Accrd Grup (WA) Pty Ltd CERTIFIED PRACTISING ACCOUNTANTS ABN: 96 210 970 944 William Murray Huse 92 Wray Avenue FREMANTLE WA 6160 PO Bx 236 FREMANTLE WA 695 Email: accrdwa@accrdwa.cm.au Telephne: (08) 9430 5559 Facsimile: (08) 9336 1192 Accrd Grup Privacy Plicy Versin: 2 Date Published: February 2016 Authr: Accrd Grup (WA) Pty Ltd
Cntents 1. Intrductin...1 2. What kind f persnal infrmatin d we cllect and hld?...1 3. Hw we cllect persnal infrmatin...2 4. Unslicited persnal infrmatin...3 5. Abut whm d we cllect persnal infrmatin?...3 6. Website cllectin...3 7. Why d we cllect and hld persnal infrmatin?...3 8. Hw might we use and disclse persnal infrmatin?...4 9. T whm might we disclse persnal infrmatin?...4 10. Hw might we use and disclse credit infrmatin?...5 11. Sending infrmatin verseas...6 12. Management f persnal infrmatin...6 13. Direct marketing...7 14. Identifiers...7 15. Hw d we keep persnal infrmatin accurate and up-t-date?...8 16. Yu have the ability t gain access t yur persnal infrmatin...8 17. Updates t this plicy...8 18. Respnsibilities...8 19. Privacy training...9 20. Nn-cmpliance and disciplinary actins...9 21. Cntractual arrangements with third parties...9 22. Privacy audits... 10 23. Inquiries and cmplaint handling... 11 24. What if I am nt satisfied with the respnse?...12
1. Intrductin Accrd Grup is cmmitted t ensuring the cnfidentiality and security f yur persnal infrmatin, including yur sensitive and credit infrmatin. This Privacy Plicy applies t Accrd Grup (WA) Pty Ltd and any f its related entities (referred t as Accrd Grup, we, ur, us ) and cvers all f the crprate grup s peratins and functins. All third parties (including clients, suppliers, sub-cntractrs, r agents) that have access t r use persnal infrmatin cllected and held by Accrd Grup must cmply with this Privacy Plicy. Accrd Grup makes this Plicy available free f charge and can be dwnladed frm www.accrdwa.cm.au. This Plicy utlines Accrd Grup s bligatins t manage and prtect persnal infrmatin. Accrd Grup is bund by the Australian Privacy Principles ('APPs'), the Credit Reprting Privacy Cde ( the Cde ) and the Privacy Act 1988 ('Privacy Act'). This Plicy als utlines Accrd Grup s practices and prcedures that ensure cmpliance with the Privacy Act, APPs and the Cde. In this Privacy Plicy: Credit infrmatin includes infrmatin that we have btained frm Third Parties, including individuals, credit prviders and credit reprting bdies ( CRBs ); Disclsing infrmatin means prviding infrmatin t persns utside Accrd Grup; Individual means any persn whse persnal infrmatin we cllect, use r disclse. Persnal infrmatin means infrmatin r an pinin relating t an individual, which can be used t identify that individual; Privacy Officer means the cntact persn within Accrd Grup fr questins and cmplaints regarding Accrd Grup s handling f persnal infrmatin; Sensitive infrmatin is persnal infrmatin that includes infrmatin relating t a persn's racial r ethnic rigin, plitical pinins, religin, trade unin r ther prfessinal r trade assciatin membership, sexual preferences and criminal recrd, and als includes health infrmatin; Use f infrmatin means use f infrmatin within Accrd Grup. 2. What kind f persnal infrmatin d we cllect and hld? Accrd Grup is required under varius legislatin and cdes f practice t cllect certain infrmatin in rder t prvider ur range f wealth management, financial planning, stckbrking, lending and persnal risk services. We may cllect and hld the fllwing kinds f persnal infrmatin abut individuals: persnal details, including name, address, cntact details, date f birth, marital status, dependents and emplyment details; details f investments including amunts invested, investr numbers and bank accunt details;
persnal gals, bjectives and risk prfiles; insurance plicy details, including life, trauma, incme prtectin and general insurance; estate planning details, including status f wills, executrs, beneficiaries and pwers f attrney; taxatin infrmatin including tax file numbers; Centrelink details, including benefit types and reference number; health infrmatin, including current health cnditins, smker status and medical histry; sexual rientatin and histry fr insurance applicatin purpses; prfessinal/trade memberships, plitical beliefs and ethnic rigins; financial and credit infrmatin, including: assets, liabilities, incme and expenses; infrmatin abut an individual s cnsumer credit liabilities; infrmatin abut an individual s repayment histry; the type and amunt f credit sught by an individual in an applicatin; whether the individual is 60 days r mre verdue in making a repayment f $150 r mre; whether the individual has repaid verdue payments; infrmatin abut new credit arrangements the individual has entered int as a result f defaulting in repayments; infrmatin abut curt judgements against the individual in relatin t credit; publicly available infrmatin that relates t the individual s credit wrthiness; infrmatin recrded in the Natinal Persnal Inslvency Index abut the individual; ur pinin as t whether the individual has cmmitted a serius credit infringement; any ther persnal infrmatin that may impact an assessment f the individual s credit wrthiness; and any ther infrmatin that is relevant t the services that we prvide. 3. Hw we cllect persnal infrmatin We generally cllect persnal infrmatin directly frm the individual. Fr example, persnal infrmatin will be cllected when an individual fills ut applicatin frms, meets with an advisr, visits ur website, r sends us crrespndence. Smetimes we may cllect persnal infrmatin frm a third party, such as financial institutin, a credit prvider, r a credit reprting bdy ( CRB ).
When we are prvided with persnal infrmatin frm a third party, we will take reasnable steps t ensure that the individual is made aware f the matters set ut in this Privacy Plicy. Our ability t prvide individuals with cmprehensive and quality services is reliant n us btaining certain persnal infrmatin. If individuals d nt prvide us with the infrmatin we request, we may elect t terminate ur relatinship with the individual as it may jepardise ur ability t prvide a cmplete, accurate and cmprehensive service. Accrd Grup des nt give individuals the ptin f dealing with them annymusly, r under a pseudnym. This is because it is impractical, and in sme circumstances illegal, fr Accrd Grup t deal with individuals wh are nt identified. 4. Unslicited persnal infrmatin Accrd Grup may receive unslicited persnal infrmatin abut individuals. If pssible, Accrd Grup will return the unslicited persnal infrmatin t the persn wh prvided it. In all ther cases, we destry the infrmatin, unless the persnal infrmatin is relevant t Accrd Grup s purpses fr cllecting persnal infrmatin. 5. Abut whm d we cllect persnal infrmatin? We may cllect persnal infrmatin abut the fllwing individuals: clients; ptential clients; service prviders r suppliers; prspective emplyees, emplyees and cntractrs; and ther third parties with whm we cme int cntact. 6. Website cllectin We cllect persnal infrmatin frm ur website (www.accrdwa.cm.au) when we receive emails and nline frms. We may als use third parties t analyse traffic at that website, which may invlve the use f ckies. Ckies allw us t track usage patterns s that we can measure the level f interest in varius areas f ur site. Infrmatin cllected thrugh such analysis is annymus. 7. Why d we cllect and hld persnal infrmatin?
We may cllect and hld infrmatin abut individuals fr the fllwing purpses: assisting Accrd Grup in prviding wealth management, financial planning, persnal risk, lending and stckbrking services; cmpletin f dcumentatin and applicatin frms; prvisin f ther services t assist in meeting yur requirements, gals and bjectives; t cmply with relevant laws, regulatins and ther legal bligatins, including antimney laundering legislatin managing credit r cllecting verdue payments; t prvide individuals with infrmatin abut a prduct r service and als t invite individuals t marketing events; prtectin f ur business and ther clients frm fraudulent r unlawful activity; t therwise cnduct ur business and perfrm ther management and administratin tasks; t cnsider any cncerns r cmplaints individuals may have; manage any legal actins invlving Accrd Grup; and t help us imprve the prducts and services ffered t ur clients, and t enhance ur verall business. 8. Hw might we use and disclse persnal infrmatin? Accrd Grup may use and disclse persnal infrmatin fr the primary purpses fr which it is cllected, fr reasnably expected secndary purpses which are related t the primary purpse and in ther circumstances authrised by the Privacy Act. We use and disclse persnal infrmatin (excluding credit infrmatin) fr the purpses utlined in sectin 7 abve. Sensitive infrmatin will be used and disclsed nly fr the purpse fr which it was prvided r a directly related secndary purpse, unless the individual agrees therwise, r where certain ther limited circumstances apply (e.g. if required by law). We engage ther peple t perfrm services fr us, which may invlve that persn handling persnal infrmatin we hld. In these situatins, we prhibit that persn frm using persnal infrmatin abut the individual except fr the specific purpse fr which we supply it. We prhibit that persn frm using yur infrmatin fr the purpses f direct marketing their prducts r services. In relatin t sensitive infrmatin held by us, wherever pssible, Accrd Grup will attempt t deidentify the infrmatin. We als undertake t take reasnable steps t delete all persnal infrmatin abut an individual when it is n lnger needed in accrdance with ur recrd keeping bligatins.
9. T whm might we disclse persnal infrmatin? We may disclse persnal infrmatin, excluding credit infrmatin, t: A related bdy crprate; an agent, cntractr r service prvider we engage t carry ut ur functins and activities, such as ur lawyers, accuntants, debt cllectrs r ther advisrs; rganisatins invlved in a transfer r sale f all r part f ur assets r business; rganisatins invlved in managing payments, including payment merchants and ther financial institutins such as banks; regulatry bdies, gvernment agencies, law enfrcement bdies and curts; an individual s referee(s), emplyer, r c-accunt hlder; the recipients utlined in sectin 10 belw; and anyne else t whm the individual authrises us t disclse it. If we cllect persnal infrmatin frm these rganisatins and individuals we will deal with that infrmatin in accrdance with this Plicy. 10. Hw might we use and disclse credit infrmatin? In relatin t credit infrmatin held by us, we will nly use and disclse credit infrmatin fr the fllwing purpses: assessing an individual s credit wrthiness and likelihd f apprval fr an applicatin fr credit; cllecting payments that are verdue in relatin t any credit that may be prvided by us; dealing with a serius credit infringement we believe an individual has cmmitted; assisting external dispute reslutin scheme f which we are a member; if the disclsure is required r authrised by law; assisting the individual t avid defaulting n his r her credit bligatins; r the prvisin r management f credit t an individual. We will nly disclse credit infrmatin t the fllwing recipients: a related bdy crprate;
a persn wh will be prcessing an individual s applicatin fr credit; a persn wh manages credit; a credit prvider if we believe an individual has cmmitted a serius credit infringement, r the individual has cnsented t the disclsure; t a persn cnsidering whether t act as a guarantr r ffer prperty as security and the individual have expressly cnsented t the disclsure; a debt cllectr; a mrtgage insurer; a CRB; and anyne else t whm the individual authrises us t disclse it. 11. Clud Strage f Infrmatin We use clud strage and back-up services, which may invlve the strage f yur data n services within Australia nly. Apprpriate safeguards are put in place t prtect this data. We will nt send persnal infrmatin t recipients utside f Australia unless: we have taken reasnable steps t ensure that the recipient des nt breach the Act, the APPs and the Credit Reprting Privacy Cde; the recipient is subject t an infrmatin privacy scheme similar t the Privacy Act; r the individual has cnsented t the disclsure. 12. Management f persnal infrmatin Accrd Grup recgnises hw imprtant the security f persnal infrmatin is t clients. We will at all times seek t ensure that the persnal infrmatin we cllect and hld is prtected frm misuse, lss, unauthrised access, mdificatin r disclsure. Accrd Grup emplyees must respect the cnfidentiality f the persnal infrmatin we cllect. Persnal infrmatin is generally held in client files. Infrmatin may als be held in a cmputer database. All paper files are stred in secure areas. Cmputer-based infrmatin is prtected thrugh the use f access passwrds. In relatin t ur cmputer-based infrmatin, we apply the fllwing guidelines: data wnership is clearly defined within Accrd Grup; passwrds are rutinely checked; we change emplyees access capabilities when they are assigned t a new psitin;
emplyees have restricted access t certain sectins f the system; the system autmatically lgs and reviews all unauthrised access attempts; the system autmatically limits the amunt f persnal infrmatin appearing n any ne screen; all persnal cmputers which cntain persnal infrmatin are secured, physically and electrnically; data is encrypted during transmissin ver the netwrk; print reprting f data cntaining persnal infrmatin is limited; Accrd Grup has created prcedures fr the dispsal f persnal infrmatin; and persnal infrmatin is verwritten t the extent pssible when the infrmatin is n lnger required. If a persn ceases t be a client, any persnal infrmatin we hld will be maintained in a secure area r secure ff-site strage facility fr a perid f at least 7 years in rder t cmply with legislative and prfessinal requirements, fllwing which the infrmatin will be destryed. 13. Direct marketing Accrd Grup des nt use persnal infrmatin fr the purpses f direct marketing, unless: the persnal infrmatin des nt include sensitive r credit infrmatin; the individual wuld reasnably expect us t use r disclse the infrmatin fr the purpse f direct marketing; we prvide a simple way f pting ut f direct marketing; and the individual has nt requested t pt ut f receiving direct marketing frm us. If the individual wuld nt reasnably expect us t use r disclse the infrmatin fr the purpse f direct marketing, we may nly use r disclse that infrmatin fr direct marketing if the individual has cnsented t the use r disclsure f the infrmatin fr direct marketing r it is impracticable t btain that cnsent. In relatin t sensitive infrmatin, Accrd Grup may nly use r disclse sensitive infrmatin abut an individual fr the purpse f direct marketing if the individual has cnsented t the use r disclsure f the infrmatin fr that purpse. We will nt use r disclse credit infrmatin fr the purpses f direct marketing. Individuals have the right t request t pt ut f direct marketing and we must give effect t the request within a reasnable perid f time. Individuals may als request that Accrd Grup prvides them with the surce f their infrmatin. If such a request is made, Accrd Grup must ntify the individual f the surce f the infrmatin free f charge within a reasnable perid f time.
14. Identifiers We will nt use identifiers assigned by the Gvernment, such as a tax file number, Medicare number r prvider number, fr ur wn file recrding purpses. Accrd Grup als endeavurs t avid data-matching. 15. Hw d we keep persnal infrmatin accurate and up-t-date? Accrd Grup is cmmitted t ensuring that the persnal infrmatin, including credit infrmatin, it cllects, uses and disclses is relevant, accurate, cmplete and up-t-date. We encurage individuals t cntact us in rder t update any persnal infrmatin we hld abut them. If we crrect infrmatin that has previusly been disclsed t anther entity, we will ntify the ther entity within a reasnable perid f the crrectin. Where we are satisfied infrmatin is inaccurate, we will take reasnable steps t crrect the infrmatin within 30 days, unless the individual agrees therwise. We d nt charge individuals fr crrecting the infrmatin. 16. Yu have the ability t gain access t yur persnal infrmatin Subject t the exceptins set ut in the Privacy Act, individuals may gain access t the persnal infrmatin, including credit infrmatin, which Accrd Grup hlds abut them by cntacting the Accrd Grup Privacy Officer. We will prvide access within 30 days f the individual s request. If we refuse t prvide access, we will prvide reasns fr the refusal. We may prvide cpies f the infrmatin requested, allw the individual t inspect the infrmatin at ur ffices, r prvide an accurate summary f the infrmatin held. We will require identity verificatin and specificatin f what infrmatin is required. An administrative fee fr search and phtcpying csts may be charged fr prviding access. 17. Updates t this plicy This Plicy will be updated frm time t time t take accunt f new laws and technlgy, and changes t ur peratins and the business envirnment. 18. Respnsibilities
It is the respnsibility f management t infrm emplyees and ther relevant parties that the Privacy Plicy is maintained and enfrced. Management must ensure that they peridically advise Accrd Grup s emplyees and ther relevant third parties f any changes t the Privacy Plicy. It is the respnsibility f all emplyees and ther relevant third parties t ensure that they understand and cmply with this Privacy Plicy. Ignrance f the Privacy Plicy will nt be an acceptable excuse fr nn-cmpliance. 19. Privacy training All new emplyees are prvided with timely and apprpriate access t Accrd Grup s Privacy Plicy and infrmatin which cvers Accrd Grup s bligatins under the Act, the APPs and the Cde. Emplyees must ensure that they understand the privacy issues that culd affect Accrd Grup and its clients. 20. Nn-cmpliance and disciplinary actins Privacy breaches must be immediately reprted t management by emplyees and relevant Third Parties. Emplyees r ther relevant Third Parties that d nt cmply with Accrd Grup s Privacy Plicy may be subject t disciplinary actin. 21. Cntractual arrangements with third parties Accrd Grup must ensure that all cntractual arrangements with third parties adequately address privacy issues. Accrd Grup will make relevant third parties aware f this Privacy Plicy. Third parties will be required t implement plicies t ensure they cmply with the Privacy Act, the APPs and the Cde, including: regulating the cllectin, use and disclsure f persnal and sensitive infrmatin; de-identifying persnal infrmatin wherever pssible; ensuring that persnal infrmatin is kept securely, with access t it nly by authrised emplyees r agents f the third parties; and ensuring that the persnal infrmatin is nly disclsed t rganisatins which are apprved by Accrd Grup.
22. Privacy audits Accrd Grup will cnduct peridic privacy audits in rder t ensure that it is cntinuing t cmply with its bligatins under the APPs. 23. Inquiries and cmplaints handling If yu have any questins abut ur privacy prcedures r if wish t make a cmplaint abut hw we have dealt with yur persnal infrmatin (including credit infrmatin) yu may ldge a cmplaint with us in any f the fllwing ways: by telephning 9430 5559 by writing t Privacy Officer, Accrd Grup (WA) Pty Ltd by emailing accrdwa@accrdwa.cm.au Accrd Grup has an effective cmplaints handling prcess in place t manage privacy risks and issues. Firstly, please cntact yur advisr at Accrd Grup r the Directr t discuss yur cmplaint. We strive t imprve the services we ffer and rely n feedback frm yu t help us in this regard. Secndly, if yu are nt satisfied with the respnse yu receive yu shuld cntact the Privacy Officer. With regard t Financial Services prvided by Accrd Grup Financial Services Pty Ltd, the fllwing is applicable: Cntact yur Adviser and tell them abut yur cmplaint If yur cmplaint is nt satisfactrily reslved within 5 wrking days, please cntact Wealthsure s cmpliance Manager by telephne r in writing. Wealthsure will try t reslve yur cmplaint quickly and fairly. If yu d nt get a satisfactry utcme, yu have the right t escalate yur cmplaint t the Credit & Investment Ombudsman GPO Bx 3, Melburne Vic 3000, telephne tll free 1300 780 808. Wealthsure is a member f this service. Telephne 08 9267 3444. 24. What if I am nt satisfied with the respnse? If yu are nt satisfied with the result f yur cmplaint t Accrd Grup yu can als refer yur cmplaint t the Office f the Australian Infrmatin Cmmissiner. Yu can cntact the Office f the Australian Infrmatin Cmmissiner:
by telephning - 1300 363 992 by writing t - Directr f Cmplaints, Office f the Australian Infrmatin Cmmissiner, GPO Bx 5218, SYDNEY NSW 2001 by emailing - enquiries@aic.gv.au Cntact Us Accrd Grup (WA) Pty Ltd William Murray Huse 92 Wray Avenue Fremantle WA 6160 Australia PO Bx 236 Fremantle WA 6959 Australia Tel 9430 5559 www.accrdwa.cm.au