OUR COMMITMENT |
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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 o 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.
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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: |
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Employment details and employment history |
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Details of your financial needs and objectives |
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Details of your current financial circumstances, including your
assets and liabilities (both actual and potential), income, expenditure,
insurance cover and superannuation |
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Details of your investment preferences and aversion or tolerance
to risk |
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Information about your employment history, employment circumstances,
family commitments and social security eligibility |
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Details of the members of your family |
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Health details about yourself and the members of your family |
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Details of your existing life insurance |
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Details in regard to your estate planning |
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Details of any Centrelink or Veteran's Affairs benefits |
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Details of your tax file number when we place investments on
your behalf |
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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:
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The preparation of your financial plan |
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The provision of financial planning advice to you |
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Making securities and investment recommendations |
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Reviewing your financial plan |
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Reviewing securities and investment recommendations |
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Providing investment consultancy services to you |
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USE AND DISCLOSURE |
We will not use or disclose Personal Information collected by us for
any purpose other than: |
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The purposes for which it was provided or secondary
related purposes in circumstances where you would reasonably expect
such use or disclosure; |
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Where you have consented to such disclosure; or |
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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. |
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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:
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Preparation of a financial plan |
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Monitoring of compliance to legislation |
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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.
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SECURITY |
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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.
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ACCESS AND CORRECTION |
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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:
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Providing access would pose a serious threat to
the life or health of a person |
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Providing access would have an unreasonable impact on the privacy
of others |
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The request for access is frivolous or vexatious |
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The information related to existing or anticipated legal proceedings
between us and would not be discoverable in those proceedings |
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Providing access would reveal our intentions in relation to
negotiations with you in such a way as to prejudice those negotiations
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Providing access would be unlawful |
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Denying access is required or authorised by or under law |
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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 |
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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.
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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.
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ONLINE ENVIRONMENT |
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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:
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Your name, phone / fax numbers and e-mail address
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Your occupation |
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Your age group |
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Your income range |
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Whether or not you have a financial planner |
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Whether you would like one of our planners to contact you |
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Whether your primary interest is managed funds or shares |
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How you heard about us |
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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.
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CONTACT DETAILS |
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