This policy applies to VWM Financial Services Pty Ltd, its associated and related entities, and all its directors and representatives (we, our or us). It explains our policy in relation to the collection and management of personal information we collect from individuals. The Privacy Act 1988 requires us to handle personal information in accordance with the Australian Privacy Principles (APP).
In addition, Item 6 of the Code of Professional Conduct under the Tax Agent Services Act 2009 (section 30-10) prohibits us from disclosing any information relating to your affairs to a third party without your prior permission.
Collection of information – What is collected and why we collect it.
Personal information means information, or an opinion about, an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. We are an Australian Financial Services Licensee (AFSL). When we provide you with financial services we may be required by Corporations Act 2001 and regulatory requirements to seek to obtain certain personal information about you, including, but not limited to, your:
- Name, date of birth, contact details and tax file number.
- Employment details and employment history.
- Financial details, including your needs and objectives.
- Details of your investment preferences and attitude or tolerance to investment and financial risk.
- Information about your employment history, employment circumstances, family commitments and social security eligibility.
We may also need to collect sensitive information if we organise insurance covers for you. Sensitive information includes health information, racial information, genetic information, etc.
We will only collect sensitive information that is reasonably necessary for us to perform our functions or activities in advising you and dealing with you.
How is information collected?
We collect personal and sensitive information in a number of ways, including:
- Directly from you such as when you provide the information at meetings, by phone, email, in data collection forms and when you visit our website or from other parties with whom you instruct us to deal on your behalf.
- Our website may use “cookies”. Cookies are small data files that are downloaded from our website and stored on your computer when you visit our website. Cookies are used to allow us to see which pages and what information is of most interest to visitors to our website, which in turn enables us to improve our offerings to our customers. Your computer’s web browser will allow you to configure your computer to refuse to accept cookies. You can also delete cookies from your computer’s hard drive at any time. However, please note that doing so may hinder your access to valuable areas of information within our site.
- Indirectly from fund managers, superannuation funds, life insurance companies and other product issuers once you have authorised us to obtain such information or authorised other parties to provide us with this information.
Are you obliged to provide us personal information?
You are not required to provide us the information that we request, or to allow us to collect information from third parties. However, where you choose not to provide us with the information we request, we may not be able to provide you with services that you have requested from us, and we may elect to terminate any arrangements we may have with you. Importantly, if you provide either inaccurate or incomplete information to us you risk obtaining products or services that may not be appropriate or suitable for your needs and you may risk suffering a financial detriment or financial loss.
What happens if we obtain information about you which we have not solicited?
Where we receive unsolicited personal information about you, we will consider if we could have collected the information if we had solicited the information. Where we determine that we could have collected the personal information from you, we will treat your personal information in the same manner as if we have solicited the information directly from you. Where we determine that we could not have collected the personal information, we will destroy the information or ensure that the information is de-identified as soon as practicable.
Use of information
We use your personal information for the primary purpose for which the information was obtained; i.e. for the provision of financial services. As an AFS licensee, that will typically mean for the purpose of:
- Providing financial services and tax (financial) services to you.
- Implementing investment or risk management recommendations on your behalf.
We may also use the information for the secondary purpose of:
- Attempting to identify other products and services that may be of interest to you.
- Conducting any professional quality control review program.
- Managing our business operations such as maintaining secure IT systems
Do we disclose personal information for marketing?
We may use your personal information to offer you products and services that we believe may interest you. We may also disclose your personal information to external associates and service providers who assist us to offer you our products and services.
If you do not want to receive marketing offers from us please inform us by sending an email to email@example.com or calling 08 9215 5000.
Disclosure of information
With your permission, we may disclose your personal information to:
- Our representatives.
- The product issuers of products and services that you have elected to acquire, vary or dispose of using our assistance.
- Parties who we think are necessary or convenient to allow us to provide financial services to you.
- Prospective entities interested in acquiring all or part of our business.
For example, information may be disclosed to the following parties:
- Product issuers and credit providers for the purpose of giving effect to the recommendations made by us, and other organisations who support the products and services we offer.
- Other parties involved in the administration of your financial products or insurance cover (e.g. custodians, brokers, actuaries, call centres, mail houses, product registries, any persons who propose to guarantee (or have guaranteed) repayment of any credit provided to you, claims assessors etc.).
- Our external service providers (e.g. IT providers, professional advisers and contractors).
- Government and regulatory authorities and other organisations, as required or authorised by law.
- Any person considering acquiring, or acquiring, an interest in our business.
Government related identifiers
Although in certain circumstances we are required to collect government identifiers such as your tax file number, Medicare number or pension card number, we do not use or disclose this information other than when required, authorised by law or unless you have voluntarily consented to disclose this information to any third party.
Cross-border disclosure of personal information
We may transfer personal information to related bodies corporate or external service providers in locations outside Australia, including, but not limited to, India, United States, China, Poland, Philippines, in the course of storing that information and when using or disclosing it for one of the purposes referred to above. When transferring personal information to foreign jurisdictions, we will ensure that we satisfy one of the requirements below:
Storage and security of information
We store personal information in our computer database and hard copy work-in-progress files. We take reasonable steps to ensure the personal information collected and held by us is protected from misuse, interference, loss, unauthorised access, modification or disclosure.
In the event you cease to be a client of ours, any personal information which we hold about you will be maintained for a period of not less than 7 years to comply with legislative and professional requirements.
Notifiable data breaches
We are required to notify you and the Information Commissioner of an eligible data breach. An eligible data breach happens if:
- there is unauthorised access to, unauthorised disclosure of, or loss of personal information held by us; and
- the access, disclosure or loss is likely to result in serious harm to you.
If you receive a statement of an eligible data breach from us, you should read and implement the recommendations about the steps you should take in response to the eligible data breach.
Access and correction of information
You may request access to the personal information we hold about you, and we will respond within a reasonable period after the request is made. Where we provide you access to such information, we may charge a reasonable fee to cover our costs. We will disclose the amount of such costs to you prior to providing you with the information.
We will take reasonable steps to ensure that the personal information that we collect, use or disclose is accurate, up-to-date, complete and relevant. In the event that you become aware, or believe, that any personal information which we hold about you is inaccurate or incomplete, you may contact us to correct the information.
If we disagree about the correction you have supplied, and refuse to correct the personal information, or if we believe that we are unable to comply with your request to access the personal information that you have provided us, we will give you a written notice to that effect. You have a right to make a complaint if you disagree with our decisions in relation to these matters (see below).
Your complaint will be investigated and responded to within 45 days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Australian Information Commissioner.
Privacy Officer: Ben Devenish
Address: Level 1, 7 Havelock Street West Perth WA 6005
Postal Address: GPO Box 2521 Perth WA 6001
Telephone: 08 9215 5000
Facsimile: 08 9215 5011