Liberty Mutual Privacy Notice – California (Workers’ Compensation)

Effective January 1, 2023

Liberty Mutual Group, its affiliates and subsidiaries (collectively “Liberty Mutual” or “we”, “us” and “our”) provide workers’ compensation insurance to companies. In this notice, we explain how we gather, use, share, and protect your data. This notice applies to you if you are a California resident and (i) are buying insurance for your company, (ii) your company has workers’ compensation insurance with us, or (iii) you have a workers’ compensation claim. If this notice does not apply to you, please go to libertymutual.com/privacy to review our privacy notices for other states.

 

  • What Personal Data Do We Collect?

    The types of personal data we gather and share depends on your relationship to us. For example, we may gather different data if you are a claimant reporting an injury than if you want a quote for insurance. The data we gather can include your Social Security Number, income, and medical information related to your injury. It may also include data gathered as we provide insurance services, when you apply for such services, or from other contacts with you. It may also include:

    • Identifiers, including a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security Number, driver’s license number, or other similar identifiers;
    • Personal data, such as your name, signature, Social Security Number, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, financial data, precise geolocation, medical data, or health insurance data;
    • Protected classification characteristics described in California Civil Code §1798.80(e), including age, race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status;
    • Commercial data, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories and tendencies;
    • Internet or other similar network activity, including browsing history, search history, data about a consumer’s interaction with a website, application, or advertisement;
    • Professional or employment related data, including current or past job history;
    • Inferences drawn from other personal data, such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;
    • Risk data, including data about your driving and/or accident history; this may include data from consumer reporting agencies, such as your motor vehicle records and loss history data, health data, or criminal convictions;
    • Claims data, including data about your previous and current claims, which may include data regarding your health, criminal convictions, third party reports, or other personal data; and
    • Sensitive data, as defined under the California Privacy Rights Act.
       

    For data about the types of personal data we have gathered in the past twelve months, please see the California Privacy Policy (Consumers).

     

  • How Do You Gather My Data?

    We gather your personal data directly from you.

    For example, you provide us with data when you:

    We also gather your personal data from other people. For example:

    • ask about, buy insurance or file a claim
    • your insurance agent or broker
    • pay your policy
    • your employer, association or business
      (if you are insured
       through them)
    • visit our websites, call us, or visit our office
    • our affiliates or other insurance companies about your transactions with them

     

    • consumer reporting agencies, Motor Vehicle Departments, and inspection services, to gather your credit history, driving record, claims history, or value and condition of your property

     

    • other public directories and sources

     

    • third parties, including other insurers, brokers and insurance support organizations who you have communicated with about your policy or claim, anti-fraud databases, sanctions lists, court judgments and other databases, government agencies, open electoral register, or in the event of a claim, third parties including other parties to the claim witnesses, experts, loss adjustors and claim handlers

     

    • other third parties who take out a policy with us and are required to provide your data such as when you are named as a beneficiary or where a family member has taken out a policy that requires your personal data


    Entities that share data with us may keep it and disclose it to others as permitted by law. For data about how we have gathered personal data in the past twelve months, please see the California Privacy Policy (Consumers).

  • How Do We Use Your Personal Data?

    Liberty Mutual uses your data to provide you our products and services and as otherwise provided in this Notice. Liberty Mutual may use your data and the data of former customers for our business and other compatible purposes.  Our business purposes include, for example:

    Business Purpose

    Data Categories

    Do we share or sell your data as defined by CPRA

    Market, sell and provide insurance. This includes for example:

    • calculating your premium;
    • determining your eligibility for a quote;
    • confirming your identity and servicing your policy;
    • Identifiers
    • Personal Information
    • Protected Classification Characteristics
    • Commercial Information
    • Internet or other similar network activity
    • Professional or employment related information
    • Inferences drawn from other personal information
    • Risk data
    • Claims data
    • No.

    Manage your claim. This includes, for example:

    • managing your claim, if any;
    • conducting claims investigations;
    • conducting medical examinations;
    • conducting inspections, appraisals;
    • providing roadside assistance;
    • providing rental car replacement, or repairs;
    • Identifiers
    • Personal Information
    • Protected Classification Characteristics
    • Commercial Information
    • Internet or other similar network activity
    • Professional or employment related information
    • Inferences drawn from other personal information
    • Risk data
    • Claims data
    • No.

    Day to Day Business and Insurance Operations.

    This includes, for example:

    • creating, maintaining, customizing and securing accounts;
    • supporting day-to-day business and insurance related functions;
    • doing internal research for technology and development;
    • marketing and creating products and services; 
    • conducting audits related to a current contract with a consumer and other transactions;
    • as described at or before the point of gathering personal data or with your authorization
    • Identifiers
    • Personal Information
    • Protected Classification Characteristics
    • Commercial Information
    • Internet or other similar network activity
    • Professional or employment related information
    • Inferences drawn from other personal information
    • Risk data
    • Claims data
    • No.

    Security and Fraud Detection. This includes for example:

    • detecting security issues;
    • protecting against fraud or illegal activity, and to comply with regulatory and law enforcement authorities;
    • managing risk and securing our systems, assets, infrastructure and premises;
    • help to ensure the safety and security of Liberty staff, assets and resources, which may include physical and virtual access controls and access rights management;
    • supervisory controls and other monitoring and reviews, as permitted by law; and
    • emergency and business continuity management.
    • Identifiers
    • Personal Information
    • Protected Classification Characteristics
    • Commercial Information
    • Internet or other similar network activity
    • Professional or employment related information
    • Inferences drawn from other personal information
    • Risk data
    • Claims data

     

     

    • No.

    Regulatory and Legal Requirements. This includes for example:

    • controls and access rights management;
    • to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Liberty’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Liberty is among the assets transferred;
    • exercising and defending our legal rights and positions;
    • to meet Liberty contract obligations;
    • to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
    • as otherwise permitted by law
    • Identifiers
    • Personal Information
    • Protected Classification Characteristics
    • Commercial Information
    • Internet or other similar network activity
    • Professional or employment related information
    • Inferences drawn from other personal information
    • Risk data
    • Claims data
    • No.

    Improve Your Customer Experience and Our Products. This includes for example:

    • improve your customer experience, our products and service;
    • to provide, support, personalize and develop our website, products and services;
    • create and offer new products and services;
    • Identifiers
    • Personal Information
    • Commercial Information
    • Internet or other similar network activity
    • Professional or employment related information
    • Inferences drawn from other personal information
    • Risk data
    • Claims data
    • No.

    Analytics to identify, understand and manage our risks and products. This includes for example:

    • conducting analytics to better identify, understand and manage risk and our products;
    • Identifiers
    • Personal Information
    • Protected Classification Characteristics
    • Commercial Information
    • Internet or other similar network activity
    • Professional or employment related Information
    • Inferences drawn from other personal information
    • Risk data
    • Claims data
    • No.

    Customer service and technical support. This includes for example:

    • answer questions and provide notifications; provide customer and technical support;
    • Identifiers
    • Personal Information
    • Commercial Information
    • Internet or other similar network activity
    • Professional or employment related information
    • Inferences drawn from other personal information
    • Risk data 
    • Claims data
    • No.

    Cross Context Behavioral Advertising

    • Internet or other similar network activity
    • Identifiers (IP address, device ID)
    • We share this information with service providers such as search engines and social media platforms.
  • Do We Disclose Your Personal Data?

    Liberty Mutual does not sell your personal data, as that term is defined under the California Consumer Privacy Act as amended. If you visit Libertymutual.com or other Liberty Mutual websites, we may share (as defined under the CCPA) some personal information (e.g., IP address, device ID) for cross-context behavioral advertising. The California privacy law defines sharing as “communicating orally, in writing, or by electronic or other means, a consumer’s personal information . . . to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.”  For example, this occurs when you visit a Liberty Mutual website. Cookies or pixels are deployed that then allow us to show you targeted advertisements when you visit other websites or social media platforms. You have the right to opt-out of this type of sharing and you may learn more about those rights at lmi.co/caprivacychoices.

    This type of sharing is different from disclosing personal information to other entities to perform a service related to providing insurance or processing your claim.  How we disclose data to these types of entities is set forth below. Liberty Mutual may disclose personal data with affiliated and non-affiliated parties, including:

    • Liberty Mutual affiliates;
    • Service Providers (such as auto repair facilities, towing companies, property inspectors and independent adjusters);
    • Insurance support organizations;
    • Brokers and agents;
    • Public entities (e.g., regulatory, quasi-regulatory, tax or other authorities, law enforcement agencies, courts, arbitrational bodies, and fraud prevention agencies);
    • Consumer reporting agencies;
    • Advisors including law firms, accountants, auditors and tax advisors;
    • Insurers, re-insurers, policy holders, and claimants;
    • Group policyholders (for reporting claims data or an audit);
    • A person, organization, affiliate or Service Providers conducting actuarial or research studies; and
    • As permitted by law.
       

    We may also disclose data with other companies that provide marketing services on our behalf or as part of a joint marketing agreement for products offered by Liberty Mutual. We will not disclose your personal data with others for their own marketing purposes.

    We may also disclose data about our transactions (such as payment history) and experiences (such as claims made) with you to our affiliates.

    Liberty Mutual may disclose the following categories of personal data as needed for Business purposes:

    Identifiers Personal data
    Protected Classification Characteristics Commercial data
    Internet or other similar network activity Professional, employment and education data
    Inferences drawn from personal data Risk data
    Claims data   


    For data about how we have disclosed personal data in the past twelve months, please see the California Privacy Policy (Consumers).

  • How Do We Keep your Personal Data Safe?

    We maintain physical, electronic, and administrative safeguards created to protect your data from unauthorized access. Our employees and agents are authorized to access your data only for legitimate business purposes.

     

  • How Long Does Liberty Mutual Retain Each Category of Personal Data?

    We retain your information in accordance with our legal obligations, our records retention policies, or as otherwise permitted by law. For example, we may have a legal obligation to retain information relating to your policies or claims with us. We will delete your data once the legal obligation expires or after the period of time specified in our records retention policies. The period of retention is subject to our review and alteration.

  • What Rights Do I Have to Learn More About My Personal Data?

    You may have rights under California laws to learn more about our privacy practices. For more information about these rights, please see the link California Privacy Policy (Consumer). If you cannot access the link, please contact us.

  • How to Contact Us

    You can submit questions, seek additional information, or obtain a copy of our privacy notice in an alternative format by either:

    Calling:             800-344-0197
    Email:               Privacy@libertymutual.com

    Mail:                 Liberty Mutual Insurance Company
                              175 Berkeley St.
                              6th Floor Boston, MA 02116

                              Attn: Privacy Office

  • Who is Providing this Notice?

    This privacy notice is provided on behalf of the following Liberty Mutual companies and affiliates:

    America First Insurance Company, America First Lloyd’s Insurance Company, American Economy Insurance Company, American Fire and Casualty Company, American States Insurance Company, American States Insurance Company of Texas, Colorado Casualty Insurance Company, Consolidated Insurance Company, Employers Insurance Company of Wausau, Excelsior Insurance Company, First National Insurance Company of America, General Insurance Company of America, Golden Eagle Insurance Corporation, Hawkeye-Security Insurance Company, Indiana Insurance Company, Liberty Insurance Corporation, Liberty Mutual Fire Insurance Company, Liberty Mutual Insurance Company, Liberty Mutual Mid-Atlantic Insurance Company, Liberty Northwest Insurance Corporation, LM Insurance Corporation, Montgomery Mutual Insurance Company, North Pacific Insurance Company, Ohio Security Insurance Company, Oregon Automobile Insurance Company, Peerless Indemnity Insurance Company, Peerless Insurance Company, The First Liberty Insurance Corporation, The Midwestern Indemnity Company, The Netherlands Insurance Company, The Ohio Casualty Insurance Company, Wausau Business Insurance Company, Wausau General Insurance Company, Wausau Underwriters Insurance Company, and West American Insurance Company.

To download a copy of this document, please click here.

 Last Updated November 29, 2022