1.
1.1
The information in this document details how we, Personal Wealth Protection Services, comply with the requirements of the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles in protecting the personal information we hold about you.
1.2
Personal information is any information or opinion about you that is capable, or reasonably capable, of identifying you, whether the information or opinion is true or not and is recorded in material form or not.
1.3
Sensitive information includes such things as your racial or ethnic origin, political opinions or membership of political associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or criminal record, that is also personal information. Your health, genetic and biometric information and biometric templates are also sensitive information.
1.4
We will act to protect your personal and sensitive information in accordance with the Australian Privacy Principles and the Privacy Act.
1.5
We collect personal and/or sensitive information to provide you with the products and services you request as well as information on other products and services offered by or through us. The law requires us to collect personal and/or sensitive information.
1.6
Your personal and/or sensitive information may be used by us to administer our products and services, for prudential and risk management purposes and, unless you tell us otherwise, to provide you with related marketing information. We also use the information we hold to help detect and prevent illegal activity. We cooperate with police and other enforcement bodies as required or allowed by law.
1.7
We disclose relevant personal information to external organizations that help us provide services. These organizations are bound by confidentiality arrangements.
1.8
You can seek access to the personal information we hold about you. If the information we hold about you is inaccurate, incomplete, or outdated, please inform us so that we can correct it. If we deny access to your personal information, we will let you know why. For example, we may give an explanation of a commercially sensitive decision, or give you access to the information through a mutually agreed intermediary, rather than direct access to evaluative information connected with it.
2.
2.1
We collect personal information when it is reasonably necessary for one or more of our functions or activities.
2.2
These include:
3.
3.1
The personal and sensitive information we collect generally consists of name, address, date of birth, gender, marital status, occupation, account details, contact details (including telephone, facsimile and e-mail) and financial information.
3.2
If you have or are applying for life insurance or income protection insurance, we also collect medical and lifestyle information that relates to the insurance. This information may include your sexual activity and is collected so we may assess whether to accept your insurance proposal and, if so, on what terms.
4.
4.1
We only collect personal information about you directly from you (rather than someone else) unless it is unreasonable or impracticable to do so or you have instructed us to liaise with someone else.
5.
5.1
We may not be able to provide you with the products or services you are seeking if you provide incomplete or inaccurate information.
6.
6.1
In addition to the above conditions of collecting personal information, we will only collect sensitive information about you if we obtain prior consent to the collection of the information or if the collection is required or authorized by law.
7.
7.1
We are committed to ensure that we protect any personal information we hold from misuse, interference, loss, unauthorized access, modification and disclosure.
7.2
For this purpose, we have a range of practices and policies in place to provide a robust security environment. We ensure the ongoing adequacy of these measures by regularly reviewing them.
8.
8.1
Depending on the product or service you have, the entities we exchange your information with include but are not limited to:
8.2
Our use or disclosure of personal information may not be limited to the examples above.
9.
9.1
We may be required to disclose customer information by law e.g. under Court Orders or Statutory Notices pursuant to taxation or social security laws or under laws relating to sanctions, anti-money laundering or counter terrorism financing.
10.
10.1
We will only use or disclose the personal information we hold about you for the purpose of direct marketing if we have received the information from you and you have not requested not to receive such information.
10.2
Direct marketing means that we should use your personal information to provide you with information on our products and services that may interest you.
10.3
If you wish to opt-out of receiving marketing information altogether, you can:
11.
11.1
You can request us to provide you with access to the personal information we hold about you.
11.2
Requests for access to limited amounts of personal information, such as checking to see what address or telephone number we have recorded, can generally be handled over the telephone.
11.3
If you would like to request access to more substantial amounts of personal information such as details of what is recorded in your account file, we will require you to complete and sign a “Request for Access to Personal Information” form.
11.4
We will respond to your request as soon as possible and in the manner requested by you. We will endeavour to comply with your request within 14 days of its receipt but, if that deadline cannot be met owing to exceptional circumstances, your request will be dealt with within 30 days. It will help us provide access if you can tell us what you are looking for.
11.5
Your identity will be confirmed before access is provided.
12.
12.1
In particular circumstances we are permitted by law to deny your request for access, or limit the access we provide. We will let you know why your request is denied or limited if this is the case. For example, we may give an explanation of a commercially sensitive decision rather than direct access to evaluative information connected with it.
13.
13.1
If we refuse to give access to the personal information or to give access in the manner requested by you, we will give you a written notice setting out the reasons for the refusal, the mechanisms available to complain and any other relevant matter.
13.2
Additionally, we will endeavour to give access in a way that meets both yours and our needs.
14.
14.1
We will correct all personal information that we believe to be inaccurate, out of date, incomplete, irrelevant or misleading given the purpose for which that information is held or if you request us to correct the information.
14.2
If we correct your personal information that we previously disclosed to another APP entity you can request us to notify the other APP entity of the correction. Following such a request, we will give that notification unless it is impracticable or unlawful to do so.
15.
15.1
If you have any questions or would like further information about our privacy and information handling practices, please contact us by:
16.
16.1
We offer a free internal complaint resolution scheme to all of our customers. Should you have a privacy complaint, please contact us to discuss your concerns.
16.2
You will also have free access to an external dispute resolution scheme in which we are member.
16.3
To assist us in helping you, we ask you to follow a simple three-step process:
16.4
If the matter is not resolved to your satisfaction, you have the right to contact the Office of the Australian Information Commissioner (“OAIC”). You can contact the OAIC to make a query concerning your privacy rights, or to lodge a complaint with the OAIC about how we have handled your personal information. You can contact the OAIC’s hotline on 1300 363 992 or visit their website at www.oaic.gov.au. The OAIC has the power to investigate a complaint and make a determination.