- 1. INTRODUCTION
Strategic Financial Management Pty Ltd (ABN 80 817 212 446) (‘Strategic’, ‘we’, ‘our’, ‘us’) recognises the importance of your right to control your personal information and our staff are trained to respect your privacy in accordance with Strategic policy and procedure.
Strategic is bound by the Australian Privacy Principles ('APPs') and the Privacy Act 1988 ('Privacy Act'). This Policy outlines Strategic’s practices, procedures and systems to manage and protect your personal information in accordance with the Privacy Act and the APPs.
Copies of this Policy are available free of charge by contacting the Privacy Officer or can be downloaded from the Privacy page of our website: www.strategic.com.au.
- ‘Credit information’ is personal information (other than sensitive information) that relates to an individual’s credit history or credit worthiness, and is further defined in the Privacy Act;
- ‘Disclosing’ information means providing information to persons outside Strategic;
- ‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual;
- ‘Privacy Officer’ means the contact person within Strategic for questions or complaints regarding Strategic’s handling of personal information;
- ‘Sensitive information’ is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
- ‘Use’ of information means use of information within Strategic.
- 2. WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We may collect and hold a range of information that we need to provide you with our services, including:
- address and other contact information;
- employment details;
- tax and financial information including bank account details and balances, and tax file number (TFN);
- drivers’ licence and/or passport details;
- details of your current financial position, including insurance arrangements, income, assets and liabilities and estate planning matters; and
- health information.
- 3. HOW WE COLLECT PERSONAL INFORMATION
We generally collect personal information directly from you, the individual. For example, personal information will be collected when you enquire about or engage us to provide you with financial advice, visit our website, call us or send us correspondence.
Sometimes we may collect personal information about you from a third party, including the kinds of organisations and individuals described in section 8 below. In this case we will take reasonable steps to ensure that they are made aware of the matters set out in this Policy.
Strategic will not collect sensitive information about you without your consent unless an exemption under the APPs applies and consent is not required. These exceptions include if the collection is required or authorised by law, or is necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
If you don’t provide us with the personal information we request, we may not be able to provide you with the benefit of our services, or meet your needs appropriately.
Strategic does not give you the option of dealing with us anonymously, or under a pseudonym. This is because it is impractical, and in some circumstances illegal, for Strategic to deal with individuals who are not identified.
- 4. UNSOLICITED PERSONAL INFORMATION
Strategic may receive unsolicited personal information about you. We destroy all unsolicited personal information we receive, unless it is relevant to Strategic’s purposes for collecting personal information.
- 5. ABOUT WHOM DO WE COLLECT PERSONAL INFORMATION?
The personal information we may collect and hold includes (but is not limited to) personal information about the following individuals:
- potential clients;
- service providers or suppliers;
- other third parties with whom we come into contact.
- 6. WEBSITE COLLECTION
- 7. HOW DOES STRATEGIC USE PERSONAL INFORMATION?
We may use and disclose your personal information to:
- provide you with financial advice
- implement your instructions, including to establish and manage investments, margin loans and accounts, and arrange and maintain insurance cover;
- make arrangements to accept and process deposits or contributions, transfer funds or pay benefits;
- report on the implementation of your financial plan or performance of your investments;
- let you know about other products or services we offer or invite you to events;
- conduct our business and perform other management and administration tasks;
- consider your concerns or complaints and manage legal actions involving Strategic;
- comply with relevant laws, regulations and other legal obligations; and
- help us improve the products and services, and enhance our overall business.
Strategic may also use and disclose personal information for reasonably expected secondary purposes which are related to the primary purposes set out above and in other circumstances authorised by the Privacy Act.
Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agrees otherwise, or where certain other limited circumstances apply (e.g. if required by law).
- 8. WHO DO WE GIVE PERSONAL INFORMATION TO?
We may disclose personal information to:
- a related entity of Strategic;
- any organisations that provide you with, manage or administer financial products or services, including any fund (administrator or trustee) to which your benefit is to be transferred or rolled over;
- other financial advisers, custodians, external dispute resolution services, insurers, investment managers or mail houses
- your employer (regarding employer sponsored superannuation arrangements);
- medical practitioners and other relevant professionals, where you have applied for insurance cover or made a claim;
- any financial institution who holds an account for you
- any professional advisers appointed by us
- businesses that may have referred you to us.
- an agent, professional adviser or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, information and IT managers;
- organisations involved in a transfer or sale of all or part of our assets or business;
- organisations involved in managing payments, including payment merchants and other financial institutions such as banks;
- regulatory bodies, government agencies, law enforcement bodies and courts;
- anyone else to whom the individual authorises us to disclose it or is required by law.
If we disclose your personal information to service providers that perform business activities for us the service provider may use your personal information only for the specific purpose for which we supply it.
There are also situations where we may disclose your personal information if it is:
- required by law (such as to the Australian Taxation Office)
- authorised by law (such as where we are obliged to disclose information in the public interest or to protect our interests)
- necessary in discharging obligations (such as to foreign governments for the purposes of foreign taxation)
- required to assist in law enforcement (such as to a police force).
- 9. SENDING INFORMATION OVERSEAS
We will not send personal information overseas without your consent unless:
- we have taken reasonable steps to ensure that the recipient does not breach the Act, or the APPs; or
- the recipient is subject to a similar information privacy regime.
- 10. MANAGEMENT OF PERSONAL INFORMATION
Strategic recognises how important the security of personal information is to clients. We will at all times seek to ensure that the personal information we collect and hold is protected from inference, misuse or loss, and unauthorised access, modification or disclosure.
Personal information is generally held in client files. Information may also be held in a computer database. All paper files are stored in secure areas. Computer-based information is protected through the use of access passwords.
In relation to our computer-based information, we apply the following guidelines:
- data ownership is clearly defined within Strategic;
- passwords are routinely checked;
- employees have restricted access to certain sections of the system;
- the system automatically logs and reviews all unauthorised access attempts;
- unauthorised employees are barred from updating and editing personal information;
- all personal computers which contain personal information are secured, physically and electronically;
- print reporting of data containing personal information is limited;
- Strategic has created procedures for the disposal of personal information; and
- personal information is overwritten to the extent possible when the information is no longer required.
Where we no longer require the personal information for a permitted purpose under the APPs, we will take reasonable steps to destroy it.
- 11. IDENTIFIERS
We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes, unless one of the exemptions in the Privacy Act applies. Strategic endeavours to avoid data-matching, being the comparison of data collected and held for two or more separate purposes in order to identify common features as a basis for further investigation or action.
- 12. HOW DO WE KEEP PERSONAL INFORMATION ACCURATE AND UP-TO-DATE?
Strategic is committed to ensuring that the personal information it collects, uses and discloses is relevant, accurate, complete and up-to-date.
We encourage you to contact us to update any personal information we hold about you. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge individuals for correcting the information.
- 13. ACCESS TO PERSONAL INFORMATION
Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information that we hold about you by contacting the Strategic Privacy Officer. We will provide access within 30 days of your request. If we refuse to provide the information, we will provide reasons for the refusal.
An administrative fee for search and photocopying costs may be charged for providing access to your personal information.
- 14. ENQUIRIES AND COMPLAINTS
If you have any questions, or if wish to make a complaint about how we have dealt with your personal information you may lodge a complaint with us by:
- telephoning – (03) 9818 7222
- by writing to – Strategic Privacy Officer, P.O. Box 5101, Glenferrie South, Vic, 3122
- by emailing – firstname.lastname@example.org
If you are not satisfied with our response to your complaint you can ask the Office of the Australian Information Commissioner to consider it by
- telephoning - 1300 363 992
- writing to - Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
- emailing - [email protected]