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10 December 2021
Protecting our clients’ privacy is very important to us. To ensure our compliance with the Privacy Act and as part of our commitment to ensuring the safety of your private and confidential information, we have established and implemented this 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 (APPs), which regulate the collection, use, correction, disclosure and transfer of personal information about individuals by organisations like us in the private sector.
The Policy explains our policies and practices with respect to the collection, use and management of your personal information and our approach to the APPs.
This Policy applies to Insignia Financial Ltd (formerly known as IOOF Holdings Ltd) and its subsidiaries and related bodies corporate, which include APRA Regulated Entities, Responsible Entities, Australian Financial Services Licensees and all Australian business divisions (collectively referred to as “the Insignia Financial group” in this Policy). Where an entity specifically adopts this Policy (for example an ASIC or APRA-regulated entity), references to Insignia Financial are taken to be a reference to that entity. This Policy applies to the Insignia Financial group’s business activities carried on in Australia. In the event of any inconsistencies between the Policy requirements and the Insignia Financial group’s statutory duties under Australian law, the latter shall prevail.
Definitions used in this Policy are set out in section 6.
We will collect and hold your personal information for the purposes of:
The type of information collected from you includes information that is necessary to operate your account or for us to provide advice to you. We may ask you to provide personal information such as your:
We may also collect personal information from you regarding your family situation, your partner, dependants, beneficiaries, and children, if it is considered necessary to provide you services, such as financial planning advice where members of your family may become beneficiaries to your life insurance policy or superannuation fund. If you provide us with personal information about another person, we expect and assume that you have that person's permission to provide this information to us and that you have made them aware that their personal information will be handled in accordance with this Policy.
This information is primarily collected from application forms you have completed, your use of our online facilities, or through ongoing communications with you or persons you authorise to communicate with us on your behalf.
There are specific circumstances in which we will ask for your consent to provide sensitive information such as:
We will inform you of any legal requirements for us to request information about you and the consequences of not providing that information. For example, in addition to the personal information we will obtain from you, whenever you acquire a new product or service from us, we will require documents evidencing your identity. Such evidence may include a certified copy of your driver’s licence, passport or birth certificate. If you do not provide identity documentation, we may not be able to action your request.
We will solicit personal information about you where you have knowingly provided that information to us, we believe you have authorised a third party to provide that information to us, or we are obligated or authorised by law to obtain such information. Third parties that we may need to collect information from include your financial adviser, product issuer, employer, accountant or solicitor. To verify your identity for Know Your Customer (KYC) purposes, we may also solicit personal information about you from reliable identity verification service providers.
In order to identify opportunities to improve our products and services and to enhance your customer experience with us, we may also collect data from third parties. Prior to engaging any third party, a thorough due diligence process is undertaken to ensure your personal information is fully protected. This includes ensuring that sufficient security measures and relevant confidentiality and contractual arrangements are in place which, at a minimum, require the third party to handle personal information in strict accordance with our requirements under Australian privacy law.
You are not obligated to give us the information that we request. However, if you do not give us the information that we ask for, or the information you give is not complete or accurate, this may:
For example, we are required to ask for your TFN when you become a member of one of our superannuation products. If you choose to not give us your TFN, you may be subject to higher tax charges on your superannuation, we may not be able to locate different accounts in your name, and we may not be able to accept personal contributions.
We use your personal information for the purpose for which it has been obtained and for related purposes. For example, we collect your personal information so that we are able to:
For the purpose of providing the services you have requested to you (or an authorised related purpose), we may provide your information to other companies within the Insignia Financial group or external parties. Where personal information is disclosed, we have strict controls in place to ensure information is held, used and disclosed in accordance with the APPs.
The types of external organisations to which we may disclose your personal information include:
Like other financial services companies, there are situations where we may also disclose your personal information where it is:
We may also disclose your information if you give your consent.
It is generally unlikely that we will disclose your personal information overseas. However, we may occasionally use third-party service providers or offshore outsourcing services to provide services to you. Depending on the circumstances, the relevant countries will vary such that it is not practicable to list them here.
Any overseas disclosure does not affect our commitment to safeguarding your personal information and we will take reasonable steps to ensure any overseas recipient complies with the APPs.
Where it is likely that we will transfer your personal information overseas, we will either seek your consent or inform you and ensure that appropriate contractual measures are in place requiring the overseas entity to protect your personal information in accordance with our obligations under Australian privacy law.
You may request access to the personal information we hold about you. We may charge a reasonable fee to cover our 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 will give you a written notice to that effect.
If you wish to access or correct your personal information, you may contact us through our offices or by writing to the Privacy Officer, whose contact details are set out in section 4.
We have security systems, practices and procedures in place to safeguard your privacy. We may use cloud storage or third-party servers to store the personal information we hold about you. These services are subject to regular audit and the people who handle your personal information have the training, knowledge, skills and commitment to protect it from unauthorised access, disclosure or misuse.
If you use the secure adviser or client sections of our websites, we will verify your identity by your username and password. Once verified, you will have access to secured content. You are responsible for maintaining the secrecy of your login details.
You should note that there are inherent security risks in transmitting information through the internet. You should assess these potential risks when deciding whether to use our online services. If you do not wish to transmit information through our website, there are other ways in which you can provide this information to us. You can, for example, contact our ClientFirst team. Refer to section 4 for ClientFirst's contact details.
All browsers allow you to be notified when you receive a cookie and you may elect to either accept it or not. If you wish not to accept a cookie, this may impact the effectiveness of the website. Your internet service provider or other IT service provider should be able to assist you with setting your preferences.
We are required by law to retain certain records of information for varying lengths of time and, in certain circumstances, permanently. Where your personal information is not required to be retained under law and is no longer required for the purpose for which it was collected, we will take reasonable steps to irrevocably destroy or de-identify it.
If you reside in a country that is a member of the European Economic Area (the EU and Norway, Lichtenstein and Iceland), in addition to the protection you receive under the Privacy Act, you are entitled to other protections provided by the GDPR, including, in certain circumstances, the right to:
The Insignia Financial Ltd Board is ultimately responsible for overseeing the Policy.
The Privacy Officer is responsible for updating this Policy and for managing the business impacts of privacy laws across the Insignia Financial group.
You can contact the Privacy Officer by:
Insignia Financial Ltd
GPO Box 264
Melbourne VIC 3001
or by email: Privacy.Officer@ioof.com.au
You can contact the ClientFirst team by telephoning 1800 913 118
If you believe that we have breached the APPs by mishandling your information, you may lodge a written complaint addressed to the Privacy Officer, whose contact details are set out in section 4.
The Privacy Officer will respond to your complaint within 30 days of its receipt.
In the event that the Privacy Officer is unable to resolve your complaint, you may lodge a Privacy Complaint with the Australian Information Commissioner. For more information, please visit the Australian Information Commissioner's website.
If you have a complaint about a breach of the GDPR, you may contact the local regulator in your European Economic Area.
We are committed to helping you have control of your personal information and so it is our practice to take reasonable steps to notify you if we are aware that we have breached your privacy.
In accordance with the Notifiable Data Breaches Scheme, if your personal information is involved in a data breach that is likely to result in serious harm to you, we will notify you and the Australian Information Commissioner.
Unless required earlier, this Policy is reviewed and updated annually by the Privacy Officer, and it will be submitted to the Insignia Financial Ltd Board for approval at least triennially.
Material amendments to this Policy must be approved by the Insignia Financial Ltd Board. Non-material amendments to the Policy may be approved by the Chief Executive Officer.
The most current version of the Policy can be obtained from our website at www.ioof.com.au/privacy.
Questions about this policy should be directed to the Privacy Officer or to our ClientFirst team. Refer to section 4 of this Policy for contact details.
an Act of the Commonwealth or of a State or Territory or regulations, or any other instrument, made under such an Act.
Australian Privacy Principles or APPs
the Australian Privacy Principles set out in Schedule 1 of the Privacy Act.
an act or practice which is contrary to or inconsistent with the Privacy Act, including any of the APPs.
to collect personal information, usually for inclusion in a record.
express consent or implied consent.
personal information about the health of an individual, an individual’s expressed wishes about the future provision of health services to the individual, or a health service to be provided to an individual.
possession or control of a record that contains personal information.
a natural person.
Know Your Customer or KYC
the process of verifying a customer’s identity (as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)) by using reliable and independent documents and information.
the scheme under Part IIIC of the Privacy Act which requires that, in the event personal information is involved in a data breach that is likely to result in serious harm, we must notify each affected individual and the Australian Information Commissioner.
a person who receives personal information who is not in Australia or an external Territory, not us or a subsidiary or associate of us, and not the individual to whom the personal information relates.
information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.
the Privacy Act 1988 (Cth).
the Insignia Financial group privacy officer, responsible for managing the business impacts of privacy laws and policies across the Insignia Financial group. Refer to section 4 of this Policy for contact details.
the actions or efforts we undertake to comply with the Privacy Act and the APPs, which must be objectively reasonable in the circumstances.
personal information about an individual’s:
to request personal information, or anything that includes personal information, from someone other than the individual.
Tax file number or TFN
a tax file number as defined in Part VA of the Income Tax Assessment Act 1936 (Cth).
to handle, manage, or undertake an activity with personal information in our effective control.