We are committed to being open about how we use personal information. When requesting personal information, we will generally state the purposes for its use and to whom it may be disclosed.
Why does SFR Property collect personal information?
Our business is to understand and meet our clients’ needs over their lifetime for a wide range of financial services. To do this effectively, we need to collect certain personal information. Collecting personal information also allows us to meet legal and regulatory obligations we might have.
What kind of personal information do we ask for?
In line with the nature of the services provided, government regulations and taxation laws, we ask for a range of personal information from our clients. The type of personal information we may collect can include (but is not limited to) name, address, date of birth, contact details, income, assets and liabilities, account balances, tax and financial statements and employment details.
How do we collect personal information?
We obtain most of the information directly from our clients through application or other forms, and from maintaining records of information provided in the course of ongoing financial planning advice or client service. We may also obtain information from other sources. You have a right to refuse us authorisation to collect information from a third party.
We don’t usually collect unsolicited personal information. Where we receive unsolicited personal information, we’ll determine whether or not it would have been permissible to collect that personal information if it had been solicited. If we determine that collection would not have been permissible, to the extent permitted by law, we’ll destroy or de‐identify that personal information as soon as practicable.
We may ask for other information voluntarily from time to time (for example, through market research, surveys or special offers) to enable us to improve our service or consider the wider needs of our clients or potential clients. If, at any time, you do not wish to receive this information any further, you may contact us with this request. You will be given the opportunity to “opt out” from receiving communications from us or from third parties that send communications to you. You may “opt out” from receiving these communications, such as newsletters, emails and other marketing and promotional materials, by clicking on an unsubscribe link at the end of an email. We maintain details of the source of your personal information used for direct marketing and you have the right to request these details. We will endeavour to meet your request within 2 weeks. We maintain a Register for those individuals not wanting direct marketing material.
Am I required to provide personal information?
As a financial services organisation it is in our duty to act in the best interests of our clients in relation to the advice and are subjected to certain legislative and regulatory requirements which necessitate us to obtain personal information about you, including s 961B of the Corporations Act. If you provide inaccurate or incomplete information we may not be able to provide you with the products or services you are seeking.
You can deal with us anonymously or by using a pseudonym where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.
How do we use this information and to whom may we disclose it?
Unless you are informed otherwise, the personal information we hold is used for establishing and managing your financial products or services, reviewing your ongoing needs, enhancing client service and product options and giving you ongoing information or opportunities that we believe may be relevant to your financial needs and other circumstances.
Your personal information will not be provided to any external organisation without your written authorisation. Generally, we require external organisations that handle or obtain personal information as service providers to SFR Property, to acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with the National Privacy Principles and this policy.
In line with modern business practices common to many financial institutions and to meet your specific needs we may disclose your personal information to fund managers, compliance consultants, your accountant or solicitor as authorised by you, IT provider, another Authorised Representative of the Licensee and a potential purchaser of the business.
As an FPA Professional Practice, we are required to meet a level of professional standards set by the Financial Planning Association of Australia. From time to time, we may need to provide the Association with access to your personal information to ensure that we are meeting our compliance requirements.
The Corporations Act 2001 has provided the Australian Securities and Investments Commission with the authority to inspect certain personal information that is kept on our files about you.
In the event of that we propose to sell the business, we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. 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.
What extra restrictions apply to sensitive information?
Sensitive information relates to a person’s racial or ethnic origin, membership of political bodies, religions or trade unions, sexual preferences or activities, criminal record, state of health and medical history. Law also restricts the way we use individual information from credit reporting agencies and government identifiers, such as tax file numbers, Medicare number or pension card number. We do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party. We may only use sensitive information about you for direct marketing once we have obtained your consent.
Sensitive information is usually needed for applications for death, sickness and disability insurance and to manage claims on those products. It may also be relevant to credit and other applications. Sensitive information will be used and disclosed only for the purposes for which it was provided, unless the client agrees otherwise or law allows or requires the use or disclosure of this information. Documents asking for sensitive information will explain this.
Personal information will be treated as confidential information and sensitive information will be treated highly confidential.
Management of personal information
SFR Property trains its staff to respect the confidentiality of client information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties.
How do we store personal information?
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the Internet or other electronic medium. We hold personal information in a combination of secure computer storage facilities and paper‐based files and other records, and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.
It is a legislative requirement that we keep all personal information and records for a period of 7 years. Should you cease to be a client of ours, we will maintain your personal information on or off site in a secure manner for 7 years. After this, the information will be destroyed.
How do we keep personal information accurate and up‐to‐date?
SFRP endeavours to ensure that the personal information we hold is accurate and up‐to‐date. We realise that this information changes frequently with personal circumstances. We can generally update your client information over the telephone, in writing or in person.
Under the Commonwealth Privacy Act, you have the right to obtain a copy of any personal information about you and to advise us of any perceived inaccuracy. The Act does set out some exceptions to this. To make a request, you will need to complete an application form verifying your identity and specifying what information you require. We will acknowledge your request within 14 days and respond promptly to it. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.
Some exceptions exist where 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 is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
- providing access would be unlawful;
- denying access is required or authorised by or under law;
- an enforcement body requests that access not be provided on the grounds of national security.
Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal. We also collect information about you for the purpose of reporting to AUSTRAC under the Anti‐Money Laundering and Counter Terrorism Act 2006.
Some of the recipients to whom SFR Property Pty Ltd discloses your personal information may be based overseas. It is not practicable to list every country in which such recipients are located but it is likely that such countries will include USA. If this occurs we will obtain your specific consent before such information is sent overseas.
What if you have a complaint?
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