1. Overview
Protecting clients’ privacy is very important to us. To ensure our compliance with the Privacy Act 1988 (Cth) (the Privacy Act) and as part of our commitment to ensuring the safety of our clients’ private and confidential information, we have established and implemented this Privacy Policy (the Policy).
The Privacy Act requires that we handle your personal information in accordance with a set of national principles, known as the Australian Privacy Principles, which regulate the collection, use, correction, disclosure and transfer of personal information about individuals by organisations in the financial industry.
If you would like more information about how we protect your privacy, please contact us.
Purpose
The Policy explains our policies and practices with respect to the collection, use and management of your personal information and our approach to the Australian Privacy Principles.
2. Collection
What information do we collect?
We will collect and hold your personal information for the purpose of providing financial advice services to you.
The type of information collected from you includes information that is necessary for us to provide advice to you. We may ask you to provide personal information such as:
- Your name, date of birth and occupation
- Your income, expenses, assets and liabilities
- Your tax file number (TFN)
- Details of your partner and dependents
- Your citizenship status
- Your current insurances
We will only collect sensitive information to provide you with financial products and services. Sensitive information includes information or an opinion relating to a person’s racial or ethnic origin, political views or memberships, religious beliefs or affiliations, membership of a professional or trace association or trade union, sexual orientation or practices and criminal record. It also includes information about a person’s health and medical history. The Australian Privacy Principles set out restrictions about the way sensitive information can be used. Unless you give us your consent, or if we are required or permitted by law, we will only use or disclose sensitive information for the purposes for which it was provided.
If you do not provide us with personal information of the type indicated above, or you provide incomplete or inaccurate information, we may not be able to provide you with advice that is appropriate to your needs, circumstances and objectives.
We are also required to ask for certain information by law. Wherever there is a legal requirement for us to ask for information about you, we will inform you of the obligation and the consequences of not giving us the requested information.
For example, in addition to obtaining personal information from you, whenever you acquire a new product or service via us, we will need to obtain certain documentary evidence from you as to your identity to ensure compliance with AML/CTF laws. Such evidence may include for example a certified copy of your driver’s licence, passport or birth certificate.
If we receive any information about you that is unsolicited and is not required to be collected for the purposes outlined in this section, we will, if it is lawful and reasonable to do so, destroy the information or ensure the information is de-identified.
How do we collect personal information?
We collect your personal information directly from you where this is reasonable and practical. We gather this information either through application or other forms you complete (commonly referred to as “fact finding” documents) or by recording the information you provide via phone calls, interviews and other forms of communication.
In addition to the above, we may also collect information from you from external sources. Examples of the people or organisations who may provide us with information are:
- Parents or guardians, in respect of children
- People authorised by you (such as lawyers or accountants)
- Public sources of information (such as telephone directories)
- Third-party brokers (such as insurance brokers)
How do we up-date your personal information?
You can let us know about your up-dated personal information over the telephone or in writing (including email). We will use this information to up-date our internal records only.
Where we manage investments for you, we will ask you to sign a form for each of the investments that you hold and we will forward this form to the relevant external institutions. In some instances, the external institutions will require additional documentation as evidence of the change (such as where you have changed your name). We will let you know if this is required.
If we believe the information we hold is incomplete or out of date, we may also seek to correct or up-date our records by gathering data from other sources, such as public records and other organisations.
3. Use of information
How do we use the information that we collect from you?
We use your personal information for the purpose providing financial services and advice to you.
We may also, from time to time, use your personal information (excluding sensitive information) for the purposes of direct marketing to you. Generally, we will only provide you with direct marketing if you have consented for us to do so, and you are able to opt out of receiving direct marketing from us at any time by contacting your financial adviser.
4. Disclosure
Who do we give your information to?
- We may disclose your information to the following parties:
- Product issuers with whom you are investing or taking out insurance policies with
- Internal staff members of GMP Financial
- External compliance contractors for the purposes of auditing our financial advice
- Accountants, solicitors and other professionals to whom you consent to disclose your information for the purpose of providing services to you related to your financial planning requirements.
There are also situations where we may also disclose your personal information where it is:
- required by law (such as to the Australian Taxation Office or pursuant to a court order)
- 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).
We may also disclose your information if you give your consent.
Will my information be disclosed overseas?
Some of the entities we share information with may be located in, or have operations in, other countries. The current list of countries to which your personal information could be sent is set out below:
- Administration, research and other financial services and specialist advice: Canada, India, Malaysia, the Philippines, United States of America
- Sending or receiving superannuation benefits overseas: England, New Zealand
Any overseas disclosure does not affect our commitment to safeguarding personal information we collect and we will take reasonable steps to ensure overseas recipients comply with the Australian Privacy Principles.
5. Storage of your information
We will store your personal information in files within secure office premises, as well as electronically on financial planning software and on secure servers. We have security and privacy measures in place to ensure the integrity of your personal information and to protect it from misuses, interference and loss, and from unauthorised access, modification or disclosure.
Where we hold information that we no longer require for any purpose and it is not required to be maintained by Australian law, we will take reasonable steps to destroy the information or ensure that the information is de-identified.
6. Access and correction of information
Can I access my information and what if it is incorrect?
You may request access to the personal information we hold about you. Before providing the requested information we will give you an estimate of any potential costs associated with this, including expenses for locating, retrieving, reviewing and copying any of the material you need. We may charge a reasonable fee to cover these costs.
There may be circumstances where we are unable to give you access to the information that you have requested. If this is the case we will inform you and explain the reasons why.
We will take reasonable steps to ensure that the personal information we collect, hold, use or disclose is accurate, complete, up to date, relevant and not misleading.
You have a right to ask us to correct any information we hold about you if you believe it is inaccurate, incomplete, out of date, irrelevant or is misleading. If we do not agree with the corrections you have supplied and refuse to correct the personal information, we are required to give you a written notice to that effect and a statement if requested. Where we do not allow access, we will provide you with a reason (unless unlawful to do so) in writing, along with details of how you may make a complaint in relation to the refusal.
If you wish to access or correct your personal information, you may contact us through our offices or by writing to the Compliance Manager, whose contact details are set out below.
7. Complaints
We take privacy-related complaints very seriously and consider all complaints carefully as part of our commitment to being open, honest and fair in dealing with your concerns. You can let us know of any concerns you might have in relation to privacy in any of the following ways:
- By telephone: (03) 9913 0590
- By email: milton@gmpfin.com.au
- In writing: Suite 607, Level 6, 10 Yarra Street, South Yarra VIC 3141
Our Compliance Manager will respond to your complaint within 5 days of its receipt.
In the event the Compliance Manager is unable to resolve your complaint, or if you feel it is taking too long to resolve, you may lodge a complaint with the Australian Financial Complaints Authority in the following way:
The Australian Financial Complaints Authority
8. What about privacy and the internet?
Links to third party websites
Our website has links to external third party websites that may be of benefit to you – such as accessing your investment portfolio.
External websites should contain their own privacy statements and we recommend you review them. Please note, third party websites are not covered by this policy, and these sites are not subject to GMP Financial privacy standards and procedures.
Website analytics
Website analytics measurement software is used to assist in tracking patterns to and from our website, anonymously surveying users of the site. The system is used to collect such information as the number of unique visitors, how long these visitors spend on the website, and common entry and exit points into and from the website.
This non-personal information is collected and aggregated by third party software and we use this analysis to better understand and, where needed, modify and improve our website.
You cannot be identified personally from this information and no personal information is stored about you.
9. Changes to our Privacy Policy
We may update or amend our Privacy Policy from time to time as required by law, or changes to our business. An up-to-date version of the Privacy Policy is available by contacting our office on (03) 9913 0590 or via email milton@gmpfin.com.au
