OUR
COMMITMENT
Direct Advisers Pty Limited is
committed to implementing and promoting a privacy policy, which will ensure the
privacy and security of your personal information. The following Privacy Policy expresses our policies on the
management of your personal information.
At Direct Advisers we recognise
that your privacy is very important to you – it is to Direct Advisers as well.
We handle personal information provided by and about people every day.
By personal information we mean information or an opinion about a person
whose identity is apparent or can reasonably be ascertained.
We are bound by, and committed
to supporting, the National Privacy
Principles (NPPs) set out in the Privacy
Amendment (Private Sector) Act 2000. Our
aim is to both support, and ensure that we comply with, the NPPs that form the
basis of laws introduced to strengthen privacy protection for the general
public. The information set out
below is largely a summary of our obligations under the NPPs.
We believe that this Statement
will address any potential concerns you may have about how personal information
you provide to Direct Advisers is collected, held, used, corrected, disclosed
and transferred. You can obtain
more information on request about the way we manage the personal information we
hold. If you seek any further
information please contact us in one of the ways set out below.
COLLECTION
As a financial planning 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 a comprehensive financial planning and advice service is dependent on us obtaining certain personal information about you, including:
 | 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 your investment preferences and aversion or tolerance to risk; |
| Information about your employment history, employment circumstances, family commitments and social security eligibility; |
| Details of the members of your family |
| Health details about yourself and the members of your family |
| Details of your existing life insurance |
| Details in regard to your estate planning |
| Details of any Centrelink or Veteran’s Affairs benefits |
| Details of your tax file number when we place investments on your behalf. |
Failure to provide the personal
information referred to above may expose you to higher risks in respect of the
recommendations made to you and may affect the adequacy or appropriateness of
advice we give to you.
As we are required pursuant to
the Corporations Act and Rules of Professional Conduct of the Financial Planning
Association of Australia to collect sufficient information to ensure appropriate
advice can be given in respect of recommendations made to our clients, if you
elect not to provide us with the personal information referred to above, we may
elect to terminate our relationship with you if we believe we are unable to
provide you with a complete service.
We will not collect any personal
information about you except when you have knowingly provided that information
to us or authorised a third party to provide that information to us.
Generally collection of your
personal information will be effected in either face to face interviews, over
the telephone or online using one of our standardised questionnaires.
From time to time additional and/or updated personal information may be
collected through one or more of those methods.
We will only collect, maintain and use Personal Information about you if it is necessary for us to adequately provide to you the services you have requested including:
| The preparation of your financial plan; |
| The provision of financial planning advice to you; |
| Making securities and investment recommendations; |
| Reviewing your financial plan; |
| Reviewing securities and investment recommendations; |
| Providing investment consultancy services to you. |
We will not use or disclose Personal Information collected by us for any purpose other than:
| The purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; |
| Where you have consented to such disclosure; or |
| Where the National Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body. |
We are required under the Rules of Professional Conduct of the Financial Planning Association of Australia to make certain information available for inspection by the Association on request to ensure ongoing compliance with mandatory professional standards. This may involve the disclosure of your personal information. We are also obliged pursuant to the Corporations Act to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission.
We may use the personal information collected from you for the purpose of providing you with direct marketing material such as articles that may be of interest to you, however you may, by contacting us by any of the methods detailed below, request not to receive such information and we will give effect to that request. Please allow 2 weeks for your request to be actioned.
We may disclose your personal information to another financial planner during periods when this office is unmanned or closed so that you can be assured of receiving a continued service.
We may disclose your Personal Information to superannuation fund trustees, insurance providers, fund managers and other product issuers for the purpose of giving effect to your financial plan and the recommendations made by us.
In order to ensure that you
receive a personal and tailored service, your Personal Information may be
transferred to one of our agents or authorised representatives who will be your
primary point of contact with the organisation. It is a condition of our agreement with each of our
representatives that they adopt and adhere to this privacy policy.
You can be assured that your information will be maintained by any agent
or representative in accordance with this policy.
If you have any concerns in this regard, you should contact us by any of
the methods detailed below.
We may disclose your personal information to external contractors for the following purposes:
| Preparation of a financial plan |
| Monitoring of compliance to legislation |
It is a condition of our agreement with each of our external contractors that they adopt and adhere to this privacy policy. You can be assured that your information will be maintained by any contractor to whom it is disclosed in accordance with this policy. If you have any concerns in this regard, you should contact us by any of the methods detailed below.
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 effected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer.
SECURITY
Your personal information is
generally held in your client file. Information
may also be held in a computer database.
We will at all times seek to
ensure that the personal information collected and held by us is protected from
misuse, loss, 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 stored in lockable storage room, which is locked out
of hours. All record movements off
premises are recorded in a central register.
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 off site storage facility for a period of at
least seven years in order to comply with legislative and professional
requirements, following which time the information will be destroyed.
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 will not provide you access
to personal information which would reveal any confidential formulae or the
detail of any in house evaluative decision making process, but may instead
provide you with the result of the formulae or process or an explanation of that
result.
We will not provide you with access to your personal information if:
| Providing access would pose a serious threat to the life or health of a person; |
| Providing access would have an unreasonable impact on the privacy of others; |
| The request for access is frivolous or vexatious; |
| The information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings; |
| Providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations; |
| Providing access would be unlawful; |
| Denying access is required or authorised by or under law; |
| Providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security. |
In the event we refuse you
access to your personal information, we will provide you with an explanation for
that refusal.
We will endeavour to ensure that, at all times, the personal information about you, which we hold is up to date and accurate. 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 outdatedness 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 must, if you request, take
reasonable steps to ensure that whenever your personal information is accessed
or handled in the future, it is apparent that you are not satisfied as to the
accuracy or completeness of that information.
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.
MAKING
A PRIVACY COMPLAINT
If you wish to complain about
any breach or potential breach of this privacy policy or the National Privacy
Principles, you should contact us by any of the methods detailed below and
request that your complaint be directed to the Privacy Officer.
Your complaint will be considered within 7 days and responded to.
It is our intention to use our best endeavours to resolve any complaint
to your satisfaction, however, if you are unhappy with our response, you are
entitled to contact the Office of the Privacy Commissioner who may investigate
your complaint further.
ONLINE
ENVIRONMENT
This Web site contains links to
other Web sites whose operator may or may not adhere to a privacy policy or be
governed by the National Privacy Principles.
While it is not necessary to register your personal details to use our Web site, we do offer an email registration service which will enable you to receive product and service updates, newsletters and other information. In the event you do register with us, we will collect personal information from you including
| Your name, phone / fax numbers and e-mail address |
| Your occupation |
| Your age group |
| Your income range |
| Whether or not you have a financial planner |
| Whether you would like one of our planners to contact you |
| Whether your primary interest is managed funds or shares |
| How you heard about us |
If you have registered with us
and decide, at any time, that you do not wish to receive any further information
from us, you can send an e-mail to the e-mail address noted below requesting to
be removed from our online registration database.
Please allow 2 weeks for your request to be actioned.
You may amend or update your
registration details by sending an e-mail to the e-mail address noted below
providing your amended details. Please
allow 2 weeks for your request to be actioned.
Our Web sites use cookies, which allow us to identify your browser while you are using our site. Cookies do not identify you, they simply allow us to track usage patterns so that we can measure the level of interest in various areas of our site. All browsers allow you to be notified when you receive a cookie and elect to either accept it or not. Your Internet service provider should be able to assist you to set your preferences.
Privacy Officer: Peter Rodgers
Address: P.O. Box 269 Port Macquarie, 2444
Telephone: 02 6583 7588
Facsimile: 02 6583 7123
Contact us: enquiries@directadvisers.com.au
