MultiNational Underwriters® (MNU)
respects individual privacy and values the confidence of its
customers, employees, consumers, business partners, and others. Not only does
MultiNational Underwriters® strive to collect, use and disclose personal information in a
manner consistent with the laws of the countries in which it does business, but
it also has a tradition of upholding the highest ethical standards in its
business practices. This Safe Harbor Privacy Policy (the "Policy") sets forth
the privacy principles that MultiNational Underwriters® follows with respect to personal
information transferred from the European Economic Area (EEA) (which includes
the fifteen member states of the European Union (EU) plus Iceland, Liechtenstein
and Norway) to the United States.
SAFE HARBOR
The
United States Department of Commerce and the European Commission have agreed on
a set of data protection principles and frequently asked questions (the "Safe
Harbor Principles") to enable U.S. companies to satisfy the requirement under
European Union law that adequate protection be given to personal information
transferred from the EU to the United States. The EEA also has recognized the
U.S. Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001,
p.47). Consistent with its commitment to protect personal privacy, MultiNational Underwriters®
adheres to the Safe Harbor Principles.
SCOPE
This Safe Harbor
Privacy Policy (the "Policy") applies to all personal information received by
MultiNational Underwriters® in the United States from the European Economic Area, in any format
including electronic, paper or verbal.
DEFINITIONS
For
purposes of this Policy, the following definitions shall apply:
"Agent"
means any third party that collects or uses personal information under the
instructions of, and solely for, MultiNational Underwriters® or to which MultiNational Underwriters® discloses
personal information for use on MultiNational Underwriters®'s behalf.
"MultiNational Underwriters®. (MNU)" means MultiNational Underwriter®, a
Noel Group company, and is known as the Plan Administrator for Lloyd’s
London, the largest and oldest insurance market in the world.
"Personal information" means any
information or set of information that identifies or is used by or on behalf of
MultiNational Underwriters® to identify an individual. Personal information does not include
information that is encoded or anonymized, or publicly available information
that has not been combined with non-public personal information.
"Sensitive personal information" means personal information that reveals
race, ethnic origin, political opinions, religious or philosophical beliefs, or
trade union membership, or that concerns health or sex life. In addition, MultiNational
Underwriters® will treat as sensitive personal information any information received from
a third party where that third party treats and identifies the information as
sensitive.
PRIVACY
PRINCIPLES
The privacy principles in this Policy are based on the Safe
Harbor Principles.
NOTICE: Where MultiNational Underwriters® collects personal
information directly from individuals in the EEA, it will inform them about the
purposes for which it collects and uses personal information about them, the
types of non-agent third parties to which MultiNational Underwriters® discloses that
information, and the choices and means, if any, MultiNational Underwriters® offers individuals
for limiting the use and disclosure of their personal information. Notice will
be provided in clear and conspicuous language when individuals are first asked
to provide personal information to MultiNational Underwriters®, or as soon as practicable
thereafter, and in any event before MultiNational Underwriters® uses or discloses the
information for a purpose other than that for which it was originally collected.
Where MultiNational Underwriters® receives personal information from its subsidiaries,
affiliates or other entities in the EEA, it will use and disclose such
information in accordance with the notices provided by such entities and the
choices made by the individuals to whom such personal information relates.
CHOICE: MultiNational Underwriters® will offer individuals
the opportunity to choose (opt-out) whether their personal information is (a) to
be disclosed to a non-agent third party, or (b) to be used for a purpose other
than the purpose for which it was originally collected or subsequently
authorized by the individual.
For sensitive personal information, MultiNational
Underwriters® will give individuals the opportunity to affirmatively and explicitly
(opt-in) consent to the disclosure of the information to a non-agent third party
or the use of the information for a purpose other than the purpose for which it
was originally collected or subsequently authorized by the individual.
MultiNational Underwriters® will provide individuals with reasonable mechanisms to
exercise their choices.
DATA INTEGRITY: MultiNational
Underwriters® will use personal information only in ways that are compatible with the
purposes for which it was collected or subsequently authorized by the
individual. MultiNational Underwriters® will take reasonable steps to ensure that personal
information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO AGENTS: MultiNational Underwriters® will obtain
assurances from its agents that they will safeguard personal information
consistently with this Policy. Examples of appropriate assurances that may be
provided by agents include: a contract obligating the agent to provide at least
the same level of protection as is required by the relevant Safe Harbor
Principles, being subject to EU Directive 95/46/EC (the EU Data Protection
Directive), Safe Harbor certification by the agent, or being subject to another
European Commission adequacy finding. Where MultiNational Underwriters® has knowledge that an
agent is using or disclosing personal information in a manner contrary to this
Policy, MultiNational Underwriters® will take reasonable steps to prevent or stop the use or
disclosure.
ACCESS AND CORRECTION: Upon
request, MultiNational Underwriters® will grant individuals reasonable access to personal
information that it holds about them. In addition, MultiNational Underwriters® will take
reasonable steps to permit individuals to correct, amend, or delete information
that is demonstrated to be inaccurate or incomplete.
SECURITY: MultiNational Underwriters® will take reasonable
precautions to protect personal information in its possession from loss, misuse
and unauthorized access, disclosure, alteration and
destruction.
ENFORCEMENT: MultiNational Underwriters® will
conduct compliance audits of its relevant privacy practices to verify adherence
to this Policy. Any employee that MultiNational Underwriters® determines is in violation of
this policy will be subject to disciplinary action up to and including
termination of employment.
DISPUTE RESOLUTION:
Any questions or concerns regarding the use or disclosure of personal
information should be directed to the MultiNational Underwriters® Privacy Office at the address
given below. MultiNational Underwriters® will investigate and attempt to resolve complaints and
disputes regarding use and disclosure of personal information in accordance with
the principles contained in this Policy. For complaints that cannot be resolved
between MultiNational Underwriters® and the complainant, MultiNational Underwriters® has agreed to participate
in the dispute resolution procedures of the panel established by the European
data protection authorities to resolve disputes pursuant to the Safe Harbor
Principles.
LIMITATION ON APPLICATION
OF PRINCIPLES
Adherence by MultiNational Underwriters® to these Safe Harbor Principles
may be limited (a) to the extent required to respond to a legal or ethical
obligation; and (b) to the extent expressly permitted by an applicable law, rule
or regulation.
INTERNET
PRIVACY
MultiNational Underwriters® sees the Internet and the use of other technologies
as valuable tools for communicating and interacting with consumers, employees,
business partners, and others. MultiNational Underwriters® recognizes the importance of
maintaining the privacy of information collected online and has created a
specific Internet Privacy Policy (the "IPP") governing the treatment of personal
information collected through web sites that it operates. With respect to
personal information that is transferred from the European Economic Area to the
U.S., the IPP is subordinate to this Policy. However, the IPP also reflects
additional legal requirements and evolving standards with respect to Internet
privacy. MultiNational Underwriters®’s Internet Privacy Policy can be found at http://www.mnui.com/privacy.asp.
CONTACT INFORMATION
Questions or comments regarding this Privacy Policy should be submitted to the Technical Services Department of MultiNational Underwriters® by mail or e-mail as follows:
MultiNational Underwriters®
Attention: Technical Services Department
P.O. Box 863
Indianapolis, IN 46206
insurance@mnui.com
CHANGES TO THIS SAFE
HARBOR PRIVACY POLICY
This Policy may be amended from time to time,
consistent with the requirements of the Safe Harbor Principles. A notice will be
posted on the MultiNational Underwriters® web page (www.mnui.com) for 60 days whenever
this Safe Harbor Privacy Policy is changed in a material
way.
CHANGES TO THIS PRIVACY POLICY
This Policy may be amended from time to time, consistent with the requirements of the regulated Privacy Principles. A notice will be posted on the web page for MultiNational Underwriters® (www.mnui.com) for 60 days whenever this Privacy Policy is changed in a material way.
EFFECTIVE DATE: October 24, 2003
