Updated August 2015
About this policy
Accru Melbourne provides financial planning advice to clients through Accru Wealth Management, which holds its own Australian Financial Services License. The information set out below provides an overview of how Accru Wealth Management will protect your privacy and manage your personal information.
When you trust us with your personal information, we are committed to respecting your privacy, and protecting it.
We are bound by the Privacy Act 1988 (Cth) (‘Privacy Act’) and will protect your personal information in accordance with the Australian Privacy Principles. These principles govern how we can collect, use, hold and disclose your personal information, as well as ensure the quality and security of your personal information.
What is personal information?
Personal information includes any information or opinion, about an identified individual or an individual who can be reasonably identified from their information. The information or opinion will still be personal information whether it is true or not and regardless of whether we have kept a record of it.
The information that we seek to collect about you will depend on the products or services that we provide.
Failure to provide full personal information may expose you to higher risks in respect of the recommendations made to you, and may affect the adequacy or appropriateness of advice we provide to you. Where you provide us with limited information because you have scaled the services you require from us, we will make you aware of any associated risks in doing so.
As we are required pursuant of the Corporations Act to collect sufficient information to ensure appropriate advice can be given, if you elect not to provide us with the personal information we need, we may not be able assist you in providing the products, services or advice you have requested.
What kinds of personal information do we collect and hold?
When you apply for our products or services we may ask for identification information. This could include your name, address, contact details, date of birth, financial situation and assets and liabilities.
Depending on the service we may collect your tax file number if we are authorised to collect it and if you choose to supply it.
If applying for insurance, subject to the type of insurance applied for, we may collect information about what is being insured, the beneficiaries, and your health and financial situation.
Throughout the life of your product or service, we may collect and hold additional personal information about you. This could include transaction information or creating a record of queries or complaints you make. If you were to make an insurance claim, we may collect and hold additional information to assess the claim.
The collection of sensitive information is restricted by the Privacy Act. This includes information about your religion, racial or ethnic origin, political opinions, criminal record, and sexual orientation. It also includes health information and biometric information.
Generally, we only collect this sort of information if it is necessary to provide you with a specific product or service and you have consented to that collection. For example, we may collect health information about you to process a claim under an insurance policy or collect voice biometric information to verify your identity or authorise transactions.
For what purposes do we collect, hold, use and disclose personal information?
The main reason we collect, use, hold and disclose personal information is to provide you with products and services. This includes:
+ checking whether you are eligible for the product or service;
+ assisting you where online applications are not completed;
+ providing the product or service; and
+ managing the product or service.
We may also use your information to comply with legislative or regulatory requirements in any jurisdiction, prevent fraud, crime or other activity that may cause harm in relation to our products or services and to help us run our business.
We may also use your information to internally help us improve our services for you.
How do we collect personal information?
We collect most personal information directly from you. For example, we will collect your personal information when you apply for or use a product or service or talk to us in person or on the phone.
We also collect information from you electronically. For instance, when you visit our website or if you send us electronic correspondence (see “Do we collect personal information electronically?”).
Sometimes we collect personal information about you from other people or organisations. This may happen without your direct involvement. For instance, we may collect personal information about you from:
+ publicly available sources of information, such as public registers;
+ your representatives (including your legal adviser, mortgage broker, executor, administrator, guardian, trustee, or attorney);
+ your employer;
+ other organisations, who jointly with us, provide products or services to you;
+ commercial information service providers, such as companies that provide fraud prevention reports; and
+ insurers, re-insurers and health care providers.
What laws require or authorise us to collect personal information?
We are required or authorised to collect:
+ certain identification information about you by the Anti-Money Laundering and Counter- Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1);
+ your Tax File Number, if you choose to provide it, by the Income Tax Assessment Act 1936 (Cth); and
+ certain information in relation to your application if you have applied for an insurance as required by the Insurance Contracts Act 1984 (Cth).
How do we hold personal information?
Much of the information we hold about you will be stored electronically in secure data centres which are owned by either Accru Wealth Management or by external service providers bound by the Australian Privacy Principles. Some information we hold about you will be stored in paper files. We use a range of physical and electronic security measures to protect the security of the personal information we hold. For example:
+ access to information systems is controlled through identity and access management;
+ employees are bound by internal information security policies and are required to keep information secure;
+ all employees are required to complete training about information security; and
+ we regularly monitor and review our compliance with internal policies and industry best practice.
+ We take reasonable steps to destroy or permanently de-identify any personal information after it can no longer be used.
Who do we disclose your personal information to, and why?
We may provide personal information about our clients to organisations outside the Accru Wealth Management. To protect personal information, we ensure our service providers comply with the Privacy Act. We only authorise our service providers to use or disclose your personal information for the specific role we ask them to perform.
Generally, we disclose personal information to organisations that help us with our business. These may include:
+ our agents, contractors and external service providers (for example, mailing houses and technology service providers);
+ paraplanning service providers;
+ insurers, re-insurers and health care providers;
+ payment systems operators (for example, merchants receiving card payments);
+ other organisations, who jointly with us, provide products or services to you;
+ financial services organisations, including banks, superannuation funds, stockbrokers, custodians, fund managers and portfolio service providers;
+ debt collectors;
+ our legal, compliance advisers or auditors;
+ your representatives (including your legal adviser, accountant, mortgage broker, executor, administrator, guardian, trustee, or attorney);
+ fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct;
+ IT Service Providers;
+ our Licensee, Accru Wealth Management Pty Ltd and their related entities;
+ external dispute resolution schemes; and
+ regulatory bodies, government agencies and law enforcement bodies in any jurisdiction.
We may also disclose your personal information to others outside the Accru Wealth Management Group where:
+ we are required or authorised by law, or where we have a public duty to do so;
+ you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
+ we are otherwise permitted to disclose the information under the Privacy Act.
Do we disclose personal information overseas?
We may use outsourced providers who may disclose your personal information to recipients located outside Australia who are part of their corporate group, or as part of their operations when they deliver their services to us. We can make available a list of our outsourced providers on request if you would like to understand their individual privacy statements.
Do we use or disclose personal information for marketing?
We may use your personal information to offer you products and services we believe may interest you. We may send you direct marketing communications such as offers, updates, events, articles or newsletters. We will always give you the option of electing not to receive any of these communications in the future by notifying us or unsubscribing at any time.
Do we collect personal information electronically?
We will collect information from you electronically, for instance through internet browsing, mobile or tablet applications.
Each time you visit our website, we collect information about your use of the website, which may include the following:
+ the date and time of visits;
+ which pages are viewed;
+ how users navigate through the site and interact with pages (including fields completed in forms and applications completed);
+ location information about users;
+ information about the device used to visit our website; and
+ IP addresses.
We use technology called cookies when you visit our site. Cookies are small pieces of information stored on your hard drive or in memory. They can record information about your visit to the site, allowing it to remember you the next time you visit and provide a more meaningful experience.
One of the reasons for using cookies is to offer you increased security. The cookies we send to your computer cannot read your hard drive, obtain any information from your browser or command your computer to perform any action. They are designed so that they cannot be sent to another site, or be retrieved by any non-Accru Wealth Management site.
We won’t ask you to supply personal information publicly over facebook, Twitter, or any other social media platform that we use. Sometimes we may invite you to send your details to us via private messaging, for example, to answer a question. You may also be invited to share your personal information through secure channels to participate in other activities, such as competitions.
Access to and correction of personal information
You can request access to the personal information we hold about you. You can also ask for corrections to be made. To do so, please contact us.
There is no fee for requesting that your personal information is corrected or for us to make corrections. In processing your request for access to your personal information, a reasonable cost may be charged. This charge covers such things as locating the information and supplying it to you.
There are some circumstances in which we are not required to give you access to your personal information.
If we refuse to give you access, or to correct your personal information, we will give you a notice explaining our reasons except where it would be unreasonable to do so.
If we refuse your request to correct your personal information, you also have the right to request that a statement be associated with your personal information noting that you disagree with its accuracy.
If we refuse your request to access or correct your personal information, we will also provide you with information on how you can complain about the refusal.
Resolving your privacy concerns and complaints – your rights
If you are concerned about how your personal information is being handled or if you have a complaint about a breach by us of the Australian Privacy Principles, please contact us.
We will acknowledge your complaint as soon as we can after receipt of your complaint. We will let you know if we need any further information from you to resolve your complaint.
We aim to resolve complaints as quickly as possible. We strive to resolve complaints within five business days but some complaints take longer to resolve. If your complaint is taking longer, we will let you know what is happening and a date by which you can reasonably expect a response.
If you are unhappy with our response, there are other bodies you can go to.
The Australian Financial Complaints Authority (AFC) can consider most privacy complaints involving providers of financial services.
AFC can be contacted at: Australian Financial Complaints Authority GPO Box 3 Melbourne VIC 3001
Phone: 1800 931 678 www.afc.org.au
Under the Privacy Act you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information.
You can contact Accru Wealth Management by:
+ Calling 03 9835 8200
+ Emailing firstname.lastname@example.org
+ Visiting us at 50 Camberwell Road, Hawthorn East VIC 3123
+ Writing to us at PO Box 268 Camberwell VIC 3124
Our Privacy Officer can also be contacted in relation to privacy concerns on the above contact details.
We may change the way we handle personal information from time to time for any reason.
Meaning of words
Accru Wealth Management, we, us or our means:
Accru Wealth Management Pty Ltd, ABN 43 083 409 714 and Australian Financial Services Number 238520.
By asking us to assist you with our financial and finance needs, you consent to the collection and use of the information you have provided us for the purposes described above.