The collection of personal information about individuals by organisations is governed by the Privacy Act 1988 (the Privacy Act) which contains the Australian Privacy Principles (APPs) for the collection, use, correction, disclosure and transfer of personal information.
Note: A public register of Financial Advisers is available at the website www.moneysmart.gov.au/toolsand-resources/check-asic-lists/check-a-financial-adviser. The register includes details of any persons controlling a corporate financial services licencee.
Apt Wealth Partners is a business which is privately owned by financial advisers who operate under the licence. We do not have any ownership or licensing ties to product providers.
The Policy explains our policies and practices with respect to the collection and management of your personal information.
The Privacy Act 1988 requires us to handle your personal information in accordance with the APPs. Our approach to the APPs is set out below.
The Policy applies to Apt Wealth Partners Pty Ltd and all of its wholly-owned subsidiaries and related entities, together referred to in this Policy as ‘Apt’, ‘us’, ‘our’, or ‘we’.
What information do we collect?
We will only collect your personal information by lawful and fair means. We will collect and hold your personal information for the purposes of:
- Providing products and services to you
- Managing and administering the products and services
- Letting you know about our other products and services.
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 the following personal information:
- Email address
- Residential and/or postal address
- Date of birth
- Contact details
- Bank account details
- Financial details
- Tax file number (TFN).
This information is collected through application forms, the use of our online facilities or through ongoing communications with you.
We will only collect your personal information where reasonably necessary for one or more of our functions or activities. We will not collect any personal information about you except where you have knowingly provided that information to us or we believe you have authorised a third party to provide that information to us or it is otherwise unreasonable or impracticable for us to collect it from you.
There are also specific circumstances in which we will ask for additional sensitive information such as:
- Personal health information from medical practitioners when you are making an insurance claim
- Income information from employers in instances where you are applying for additional insurance protection or salary continuance insurance
- Details of your dependents for the purposes of paying benefits in the event of your death.
We will seek your consent before collecting this kind of sensitive information unless the APPs otherwise permit.
We may also need to collect information from third parties. For example, we may need to collect information from your financial adviser, another product issuer and employer.
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. In addition to obtaining personal information from you, whenever you acquire a new product or service from us, we will need to obtain certain documentary evidence from you as to your identity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. Such evidence may include items such as a certified copy of your driver’s licence, passport or birth certificate.
What if you don’t give us the information we request?
You are not required 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:
- Prevent or delay the processing of your application, the implementation of your instructions or any insurance claim
- Affect your eligibility for insurance cover
- Prevent us from contacting you
- Impact on the taxation treatment of your account.
For example, when you become a member of a superannuation product, if you choose not to give us your TFN for passing on to the provider of the product, you may be subject to higher tax charges on your superannuation and the provider may not be able to accept personal contributions.
3 Use of information
How do we use the information that we collect from you?
We use personal information about an individual for the purposes for which it has been obtained. We collect personal information so that we are able to complete one or more of the following activities:
- Provide financial advice to you
- Establish and manage your investments and accounts
- Implement your investment instructions
- Establish and maintain insurance protection
- Process contributions, transfer monies or pay benefits
- Report the investment performance of your account
- Keep you up-to-date on other products and services offered by us.
Personal information will also be used where you have consented to such use or where it is permitted under the APPs. For example, where you would reasonably expect that usage, or in permitted health situations, or in connection with certain operations by or on behalf of an enforcement body.
Who do we give information to?
We may provide your information to other related companies within the Apt Wealth Partners group or external parties. Where personal information is disclosed there are 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 often disclose your personal information are:
- Any organisations involved in providing, managing or administering our products or services such as actuaries, custodians, external dispute resolution services, insurers, investment managers or mailhouses
- Your financial adviser
- Your employer (relates only to employer sponsored superannuation arrangements)
- Any fund (administrator or trustee) to which your superannuation benefit is to be transferred or rolled over
- Medical practitioners and other relevant professionals, where you have applied for insurance cover or made a claim for disablement benefit
- Your personal representative, or any other person who may be entitled to receive your death benefit or any person contacted to assist us to process that benefit
- Any financial institution who holds an account for you
- Any professional advisers or successors to our business appointed by us
- Businesses that may have referred you to us (for example your credit union)
- The Office of the Australian Information Commissioner (OAIC) as required by law.
Like other financial services providers, there are situations where we may also disclose your personal information where 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)
- Required to assist in law enforcement (such as to a police force)
- Required to be reported to the Office of the Information Commissioner (IAIC) under the Notifiable Data Breach (NDB) Scheme.
We will also disclose your information if you give your consent.
5 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. 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 and how you may complain about our decision.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete, relevant and up to date. You have a right to ask us to correct any information we hold about you if you believe it is not accurate, complete, relevant or up-to-date. If we do not agree with the corrections you have supplied, we are not required to alter the information but will provide you with the reasons why and how you may complain about our decision.
If you wish to access your personal information, you should contact us through our offices or by writing to the Privacy Officer. Details of how to contact the Privacy Officer are set out below.
If you have a concern about the privacy of your information, you may lodge a complaint with us by writing to the Privacy Officer. Refer to Privacy Officer contact details below.
You may also be able to complain to a recognised external dispute resolution scheme of which we are a member. If we have not been able to resolve your complaint within a reasonable time, we will provide you with the contact details of any such scheme.
At present, we are a member of the Australian Financial Complaints Authority (t: 1800 931 678, e: firstname.lastname@example.org).
If your complaint is still not resolved, you may lodge a complaint with the Office of the Australian Information Commissioner. You can contact the Office of the Australian Information Commissioner by:
- Calling the hotline on 1300 363 992
- Visiting the web site www.oaic.gov.au
- Submitting an online form: https://forms.australia.gov.au/forms/oaic/privacy-complaint/
Note: On 1 November 2010 the Office of the Privacy Commissioner was integrated into the Office of the Australian Information Commissioner (OAIC).
7 Protection of personal and sensitive information
How do we protect your information?
We have security systems, practices and procedures in place to safeguard your privacy. The people who handle your personal information for us have the training, knowledge, skills and commitment to protect it from unauthorised access or misuse.
If you use the secure adviser, member or employer sections of our websites, we will verify your identity by your username and password. Once verified, you will have access to secured content.
If we no longer need your personal information, we will destroy it or de-identify it.
Third party providers
Apt Wealth Partners engages third parties to provide services on behalf of the Australian Financial Services Licence. Apt Wealth Partners uses software, systems, technology and products supplied by third parties (whether disclosed or not). This includes information management systems (Salesforce), portfolio management systems (WealthConnect by CreativeMass) and other online information access systems.
Your information is maintained on their servers which may be based in Australia and/or overseas. The use of this information is governed by the terms of our business agreement with them and complies with our requirements for the protection of your information under the Privacy Act.
Risks of using the internet
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 Customer Service team.
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Contact the Privacy Officer:
Apt Wealth Partners Pty Ltd
PO Box Q414, QVB Post Office
Sydney NSW 1230
Version: 1 July 2020