Redgum Wealth Group Pty Ltd
- INTRODUCTION
Redgum Wealth Group Pty Ltd AFSL 277780 (referred to as Redgum Wealth Group, we, our, us) is bound by the Privacy Act 1988 (Privacy Act), including the Australian Privacy Principles (APPs) and recognises the importance of ensuring the confidentiality and security of your personal information.
All third parties (including clients, suppliers, sub-contractors or agents) that have access to or use personal information collected and held by Redgum Wealth Group, must abide by this Policy and Collection Statement. Redgum Wealth Group makes this Privacy Policy and Collection Statement available free of charge and can be downloaded from its website www.redgumwealth.com.au
In this Privacy Policy and Collection Statement:
• Disclosure of information means providing information to persons outside Redgum Wealth Group,
• 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 Redgum Wealth Group for questions or complaints regarding Redgum Wealth Group’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, criminal record and also includes health information, and
• Use of information means use of information within Redgum Wealth Group.
- WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
Redgum Wealth Group will only collect information from you where we believe it is necessary to provide you with financial planning services.
As a provider of financial planning services, we are subject to certain legislative and regulatory requirements which require us to collect and hold detailed information, which personally identifies you and/or contains information or an opinion about you. Our ability to provide you with comprehensive financial planning services and advice is dependent upon us obtaining certain personal and sensitive information about you, which may include (but is not limited to):
• Name and address,
• Date of Birth,
• Phone numbers,
• Email addresses,
• Bank Account details,
• Tax File Number,
• County of Birth,
• Employment details and employment history,
• Details of your financial needs and objectives,
• Details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, insurance cover and superannuation,
• Details of any entities you have in place or act as a Director of,
• Details of your investment preferences and aversion to or tolerance of risk,
• Details of your social security eligibility,
• Details of your estate planning requirements and instructions,
• Health information (for some types of insurance) and
• Driver’s licence or passport details for identification purposes to comply with Anti Money Laundering (AML) regulations
Where reasonably possible and practical, we will only obtain information directly from you or with your consent to gain information from a third party, in relation to certain products or other details. This may take the form of face to face meetings, telephone discussions, email correspondence, data collection forms, electronic means and from maintaining records during the course of providing ongoing financial services.
You can elect not to provide us with your personal and sensitive information. However, in doing so we may not be able to provide you with the financial services requested. Alternatively, it may expose you to higher risks in respect of the recommendations made to you as it may affect the appropriateness of the financial advice or service provided to you.
- HOW WE COLLECT PERSONAL INFORMATION
We generally collect personal information directly from you. For example, personal information will be collected through our application processes, forms and other interactions with you in the course of providing you with our products and services, including when you visit our website, use a mobile app from us, call us or send us correspondence.
We may also collect personal information about you from a third party, such as electronic verification services and referrers. If so, we will take reasonable steps to ensure that you are made aware of this Policy and Collection Statement. We may also use third parties to analyse traffic at our website, which may involve the use of cookies. Information collected through such analysis is anonymous.
We will not collect sensitive information about you without your consent unless an exemption in the APPs applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
If the personal information we request is not provided by you, we may not be able to provide you with the benefit of our services or meet your needs appropriately.
We do not give you the option of dealing with them anonymously or under a pseudonym. This is because it is impractical and in some circumstances illegal, for Redgum Wealth Group to deal with individuals who are not identified.
- WHY DO WE COLLECT AND HOLD PERSONAL INFORMATION?
We may use and disclose the information we collect about you for the following purposes:
• provide you with our products and services,
• review and meet your ongoing needs,
• provide you with information we believe may be relevant or of interest to you,
• let you know about other products or services we offer or invite you to events,
• consider any concerns or complaints you may have,
• comply with relevant laws, regulations and other legal obligations,
• help us improve the products and services offered to our clients and enhance our overall business.
We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes, which are related to the primary purposes set out above or 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 agree otherwise or an exemption in the Privacy Act applies.
- WHO MIGHT WE DISCLOSE PERSONAL INFORMATION TO?
We may disclose personal information to:
• a related entity of Redgum Wealth Group,
• an agent, contractor or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, auditors, actuaries, stockbrokers, debt collectors or other advisors,
• 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,
• financial product issuers and credit providers, and
• anyone else to whom you authorise us to disclose it or is required by law.
If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues and will make third parties aware of this Policy and Collection Statement.
We may disclose the following personal information to a Credit Reporting Body (CRB), in order to comply with our obligations under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (AML/CTF obligations):
• name,
• date of birth, and
• residential address.
The purpose of disclosing this information is to enable us to verify whether the personal information collected matches the identification information held by the CRB. We may, upon request, provide you with an alternative method of verification, however, any alternative verification method must also comply with the AML/CTF legislation.
- MANAGEMENT OF PERSONAL INFORMATION
We recognise the importance of securing the personal information of our clients. We will take steps to ensure your personal information is protected from misuse, interference or loss and unauthorised access, modification or disclosure.
Your personal information is generally stored in our computer database. Any paper files are stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:
• passwords are required to access the system and passwords are routinely checked,
• data ownership is clearly defined,
• we change employees’ access capabilities when they are assigned to a new position,
• 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 computers which contain personal information are secured both physically and electronically,
• print reporting of data containing personal information is limited.
- IDENTIFIERS
We do not adopt identifiers assigned by the Government (such as driver’s licence numbers) for our own file recording purposes, unless one of the exemptions in the Privacy Act applies.
- HOW DO WE KEEP PERSONAL INFORMATION ACCURATE AND UP-TO-DATE?
We are committed to ensuring that the personal information we collect, use and disclose 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 you for correcting the information.
- ACCESSING YOUR 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 Redgum Wealth Group Privacy Officer. We will provide access within 30 days of the individual’s request. If we refuse to provide the information we will provide reasons for the refusal.
We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged for providing access.
- UPDATES TO THIS POLICY AND COLLECTION STATEMENT
This Policy and Collection Statement will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.
- RESPONSIBILITIES
It is the responsibility of management to inform employees and other relevant third parties about this Policy and Collection Statement. Management must ensure that employees and other relevant third parties are advised of any changes to this Policy and Collection Statement. All new employees are to be provided with timely and appropriate access to this Policy and Collection Statement and all employees are provided with training in relation to appropriate handling of personal information. Employees or other relevant third parties that do not comply with this Policy and Collection Statement may be subject to disciplinary action.
- NON-COMPLIANCE AND DISCIPLINARY ACTIONS
Privacy breaches must be reported to management by employees and relevant third parties. Ignorance of this Policy and Collection Statement will not be an acceptable excuse for non-compliance. Employees or other relevant third parties that do not comply with this Policy and Collection Statement may be subject to disciplinary action.
- INCIDENTS/COMPLAINTS HANDLING/MAKING A COMPLAINT
We have an effective complaint handling process in place to manage privacy risks and issues.
The complaints handling process involves:
• identifying (and addressing) any systemic/ongoing compliance problems,
• increasing client confidence in our privacy procedures, and
• helping to build and preserve our reputation and business.
You can make a complaint to us about the treatment or handling of your personal information by lodging a complaint with the Privacy Officer.
If you have any questions about this Policy and Collection Statement or wish to make a complaint about how we have handled your personal information, you can lodge a complaint with us by:
• writing –
Redgum Wealth Group Pty Ltd
Privacy Officer
PO Box 199
Collins Street West VIC 8007
• emailing – [email protected]
If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner by:
• telephoning – 1300 363 992
• writing – Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
• emailing – [email protected]
- CONTRACTUAL ARRANGEMENTS WITH THIRD PARTIES
We ensure that all contractual arrangements with third parties adequately address privacy issues and make third parties aware of this Policy and Collection Statement.
Third parties will be required to implement policies in relation to the management of your personal information in accordance with the Privacy Act. These policies include:
• regulating the collection, use and disclosure of personal and sensitive information,
• de-identifying personal and sensitive information wherever possible,
• ensuring that personal and sensitive information is kept securely, with access to it only by authorised employees or agents of the third parties, and
• ensuring that the personal and sensitive information is only disclosed to organisations which are approved by us.
- YOUR RIGHTS
This Privacy Policy and Collection Statement contains information about how:
• you may access the personal information we hold about you,
• you may seek the correction of your personal information,
• you may ask us to provide an alternative means of identity verification for the purposes of the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth),
• you may complain about a breach of the Privacy Act, including the APPs; and
• we will deal with a privacy complaint.