Our privacy assurance to you
At the Illingworth David Financial Planning Pty Ltd your privacy is important to us. Privacy laws apply to how we collect, maintain, use and disclose your personal information and this brochure explains how these laws affect Illingworth David Financial Planning Pty Ltd and you, including:
- the types of information that we keep on record and how we may use that information
- your privacy rights along with our general rights and obligations
- our policies in relation to how we collect, maintain, use and disclose your personal information.
Other privacy statements
When you apply for a new product or service offered or administered by us, the application form will include notices about privacy and requests for consent. Those privacy notices (called privacy statements) will specify in more detail how any information about you may be used or disclosed in relation to the particular product or service. When you apply for or use one of our products or services or a product or service administered by us, you consent to us collecting, maintaining, using and disclosing personal information about you (provided by you or by another person) in accordance with the privacy statements in the application forms, any Agreement you sign and this brochure.
What information does Illingworth David Financial Planning Pty Ltd hold?
The types of information we ask for will depend on the type of product or service requested by you. Generally, we keep a record of one or more of the following types of information about you:
- information that identifies you, such as your name and address and other identification information provided by you and people nominated by you
- if you apply for insurance, information about what is being insured, including health information about you, your income and occupation, information about your beneficiaries, and information about your claims history
- if you apply for a superannuation or investment product or service, information about your employment, beneficiaries, bank accounts for funds to be transferred to or from and, in some cases, health information about you
- transaction information relating to the product or service acquired by you, such as details of contributions and distributions for investment products
- if you apply to become an authorised representative with us, information about your professional background, training and experience, which may include sensitive information.
- All information sought is required for our business purposes, which are detailed generally in this brochure and more specifically in our application for.
We do not actively seek to collect sensitive information (for example health information or information about any criminal record), unless it is necessary for our business purposes. If we do have to collect sensitive information, we will only collect, use and disclose it in accordance with privacy laws. Sometimes we act as an agent for others when collecting information about you, such as for the insurer underwriting our insurance products (‘the Insurer’) or on behalf of other parties (‘Institutional Business clients’) in our capacity as administrator. We will inform you when we do this.
How may we use your personal information?
Generally, we use your personal information to:
- help us process your application for products or services and subsequent investment directions
- effectively manage and administer these products and services (including keeping records required under superannuation laws and the Corporations Act)
- ensure our internal business operations are running smoothly, which may include fulfilling legal requirements, conducting confidential systems maintenance and testing and conducting confidential telephone call monitoring to ensure our staff are properly trained and their service to you continually improved.
If you acquire products or services from a member of the Illingworth David Financial Planning team, your personal information may also be used by other members of the Illingworth David Financial Planning team to analyse products and services, evaluate the needs of our customers and develop new products. Unless you tell us not to or have previously told us not to, we may also provide access to your personal information (excluding health information) to members of the Illingworth David Financial Planning team or use that information ourselves to inform you of products and services offered by any member of the Illingworth David Financial Planning team or other suppliers which we think may be of interest or value to you.
Any form used to collect your information may give more specific details about the way we use your information.
What rights do we have to disclose personal information?
Generally, we must obtain your consent before we tell anyone about you, or your investments. You can give us your consent expressly (by telephone or writing to us) or it may be implied by your conduct.
An example is giving your investment details to a court if we are ordered to do so under a subpoena.
Depending on the product or service we provide to you, we may also disclose your personal information to:
- our external service providers that provide services to us. This is on a confidential basis and includes organisations that provide us with financial, advisory, administrative or other services, such as investment managers of products you select, financial institutions you nominate, industry bodies, mail-houses contracted to mail information to you in relation to your products and services and archive companies
- anyone acting on your behalf, including your financial adviser or broker, their office and licensed dealer. We may do this by making this information available to them through an electronic facility or service (operated by us or an external service provider) that they use in the administration of their practice
- anyone who holds amounts on your behalf which will be transferred to or from us
- to any party acquiring an interest in our business
- to a complaints body to whom a complaint relating to a product or service is referred
- where the law requires or permits us to do so
- if you consent.
Similarly, for insurance products, we may disclose personal information about you to the Insurer without getting your consent. These parties are required to comply with the privacy laws in using any such information.
If you are a financial adviser, from time to time we may also use or give access to your personal information to the investment managers with whom you place client investments. The information we provide is limited to your name and business contact details, together with details of your funds under administration in relation to the particular investment manager, including inflow and outflow information. We do this on a confidential basis to enable those investment managers to analyse products, services and customer needs and to market products and services supplied by the investment manager that may be of interest to you. We will not provide this information to investment managers if you tell us not to. Email us if you prefer for your details (as listed above) not to be provided to investment managers.
We may at other times give you more details about our disclosure practices in relation to specific products or services - for example on the disclosure documents and applications we use to collect personal information about you.
Use of your personal information by the Insurer
How we protect the security of your information
We take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. We have physical, electronic and procedural safeguards to protect your information held by us. For example, your personal information is stored in secured office premises, in electronic databases requiring logins and passwords for access. We require all staff to maintain the confidentiality of your personal information.
We use secure methods to destroy or deidentify any personal information as soon as the law permits, provided the information is no longer needed by us for any purpose.
Changes to our privacy policies
We may amend this Privacy Brochure from time to time. Not all changes to our privacy policies will require your consent, for example where office security procedures are changed. We will notify you of any change to our policies that require your consent before being implemented.
What are your rights?
Unless required by law (for example to comply with a legal duty of disclosure when applying for an insurance product) you need not give us any of the personal information about you or any other person which may be requested in our communications with you. However, without that information, we may not be able to process an Application, fulfill your request or provide you with an appropriate level of service.
Where we collect information from you about another individual, for example your nominated beneficiaries, please make that individual aware of that fact and the contents of this Privacy Brochure.
Access to your information
You may request access at any time to personal information held by us about you. We will process your request within a reasonable time, usually 14 days for a straightforward request. More time may be needed, depending on the nature of the request.
There is no fee for requesting access to your information, however we may charge you the reasonable costs of processing your request. Sometimes we are not required to provide you with access. If we refuse you access to your personal information, we will tell you the reason why. If we are not required to provide you with access to the information requested, we will consider, if reasonable, whether the use of a mutually agreed intermediary would allow sufficient access to meet your needs and ours.
Correction of information
We try to ensure that all information held by us about you which we collect, use or disclose is accurate, complete and up-to-date. However, you must promptly notify us if there are any changes to your personal information.
You may ask us at any time to correct personal information held by us about you which you believe is incorrect or out-of-date. We will deal with your request within a reasonable time.
If we disagree as to the accuracy of the information, you may request that we make an appropriate notation in relation to that information noting you consider it is not accurate, complete or up-to-date.