Privacy Policy

Privacy Policy Background

We respect our client's rights to privacy concerning personal information we hold about them.

We aim to manage personal information in an open and transparent way.

Our goal is to take such steps as are reasonable in the circumstances to implement practices, procedures and systems relating to our functions and activities that will ensure that we comply with the Australian Privacy Principles, and as will enable us to deal with inquiries or complaints from individuals about our compliance.

This policy

This policy outlines how we manage personal information which we hold.

Broadly, we collect, hold, use and disclose your personal information for purposes related to the provision of services to you.

Details follow.

Things change

It's very important that you keep us up to date with your details. If our details about you are wrong, we will correct them free of charge if you let us know.

Investors must in a timely way give all information that we reasonably request to perform our functions.

Why we collect

Broadly, we collect personal information to:

  • administer your investment,
  • comply with laws
  • conduct research, and
  • conduct direct marketing

but just contact us to ensure you never hear from us on this front.

We also use personal information for other reasons such as:

  • for monitoring, evaluating and improving products and services,
  • for statistical, actuarial, prudential or research, and
  • to provide you information about other services and products.

If you do not provide us with your contact details and other information we ask, we may not be able to have or keep you as an investor.

How we collect

There are several ways we collect personal and other information but we aim to ensure they are lawful and fair means:

  • when you apply to invest in one of our investment products

often you tell us information in a paper or online application or other form

  • when you otherwise tell us

for example, when you contact us to update or change your details

  • through our website

like many websites, ours collects some limited information from users.

Those who help us provide products and services to you can also collect personal information and pass it on to us
for example, custodians, administrators, settlement systems, mailing houses and auditors.

People who assist you may collect personal information and pass it onto us.  In agreeing for us to provide services to you, you consent to the collection by us of information from someone other than you whom we have no reason to doubt properly represents you
for example, someone investing jointly with you, your relative, your trustee or administrator, your financial, legal or other adviser, if a trustee, your beneficiary, your partners, your investors, someone authorised to operate your account or your broker.

Unsolicited personal information which we could not have collected under the Australian Privacy Principles is destroyed or de-identified if it is lawful and reasonable to do so.

What is collected and held

We only collect personal information which we consider reasonably necessary for one or more of our functions or activities.

Personal information collected and held includes the following:

  • name, gender and date of birth
  • address details
  • contact details
  • bank account details,
  • TFNs and ABNs,
  • employment information

in relation to investments made via a superannuation fund,

  • details of your investors and beneficiaries
  • details of the source and use of money you invest
  • use details for this website
  • information contemplated by laws and regulator, settlement system or exchange policies and requests and
  • any other information that we consider necessary or desirable.

Because of the requirements of law, it is impracticable for us to deal with individuals who have not identified themselves or who have used a pseudonym.

When we disclose

We will seek to ensure that your personal information is not used or disclosed for any purpose other than:

  • the primary purpose for which it was collected

or a purpose that is related to the primary purpose for which it was collected or a related secondary purpose,

  • where you have consented to the use or disclosure, or
  • in other circumstances where the Australian Privacy Principles authorise the use or disclosure such as when it is required by or authorised under law.

We will not disclose personal information we hold about you unless:

  • this policy allows,
  • you otherwise agree,
  • we consider someone needs the information

typically because they are a regulator, settlement system or exchange or your adviser or to assist us  - for example the administrator of one of our investment products you have invested in, or

  • laws or regulator, settlement system or exchange policy requires, or a regulator, settlement system or exchange requests and
  • to administer your investment.

Those we disclose personal information to include:

  • regulators, settlement system or exchanges

such as AUSTRAC, the ASIC, the Australian and NZ tax offices, the Securities Commission of NZ,  APRA and ASX,

  • your financial or other adviser,
  • those we have no reason to doubt are acting on your behalf,
  • companies with our group, and
  • those who help us provide products and services to you

for example, superannuation fund trustees, insurance brokers, insurance companies, fund managers, custodians, fund administrators, mailing houses and auditors.

In the case of joint accounts, we allow each individual access to account balances and transaction details, but not to the personal details of the other individual.

How we hold

We keep physical records on premises or in commercial storage.

Electronic records are kept on local servers, with back-ups off site.

No personal data is stored on our web site.

Some of the measures that we have adopted are having facilities for the secure storage of personal information, having secure offices and access controls for our computer systems.

We will also take reasonable steps to destroy or permanently de-identify personal information that we no longer need for any purpose for which may be used or disclosed under the Australian Privacy Principles.

What about security?

We are committed to ensuring that your personal information is kept secure.  We take reasonable steps to ensure that the personal information that we hold is protected from misuse and loss and from unauthorised access, modification and disclosure.

We have a number of physical access and technology policies and procedures in place designed to provide a robust security environment. They include having secure premises, and access controls for our computer systems.

We require those who help us provide products and services to you to take reasonable steps to protect personal information.  If they are governed by Australian laws, this includes to meet Australian legal requirements on privacy.

A note about the Internet

The internet is not a secure environment and we cannot guarantee the security of information we exchange electronically.  This is the nature of the Internet.

It is possible however that your personal information will be moved by those who help us provide products and services to you to a place where Australian laws do not apply, and different standards may apply there.

Records may be stored in the cloud, in Australia or overseas (as is the nature of storage such as this), by us as well as those who help us provide products and services to you.  We will tell you what cloud providers are used if you ask, and direct you to their information policies on personal information.

It is not practicable to tell you the countries where that information is likely to be located.

We may use "cookies" to obtain information with regards to web site activity such as the type of browser used, the number of pages viewed and navigation patterns. This information on its own does not identify an individual but it does provide us with statistics that can help us with the design of our web site. You can configure your browser to accept or reject cookies. If you reject all cookies you may not be able to use our web site.

Sensitive information

Sensitive information is a sub-set of personal information, and is given a higher level of protection under the Australian Privacy Principles.

It is information or an opinion about:

  • racial or ethnic origin,
  • political opinions,
  • membership of a political association,
  • religious beliefs or affiliations,
  • philosophical beliefs,
  • membership of a professional or trade association,
  • membership of a trade union,
  • sexual preferences or practices,
  • criminal record, or
  • biometric and health information.

It would be very rare that we collect sensitive information.

We only ever collect sensitive information about an individual if:

  • the individual consents to the collection and the information is reasonably necessary for our functions or activities,
  • if required or authorised by or under an Australian law or a court/tribunal order,
  • there is a serious threat to their life, health or safety,
  • we suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been, is being or may be engaged in, or
  • the collection is reasonably necessary to assist to locate a missing person.

We never adopt a government related identifier to identify you – such as a TFN or ABN - unless required or authorised by or under an Australian law or a court/tribunal order, and only use these as law permits.

Links to other web sites

This web site may contain links to other web sites for your convenience. We are not responsible for the information handling and privacy policies and practices of other linked web sites.

Telephone services

We may monitor or record telephone calls for training, record or security purposes. If we do so, we will tell you at the time.

Access to personal information

In most circumstances, you have the right to access free any personal information we collect and hold about you and to have it corrected if it is wrong.

This is subject to exceptions allowed by law such as where giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety or where providing you with access would have an unreasonable impact upon the privacy of others.

If we deny a request for access we will provide you with the reasons for this decision.

To request access please contact us and we will respond within a reasonable period after the request is made.

Correcting personal information

We endeavour to take reasonable steps to ensure that the personal information that we collect, use or disclose is accurate, up to date, complete, relevant and not misleading.

If you believe that any of the personal information that we hold about you is not accurate, complete, up-to-date or is misleading please contact us.

If we agree that the personal information requires correcting we will take reasonable steps to do so.

If we do not correct your personal information we will provide you with the reasons for not correcting your personal information. If you request that we associate with the information a statement claiming that the information is not accurate, complete and up-to-date we will take reasonable steps to comply with this request.

Investing through an administration platform

If your investment into our products is through an IDPS, wrap, master trust or such other portfolio administration platform, we will not generally hold any personal information about you.

Please contact the provider directly with your query.

Acting reasonably

We may take and may act (or not act as relevant) on any advice, information and documents which we have no reason to doubt as to authenticity, accuracy or genuineness.

About this document

This is the privacy policy for Select Asset Management Limited and its Associates .  It is current as at 12 March 2014.  If you would like a copy, contact us and we will email or post it to you free.

We may make changes to information handling and privacy policies and practices and this Privacy Policy Statement. We will publish important changes on our web site and if necessary update this Privacy Policy Statement.

Questions and complaints

You can obtain further information about the way in which we manage personal information that we hold, or you can raise any privacy issues with us (including any concerns you may have about breaches of the Australian Privacy Principles), by contacting us in writing:

The Privacy Officer
Select Asset Management Limited

Level 5 
10 Spring Street
Sydney NSW 2000

Tel: 02 8022 7400 
Fax: 02 8022 7448