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SMA Consultants Pty Ltd - Privacy Policy
Policy Statement
The SMA Consultants Pty Ltd (SMA) Privacy Policy sets out how information we capture and store about individuals is handled
responsibly and in accordance with National Privacy Principals set out in the Privacy Act 1988
(Cth).
SMA will:
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only collect information that is necessary;
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be lawful, fair and unintrusive in the way that we collect information;
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take reasonable steps to ensure that the individual is informed of who we are and how we use the information;
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where practical collect the information directly from the individual;
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only disclose information where it is consistent with the individual's expectations or is required in the public
interest;
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take reasonable steps to ensure the information is accurate;
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keep personal information secure and be open about what kind of information we hold;
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take all reasonable steps to correct any information which is established to be incorrect;
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not use identifiers that government agencies assign;
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take steps to ensure privacy if we supply personal information to third parties; and
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only obtain highly sensitive information about an individual with that individual's consent.
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This policy does not apply to the treatment of our employee records. Employee records are exempt from the operation of the
Privacy Act if the organisation is, or has been, an employer of the individual in question and the act or practice is directly
related:
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to a current or former employment relationship between the employer and the individual; and
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an employee record held by the organisation and relating to the individual.
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This exemption does not cover contractors, sub contractors or prospective employees.
Objectives
The objectives of our privacy policy are:
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to protect personal information about individuals from misuse;
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to ensure SMA is not exposed to legal proceedings for any breach of the privacy laws; and
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to be a responsible corporate citizen.
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Key Privacy Policies
Collection of personal information
We will only collect personal information that is necessary for one or more of our functions or activities. When collecting
this personal information, we will do so only by lawful and fair means and not in an unreasonably intrusive way. We will only
collect sensitive information about you with your consent.
When personal information is provided to us we must inform the relevant person:
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what that personal information will be used for;
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to whom the personal information may be passed: and
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that he or she is able to gain access to that personal information.
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Personal information we may hold
If you are our client, personal information that we may hold about you includes:
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your name, age, date joined employer, occupation, salary and contact details;
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account details such as investment option used, contributions paid by you and your employer and amounts transferred
into and from your account;
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tax file number;
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details concerning the dependants you have nominated to receive the death benefit; and
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details about your health provided to us via a personal statement and/or doctor's report, for insurance purposes.
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Personal information that we may hold about individuals who are not our clients includes but is not limited to:
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information provided to us in job application forms and resumes, such as the applicants name, age, contact details and
employment history, and information recorded by us during the recruitment process;
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information provided to us about contractors, and sub contractors, either by themselves or their employer, and
information recorded by us during the course of their relationship with SMA;
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the names and contact details of advisers and other individuals who have a business relationship with SMA, and
information recorded by us in order to establish and maintain that relationship.
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Purpose and use of personal information
When dealing with clients, our primary purpose in collecting personal information is to enable us to provide and manage
financial products and services. However, we may also use personal information for secondary purposes such as:
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to enable advisers to contact members to make sure they understand their investment, and to offer to help them see how
the investment fits into their overall financial plan;
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for our internal operations including accounting, risk management, record keeping, archiving, systems development and
testing, staff training and compliance monitoring;
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in order to ensure we comply with legislative and regulatory requirements, or for preventing or investigating crime or
fraud; and
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to give employers (where relevant) any necessary details in relation to monitoring their superannuation arrangements
and of their total contributions for superannuation guarantee, taxation and fringe benefit reporting purposes.
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When we disclose your
personal information
We collect information about you for the
purpose of reporting to AUSTRAC under the Anti-Money Laundering and
Counter-Terrorism Financing Act 2006.
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banks or other financial institutions, for any direct debits or credits;
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other superannuation entities for the purpose of rollover or transfer of benefits;
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advisers, auditors, consultants, legal or accounting firms, insurers and financial services industry bodies;
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regulatory bodies, government authorities and law enforcement agencies;
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debt collection agencies;
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mailing houses or other similar companies we may use for printing and/or mailing letters, statements, reports,
newsletters and other correspondence;
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a client's executor, administrator, trustee, guardian or attorney; and
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other parties to whom we are authorised or required by law to disclose personal information.
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Information we collect about individuals who are not clients will generally have very limited use and disclosures. In these
circumstances, our primary purpose for collecting information about you will depend on your relationship to us. Typically,
these purposes include:
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the facilitation of business relationships, such as those formed with advisers; and
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recruitment.
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We usually will only disclose information about contractors, sub contractors and prospective employees for these purposes to:
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other organisations to whom we outsource one or more of our functions; or
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regulatory bodies, government authorities and law enforcement bodies as required.
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Access & changes to your personal information
Individuals may request access to their personal information that we (or an outsourced service provider) hold in relation to
them. They can request access to their personal information by writing to us at:
SMA Privacy Officer
SMA Consultants Pty Ltd
Level 16
114 William Street
Melbourne Vic 3000
If you can show us that the
personal information is inaccurate, we will
take reasonable steps to correct it. Note
that we need not provide access to personal
information in several types of situations,
for example where a request is frivolous,
or where to provide access would pose a
threat to health or public safety, unreasonably
interfere with another persons privacy,
or be a breach of the law. If we refuse
access we will advise you of our reasons
for doing so.
Data Quality
We will take reasonable steps to make sure that personal information we collect, use or disclose is accurate, complete and up
to date. It is, however, the individual's responsibility to advise us of any changes to their personal details to ensure we can
keep our records accurate and up to date.
Data Security
We employ appropriate technical security measures to protect your personal information and ensure that it is not accessed by
unauthorised persons. Our security measures also provide that we may request proof of identity before we will release personal
information to you.
SMA has information technology data security which covers the following matters:
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physical security
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computer and network security
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secure communications
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security in contracting out functions
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We have a responsibility to protect personal information. Consequently, only those that need to know are to be provided with
access to personal information.
We maintain physical
security such as locks and security systems
over our paper and electronic data stores
and premises.
Outsourcing and Contractual Arrangements
All contractual arrangements with third parties impose appropriate privacy and confidentiality obligations on those third
parties to ensure that personal information that SMA holds is kept secure and that SMA does not breach it obligations under the
Privacy Act and this policy.
Complaints
We are committed to providing members, and other parties
whose personal information we hold, a fair
and responsible system for the handling
of their complaints.
If at any time
you have any complaints in relation to privacy,
please contact our Privacy Officer (as detailed
above). We will
seek to address any concerns that you have
through our complaints handling processes,
but if you wish to take matters further
you may refer your concerns to the Office
of the Federal Privacy Commission.
Compliance
Employees of SMA must comply with this Privacy Policy and breaches will be treated seriously.
Changes to this Privacy Policy
We reserve the right to review and amend this Privacy Policy from time to time and to notify you as soon as is practicable
thereafter.
Website
Access
When you visit our website, details may be recorded about
your visit, such as time and date, your
server address, pages accessed, time spent
and type of browser. This information is
used in an anonymous form for statistical
purposes and as such cannot identify you
individually.
We may use cookies
to identify your browser so that the next
time you visit our website we remember your
log in details. A cookie is a small file
which remains on your computer and contains
information enabling our website to recognise
your browser. If you do not wish to use
cookies, you can adjust the settings on
your browser to reject cookies or notify
you when they are being used.
Identification
As
you would already know, government departments
have a variety of ways to identify us as
members of Australia. Some of those ways
include Tax File Numbers (TFNs), Australian
Company Numbers (ACNs) and Medicare Numbers.
This information filing system was created
by those government departments, specifically
for their own needs and purposes. We do
not consider it appropriate to use those
government identifiers with SMA business
and consider the use of such identifiers
can cause confusion, and in some circumstances,
a breach of your privacy. As such we have
our own identifiers to recognise our clients
and our professional members.
Information
Sent Overseas Or Shared Through The Internet
We
will not send any personal information about
you overseas unless you consent to this,
or we reasonably believe that the other
country has privacy laws substantially similar
to our own, or we provide the information
in other circumstances giving like protection.
Our
website contains a number of links to other
websites, including the websites of our
commercial partners. When this occurs,
be sure to check the privacy policy of those
websites as we are not responsible for privacy
practices of those other parties
Additional
Privacy Information
Further
information on privacy in Australia may
be obtained by visiting the web site of
the Office of the Federal Privacy Commissioner
at http://www.privacy.gov.au.
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