Information we collect
As a financial services organisation we are subject to certain legislative and regulatory requirements which necessitate us obtaining and holding detailed information which personally identifies you and/or contains information or an opinion about you (“personal information”). In addition, our ability to provide you with comprehensive financial service(s) is dependent on us obtaining certain personal information about you, information including:
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, have requested from us.
The privacy laws impose greater obligations on us regarding any collection, use or disclosure of your sensitive information. We will only collect your sensitive information if:
Method of collection
Generally, collection of your personal information will be effected in either face-to-face interview, over the telephone, by email or by way of a client application form. From time to time additional and/or updated personal information may be collected through one or more of those methods.
There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect personal information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected. Where we receive unsolicited personal information about you, we will determine within a reasonable period whether we may retain it or are required to destroy or de-identify it and take the appropriate action.
In general, you can visit our website without telling us who you are or revealing any personal information about yourself. If you access our website, we may collect additional personal information about you in the form of your IP address and domain name.
Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.
Purpose of collection
We will only collect, maintain and use personal information about you if it is reasonably necessary or directly related to our functions and activities, including for us to adequately provide to you the services you have requested such as:
Use and disclosure
We will not use or disclose personal information collected by us for any purpose other than:
We may disclose your personal information to third party service providers, who assist us in operating our business, such as technology service providers or other professional services providers, including any custodian or sub-custodian. These providers may be based overseas or use overseas infrastructure to perform services for us, including Canada, Malaysia and the United Kingdom.
In the event that we propose to sell our business we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Any such disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them. In the event that a sale of our business is affected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer.
Your personal information may be stored on paper and in electronic form.
We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, interference, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential. All paper files are kept in lockable storage. Access to our premises is controlled by allowing only authorised personnel to access the premises. All computer based information is protected through the use of access passwords on each computer and screen saver passwords. Data is backed up each evening and stored securely off site.
In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in a secure storage facility for a period of 7 years in order to comply with legislative and professional requirements, following which time the information will be destroyed.
Your personal and sensitive information will be stored in servers located in Australia for the purposes set out above.
Access and correction
You may at any time, by contacting us by any of the methods detailed below, request access to your personal information and we will (subject to the following exceptions) provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. We will, prior to providing access in accordance with this policy, require you to provide evidence of your identity.
We may charge you a reasonable fee for providing access to your personal information (but not for making a request for access).
We will not provide you with access to your personal information if:
In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal which sets out the reasons (unless it would be unreasonable to provide those reasons).
We will endeavour to ensure that, at all times, the personal information about you which we hold is accurate, up to date and complete. In the event that you become aware, or believe, that any personal information which we hold about you is inaccurate, incomplete or outdated, you may contact us by any of the methods detailed below and provide to us evidence of the inaccuracy or incompleteness or out datedness and we will, if we agree that the information requires correcting, take all reasonable steps to correct the information.
If we do not agree that your personal information requires correcting, we will provide you with a written notice setting out our reasons (unless it would be unreasonable for us to do so) and the mechanisms available to you to make a complaint, and you also have the right to request that a statement be associated with your personal information noting that you disagree with its accuracy.
We will endeavour to respond to any request for access within 14–30 days depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.
GPO Box 3263
Brisbane QLD 4001
07 3229 5531
For more information about privacy in general, you can visit the federal Information Commissioner’s website at www.oaic.gov.au.
Chief Executive Officer
GPO Box 3263
Brisbane QLD 4000
07 3229 5531
Changes to this Policy