Hunter Green Pty Ltd abides by the Australian Privacy Principles established under the Privacy Act 1988 and Privacy Amendment (Enhancing Privacy Protection) Act, 2012. Detailed below, for your information, is our policy on the management of personal information.
We are committed to manage any personal information we collect from our clients in an open and transparent way.
We collect personal information from you and about you as part of our advisory role. We do this in a variety of ways, including asking you for data about you and asking others to provide data about you (e.g. a super fund you invest in).
Any personal information we hold about you will be securely stored either in hard copy or on computer hard drive, using computer software and/or data storage facilities provided by third parties over the internet (ie not just on our computers in our offices).
Because we store some of our business data electronically and may back some or all of this data up using so-called “cloud-based” technology there is a chance that some of your personal information may be disclosed to overseas recipients in the sense that its transmission via the internet will mean it is “disclosed” to the party that operates the IT infrastructure where the data is stored. We are unable to say with complete certainty which countries this infrastructure may be located in however if this is of concern to you we are happy to investigate and to advise.
If you have any call to complaint about our treatment of your personal information you can contact us or the Privacy regulator directly – they are accessible here: www.oaic.gov.au.
Although the Privacy Act makes provision for you to remain anonymous or use pseudonyms this is unlikely to occur in your dealings with Hunter Green as we have obligations under the Corporations Act and the Anti-Money Laundering and Counter-Terrorism Financing Act to know and identify our clients before we provide advice to them or transact on their behalf.
As an Australian Financial Services Licence holder 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:
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.
We are required by the Corporations Act, the Tax Agent Services Act and the rules and standards of various professional 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 retainer 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.
If we determine that we have obtained unsolicited personal information from you (i.e. information we don’t actually need in order to deliver our services to you) we will contact you and return it or otherwise remove it from our records as soon as is practicable.
Generally, collection of your personal information will be effected in either face to face interviews, or over the telephone or internet. From time to time addittional and/or updated personal information may be collected through one or more of those methods.
Where we collect information about you other than directly from you we will advise you of this fact and provide any other information to you about that collection as is determined relevant in the circumstances and in light of sub- clauses 5.1 and 5.2 of the APPs.
We will not use or disclose Personal Information collected by us for any purpose other than:
We may disclose your Personal Information to superannuation fund trustees, insurance providers, and product issuers for the purpose of giving effect to your financial plan and the recommendations made by us.
We may record and store your Personal Information on computer software and/or data storage facilities provided by third parties over the internet (ie not on our computers in our offices).
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.
The only overseas recipient of your personal information we can currently imagine is the party that hosts any IT infrastructure that we back up our business data to – e.g. via the so-called “cloud”. We will seek confirmation from any such service provider that they will treat your data securely and in alignment with the APPs. If we form the view that they are not able to treat client personal information in this way we will seek an alternative service provider.
Although it is highly unlikely, we may transfer personal information about clients to someone (other than ourselves or the client) who is in a foreign country only if:
We identify our clients via identifiers created on our electronic database. We do not identify clients using numbers that have been assigned to them by:
It is not our practice to use or disclose an identifier assigned to a client by an agency, or by an agent or contracted service provider, unless:
We will do all we can to ensure the personal information we collect is accurate, up-to-date and complete.
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 computer based information is protected through the use of access passwords on each computer and screen saver passwords. Data is backed up each evening.
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 7 years in order to comply with legislative and professional requirements, following which time the information will be destroyed.
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:
In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal and the mechanisms available to complain about our refusal.
We will endeavor 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.
Privacy Officer: Greg Hunter
Hunter Green Pty Ltd
Level 5, 320 Adelaide Street
Brisbane QLD 4000
Email: [email protected]
Telephone 07 3532 4051