office locations.
We may also use your information in the course of performing business activities including reporting and analytics. This may include the use (either in an identified or de-identified form via aggregation) of your personal information for product and service data analysis, data trend analysis and the development of business strategy.
3. What type of personal information Liberty collects
The personal information Liberty collects about you will depend on the nature of our relationship with you and can include:
- your name, date of birth, gender, mailing address, telephone number and e-mail address;
- identification information such as your passport details or driver licence;
- bank and payment details; and
- if relevant, information about your job such as job title, employment history and professional accreditations.
Applying for a specific product or service, or making a claim, may also require us to collect additional specific personal information about you (where relevant to that product or service), including:
- your insurance history; and
- your financial information such as bank account details, billing information or insurance payment arrangements to collect premiums or to pay claims.
Where we provide a product or service to you, we will need to collect, use, disclose and store your personal information relating to that product or service. This will enable us to assist you with any further information or questions you may have about that product or service.
When you make a claim with Liberty, we may also collect personal information of a more sensitive nature and express consent from you will be required (that is, you give it openly and obviously, either verbally or in writing). For example, in relation to the purchase of, or making a claim under casualty insurance, this may include any information about your membership of professional or trade associations, health information, criminal record, financial details and identification documents. More specifically, when you take out a policy or make a claim with Liberty, we will collect the following information to the extent it is relevant to that policy or claim:
- details about your criminal convictions and any related information;
- details about your physical and mental health, including medical reports, x-rays and blood tests; and
- information which may reveal your sensitive personal information, such as when you take out a policy via your trade union body or where you specify certain medical treatments.
If you do not provide us with the personal information we request (or our third parties request on our behalf) we may not be able to provide you with the appropriate type or level of products or services.
4. How Liberty collects personal information
Liberty mostly collects your personal information directly from you in the course of providing our products or services and undertaking business operations (for example, underwriting, claims processing, etc) in relation to you.
In some cases, we may collect your personal information from a third party. For example, an insured's representative (such as a broker) may tell us about other persons wanting the benefit of Liberty’s services or the relevant product. Another example might be the personal information of a director, officer, professional or other staff member being provided to us by an insured. In limited circumstances, we might also collect information about you for a claim made by you from a private investigator or through publicly available sources.
Liberty may also collect your personal information through our own representatives or third parties such as loss adjusters, lawyers, insurers, health care workers, or witnesses to a claim.
Additionally, if you are a third party making a claim against one of our insureds (for example, an individual or entity holding an insurance policy with us), we will collect your personal information directly from you when making a claim or complaint, or when you contact us by email, telephone or any other written and verbal communications. We will also collect your personal information through the party who holds a policy with us, and any third parties involved in the insurance policy or the claim you are making.
5. Disclosing your personal information
Within Australia
Liberty will disclose your personal information to third parties within Australia in the normal business of conducting insurance operations, such as providing you with an insurance quote, processing, servicing, administering your insurance policy and claims, our business administration and when permitted or required by law.
For example, in providing our services to you, we may provide information to:
- other insurers;
- reinsurers (which provide insurance to Liberty itself or to other insurance providers);
- insurance intermediaries (e.g. insurance and reinsurance brokers, agents, appointed representatives and distributors);
- governmental authorities, industry bodies or as required by a statutory or regulatory authority;
- providers of analytics and fraud detection services;
- Liberty’s own advisers or external third party service providers including loss adjusters, lawyers, private investigators, accountants and similar third party service providers that facilitate the handling of a claim.
Liberty limits our use and disclosure of your personal information to the purposes for which you have been notified (or consented to, as the case may be) including in the Privacy Policy. However, there may be limited circumstances in which Liberty uses or discloses your personal information for a secondary purpose if:
- it is reasonably necessary to do so. For example, Liberty may disclose your personal information to an outsourced service provider in carrying out our business activities such as auditing; or
- the secondary purpose is ‘related’ to the primary purpose of collection. This situation may arise if an external third party is engaged for the purposes of acting on our behalf in respect of a claim or complaint filed against us.
The limitations to the use or disclosure of your personal information do not apply to direct marketing (refer to Section 10 below).
Outside of Australia (i.e. transborder disclosure)
For the purposes noted above, Liberty may also transfer your personal information overseas (i.e. outside Australia) if it is reasonably necessary in order to provide you with our products or services or to process claims or otherwise conduct our business.
For example, depending on the product or service you have, we may transfer your personal information to overseas insurers, reinsurers, Liberty Mutual Group entities and other third party providers (or provide them access to it via the Internet). Liberty may also store your information with overseas third party cloud or other types of networked or electronic storage providers. The overseas Liberty Mutual Group entities and third parties referred to above may be located in countries outside of Australia, including:
- Canada;
- China;
- European Union;
- Hong Kong;
- India;
- Malaysia;
- Singapore;
- United Kingdom; and
- United States.
When transferring information overseas we use the following methods to ensure the appropriate protection of your personal information by the recipient:
- recipient due diligence;
- audits; and
- contractual clauses imposing appropriate data privacy obligations.
Liberty holds your personal information within Liberty’s data storage systems or with third party providers of data storage both locally and overseas.
By engaging Liberty for the purposes of taking out a policy, accessing any of Liberty’s products or services, making a claim and/or providing your personal data to us, absent any written indication to the contrary (by you to us), you consent to all reasonably necessary cross-border transfers of and access to your personal information as noted in the Privacy Policy.
6. Automated Decision-Making
Automated decision-making (ADM) refers to making a decision (or omitting to make a decision), or doing a thing (or omitting to do a thing) where it is substantially and directly assisted by a computer program using personal information, which could reasonably be expected to significantly affect your rights or interests.
An example of ADM includes where an insurance claim is automatically rejected based on predefined criteria using your personal information.
Currently, ADM is not solely used to make a decision or do a thing by Liberty.
Liberty may use AI-enabled tools (including those that are internally developed) to assist our staff with internal operations such as document review and information retrieval. These tools help improve efficiency and accuracy and are used under strict privacy controls – they do not make decisions independently. Personal information processed by these tools is handled in accordance with the law.
In all business functions, including Underwriting, Operations, HR, Marketing and Claims operations, decisions are either made manually or involve human oversight in the final decision-making process. As such, these processes are not considered ADM.
We regularly review our use of ADM to ensure transparency and fairness. If you would like more information about ADM, please contact the Privacy Officer (contact details can be found at section 13 of the Privacy Policy).
7. What Liberty expects of you (when providing another’s personal information to us)
When you provide Liberty with personal information about other individuals, we rely on you to undertake certain actions and confirm that you have performed those actions. We expect you to:
- have made them aware that you will be providing their information to Liberty (and they agree to this);
- provide them with a copy of (or details of where they can find) the Privacy Policy;
- explain the purposes for which Liberty will use their personal information and the types of third parties Liberty may disclose the personal information to by reference to the Privacy Policy; and
- explain how they can access or correct their information and how they may make a complaint by reference to the Privacy Policy.
When obtaining another individual’s agreement to share their personal information with Liberty, this can be given to you expressly or impliedly but must be clearly intended to be given. If you have not done any of the above actions, you must tell us before you provide us with the relevant personal information.
If Liberty gives you any personal information about another person (including if you are acting as a representative) you must only use it for the agreed express purposes and in accordance with the Privacy Policy.
8. Security of your personal information
Liberty holds your personal information in both electronic and hard copy formats and takes reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification and disclosure. We take reasonable steps to maintain up to date computer and network security and impose clear privacy restrictions on all third parties who will handle your personal information.
If we believe the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate in the circumstances, we will endeavour to do so promptly.
Liberty will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy. Where your personal information held by us is no longer needed for any purpose then, subject to any legal requirements to hold it, we will take steps to securely destroy your personal information.
9. Accuracy and access to your personal information
You always have a right to access or seek correction to the personal information Liberty holds about you. Liberty will, on your request, provide you with access to your personal information that we hold unless there is a legal exception preventing us from providing you with access to that information. For example, where giving access would have an unreasonable impact on the privacy of another individual, Liberty will not provide you with access to that personal information.
If Liberty does not provide you with access, we will provide you with reasons for the refusal and inform you of any legal exceptions relied upon. Liberty may recover from you its reasonable costs for retrieving and supplying your personal information to you that you have requested access to.
If you would like to access or correct your personal information, please submit your request via this: Australia Privacy Web Form or alternatively, contact Liberty’s Privacy Officer (details at section 13).
Your request to access, correct or update your personal information will be dealt with as soon as reasonably practicable, and we will respond to you no later than 21 days from your original request.
10. Opting out of receiving marketing information
As noted in Section 2 ‘Why Liberty collects your personal information’, we may use your personal information to offer you products or services we believe may be of interest to you and we may provide your personal information to our related companies for that purpose. The absence of any written indication from you to us to the contrary will be taken as your implied consent to the collection, use or disclosure of your personal information for marketing purposes.
However, if at any time you no longer wish to receive marketing information about Liberty or our related companies' branded products and services, please let us know by contacting Liberty’s Privacy Officer. We will act promptly on your request.
11. Making a complaint
With Liberty
If you wish to make a complaint about how we are handling your personal information or have any queries regarding how your personal information is collected, used or disclosed by Liberty, you can contact Liberty’s Privacy Officer.
Liberty will respond to your query or complaint as soon as possible and will try to resolve any complaint within 21 business days. If this is not possible, we will contact you within that time to inform you that further time is required to assess the resolution of your complaint.
With an external dispute resolution scheme
If you are not satisfied with Liberty’s handling of your complaint, you may wish to make a complaint with an external dispute resolution scheme, details of which are provided below:
By phone: 1800 931 678
(9:00am–5:00pm AEST/AEDT weekdays)
Online: https://www.afca.org.au/make-a-complaint
By email: info@afca.org.au
The Privacy Act 1988 (Cth) requires complaints to the OAIC to be in writing. You can complete an online privacy complaint form available on the OAIC website or write a letter that can be sent to:
Mail: GPO Box 5288,
Sydney NSW 2001
Fax: +61 2 6123 5145
12. Liberty’s website
You can browse Liberty’s website (the Site) without having to tell us who you are or revealing any personal information. We may use various technologies to passively collect information from you while you are visiting the Site. We do log non-personal information and general statistical information such as domain name, Internet Protocol (IP) address and browser type. For example, we may use "cookies" (sets of information assigned to you by our web server when you visit the Site) only for maintaining information between pages. They are not used for storing or tracking your personal information as a visitor on the Site. If you wish, you can set your computer to decline cookies. However, if you do, you are fully responsible for altering your browser software to do this.
13. Contacting Liberty Australia
If you wish to gain access to or correct your personal information held by Liberty Australia, opt out of receiving marketing information, make a personal information complaint or you have any queries regarding how your personal information is collected or used, or any other query relating to Liberty Australia and the Privacy Policy, please contact Liberty Australia's Privacy Officer on:
Telephone: 02 8298 5800
Email: privacy.officer.ap@libertymutual.com
Mail: The Privacy Officer, Liberty Mutual Insurance Company, Australia Branch, Level 38, Governor Phillip Tower, 1 Farrer Place, Sydney NSW 2000
Website: www.libertyinternational.com/au
14. Updating this Privacy Policy
Liberty may update this Privacy Policy from time to time, and in any event at least biannually, to reflect our current practices and changes in law, regulation and/or industry standards. The updated Privacy Policy will replace the version on our Site.
This Privacy Policy was last updated on 1 April 2026.