In this Policy and Collection Statement:

• Disclosure of information means providing information to persons outside of Affinity Private Financial Services;
• Personal information means information or an opinion relating to an individual, which can be used to identify that individual;
• Privacy Officer means the contact person within Affinity Private Financial Services for questions or complaints regarding Affinity Private Financial Services’ handling of personal information;
• Sensitive information is personal information that includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
• Use of information means use of information within Affinity Private Financial Services.

1. What kind of personal information do we collect and hold?

To enable your financial adviser to provide you with financial advice you request that is suitable for your investment objectives, financial situation and particular needs, we may collect and hold a range of personal information about you. This includes:

• Your name, contact details and date of birth;
• Formal identification, for instance a copy of your drivers’ licence or Passport;
• Employment details and history;
• Financial details including information about your financial needs and objectives, your current financial circumstances including your bank account details, assets and liabilities, income, expenditure, insurance cover;
• Details of your investment preferences and risk tolerance;
• Family circumstances and social security eligibility; and
• Any other information that we consider necessary

Please note that the personal information collected may include sensitive information such as health information and memberships of professional or trade associations.

2. How we collect personal information

If it is reasonable and practicable, we will only collect personal information directly from you. Generally, your personal information will be collected through the advice process as well as our application processes, forms and other interactions with you in the course of providing you with our products and services, including when you visit our website, call us or send us correspondence.

We may also collect personal information about you from a third party, such as your accountant. If so, we will take reasonable steps to ensure that you are made aware of this Policy and Collection Statement. We may also use third parties to view traffic at our website, which may involve the use of cookies. Information collected through such analysis is anonymous.

We will not collect sensitive information about you without your consent unless an exemption in the APPs applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.

If the personal information we request is not provided by you, we may not be able to provide you with the benefit of our services or meet your needs appropriately.

We do not give you the option of dealing with them anonymously, or under a pseudonym. This is because it is impractical, and in some circumstances illegal, for Affinity Private Financial Services to deal with individuals who are not identified.

3. Unsolicited personal information

We may receive unsolicited personal information about you.  We destroy or de-identify all unsolicited personal information we receive, unless it is relevant to our purposes for collecting personal information. We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other personal information.

4. Who do we collect personal information about?

The personal information we may collect, and hold includes (but is not limited to) personal information about clients, potential clients as well as prospective employers, employees and contractors.

5. Website collection

We collect personal information from our website (www.affinityprivate.com.au) should you choose to subscribe to our newsletter or contacting us by submitting an enquires form. We may also use third parties (i.e. Google Analytics) to view traffic at that web site, which may involve the use of cookies. Information collected through such evaluation is anonymous. Our website privacy policy can be accessed by clicking on the ‘privacy statement’ link at the bottom of our website.

We also use Google Analytics on the Site. We do not pass any personally identifiable information through this function; however, the data we collect may be combined with other information which may be identifiable to you. For further information on how Google use the data collected via our website, please refer to www.policies.google.com/privacy?hl=en; more specifically, www.policies.google.com/technologies/partner-sites

6. Why do we collect and hold personal information?

Your personal information may be used for the following purposes:

• to provide you with financial advice you have requested;
• review and meet your ongoing needs;
• provide you with information we believe may be relevant or of interest to you;
• let you know about other products or services we offer, send you information about special offers or invite you to events;
• consider any concerns or complaints you may have;
• comply with relevant laws, regulations and other legal obligations; and
• help us improve the products and services offered to our customers and enhance our overall business.

We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act.

Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise or an exemption in the Privacy Act applies.

7. Who might we disclose personal information to?

We may disclose personal information to:

• a related entity of Affinity Private Financial Services Pty Ltd, such as Affinity Private Advisors;
• an agent, contractor or service provider we engage to carry out our functions and activities, such as other financial advisors, paraplanners, fund managers, financial product issuers, insurance providers and superannuation trustees;
• organisations that assist in operating a financial planning business such as those that provide administrative services such as paraplanning or compliance;
• organisations involved in a transfer or sale of all or part of our assets or business;
• organisations involved in managing payments, including payment merchants and other financial institutions such as banks;
• regulatory bodies, government agencies, law enforcement bodies and courts;
• anyone else to whom you authorise us to disclose it or is required by law.

If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues and will make third parties aware of this Policy and Collection Statement.

We may disclose the following personal information to CRBs, in order to comply with our obligations under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (AML/CTF obligations). This may include, name, date of birth and residential address.

The purpose of disclosing this information is to enable us to verify whether the personal information collected matches the identification information held by the CRB. We may, upon request, provide you with an alternative method of verification, however, any alternative verification method must also comply with the AML/CTF legislation.

8. Management of personal information

We recognise the importance of securing the personal information of our customers. We will take steps to ensure your personal information is protected from misuse, interference or loss, and unauthorised access, modification or disclosure.

Your personal information is generally stored in our computer database. Any paper files are stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:

• passwords are required to access the system and passwords are routinely checked;
• data ownership is clearly defined;
• employees have restricted access to certain sections of the system;
• the system automatically logs and reviews all unauthorised access attempts;
• unauthorised employees are barred from updating and editing personal information;
• all computers which contain personal information are electronically secured; and
• data is encrypted during transmission over the network

Please note that as we use cloud computing to store and share your personal information it may result in disclosing information to overseas recipients. We may disclose personal information to third party contractors that are located in the Philippines in some circumstances.

We will not send personal information to recipients outside of Australia unless we have taken reasonable steps to ensure that the recipient does not breach the Act or the APPs; the recipient is subject to an information privacy scheme similar to the Privacy Act; or the individual has consented to the disclosure.

If you consent to your personal information being disclosed to an overseas recipient, and the recipient breaches the APPs, we will not be accountable for that breach under the Privacy Act, and you will not be able to seek redress under the Privacy Act.

9. Direct marketing

We may only use personal information we collect from you for the purposes of direct marketing without your consent if the personal information does not include sensitive information and you would reasonably expect us to use or disclose the information for the purpose of direct marketing.

If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications.

You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations. We must give effect to the request within a reasonable period of time. You may also request that we provide you with the source of their information. If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.

10. Identifiers

We do not adopt identifiers assigned by the Government (such as driver’s licence numbers) for our own file recording purposes, unless one of the exemptions in the Privacy Act applies.

11. How do we keep personal information accurate and up to date?

We are committed to ensuring that the personal information it collects, uses and discloses is relevant, accurate, complete and up to date.

We encourage you to contact us to update any personal information we hold about you.  If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge you for correcting the information.

12. Accessing your personal information

Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information that we hold about you by contacting the Affinity Private Financial Services Privacy Officer. We will provide access within 30 days of the individual’s request.  If we refuse to provide the information, we will provide reasons for the refusal.

We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged for providing access.

13. Updates to this policy and collection statement

This Policy and Collection Statement will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.

14. Responsibilities

It is the responsibility of management to inform employees and other relevant third parties about this Policy and Collection Statement.  Management must ensure that employees and other relevant third parties are advised of any changes to this Policy and Collection Statement. All new employees are to be provided with timely and appropriate access to this Policy and Collection Statement, and all employees are provided with training in relation to appropriate handling of personal information. Employees or other relevant third parties that do not comply with this Policy and Collection Statement may be subject to disciplinary action.

15. Non-compliance and disciplinary actions

Privacy breaches must be reported to management by employees and relevant third parties. Ignorance of this Policy and Collection Statement will not be an acceptable excuse for non-compliance. Employees or other relevant third parties that do not comply with this Policy and Collection Statement may be subject to disciplinary action.

16. Incidents/complaints handling/making a complaint

We have an effective complaint handling process in place to manage privacy risks and issues.

The complaints handling process involves:

• identifying (and addressing) any systemic/ongoing compliance problems;
• increasing consumer confidence in our privacy procedures; and
• helping to build and preserve our reputation and business.

You can make a complaint to us about the treatment or handling of your personal information by lodging a complaint with the Compliance Officer.

If you have any questions about this Policy and Collection Statement, or wish to make a complaint about how we have handled your personal information, you can lodge a complaint with us by:

• writing to – Head of Complaints, Office of Affinity Private Financial Services Pty Ltd, Level 5, North Building, 333 Collins Street, Melbourne VIC 3000
• emailing – complaints@apfinancialservices.com.au

If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner by:

• telephoning – 1300 363 992
• writing to – Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
• emailing – enquiries@oaic.gov.au

17. Contractual arrangements with third parties

We ensure that all contractual arrangements with third parties adequately address privacy issues and make third parties aware of this Policy and Collection Statement.

Third parties will be required to implement policies in relation to the management of your personal information in accordance with the Privacy Act.  These policies include:

• regulating the collection, use and disclosure of personal and sensitive information;
• de-identifying personal and sensitive information wherever possible;
• ensuring that personal and sensitive information is kept securely, with access to it only by authorised employees or agents of the third parties; and
• ensuring that the personal and sensitive information is only disclosed to organisations which are approved by us.

18. Your rights

This Privacy Policy and Collection Statement contains information about how:

• you may access the personal information we hold about you;
• you may seek the correction of your personal information; and
• you may ask us to provide an alternative means of identity verification for the purposes of the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth);
• you may complain about a breach of the Privacy Act, including the APPs; and
• we will deal with a privacy complaint.