This Policy outlines how we manage personal information and safeguard the privacy of our clients.
This Policy has also been developed with reference to:
A1.3 What personal information is collected?
We only collect personal information that is reasonably necessary for us to provide our clients with financial services and to administer them. The kind of personal information we collect and hold will depend upon the type of services requested by our clients and may include:
A1.4 How is personal information collected?
We collect personal information in a number of ways including:
A1.5 What if certain information is not provided?
If we are provided with an incomplete application, we may not be able to provide any services until the application is complete.
If a client chooses not to disclose their Tax File Number (TFN), TFN exemption or Australian Business Number (ABN), we may have to deduct tax at the highest marginal rate (plus the Medicare levy) from distributions or income payments.
If an individual chooses not to disclose their account details or correctly answer verification questions, we may not be able to provide services requested.
We may collect, use and disclose an individual’s personal information for the primary purpose of providing the services requested by our clients, as well as for related purposes such as:
We may disclose personal information to;
A1.7 Overseas disclosures
We may disclose personal information collected in Australia to recipients in foreign countries, but only do so where we have disclosed to users of our website the location of those recipients; and in circumstances where the overseas recipient is subject to a law, or binding scheme, that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way the APPs protect the information, and mechanisms can be accessed by the individual to enforce that protection of the law or binding scheme; or in circumstances where we enter into an enforceable contractual arrangement with the overseas recipient that requires the recipient to handle the personal information in accordance with the APPs (other than APP1). In some cases, we may utilise 'Cloud' storage solutions for data storage purposes, and the relevant servers may be located overseas.
A1.8 Use of service providers
We may contract out some of our administrative and support functions such as mailing, settlement services, unit registry services, document and data storage, background checking or identity verification to external service providers from time to time. Only information necessary for the service provider to carry out their function will be provided and will be subject to confidentiality clauses in the relevant services agreement.
Personal information such as contact details may change from time-to-time and we ask that our clients and individuals keep us informed of any changes by notifying us.
Where information has been previously provided about another person related to a client’s investment/product (such as a beneficial owner),and the information is no longer current, the client must provide up-to-date information.
Changes to some details, such as a change of name, may require additional documentation to verify the change. Additionally, some changes may be required to be made on a specific form.
We store personal information in a combination of computer storage facilities, paper-based files and other records. These are held on our premises and systems as well as offsite using 'Cloud' service providers for data storage and management purposes, which may be located overseas. We maintain effective control of the information under contractual arrangements.
We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure, and that any service provider we rely on takes similar steps.
Where personal information is no longer required to be retained, we will take such steps as are reasonable in the circumstances to de-identify the information or put it beyond use.
This document sets out our policy on the management of personal information and is made freely available on our website, or in hardcopy if requested.
Generally, we provide individuals with access to their personal information that we hold, unless a particular exception applies, such as where:
If a request for access would divulge a commercially sensitive decision-making process, then we may provide an explanation rather than direct access to the information.
If we become aware that the personal information we hold about an individual is inaccurate, incomplete, misleading or irrelevant, then we will take reasonable steps to amend it. If we receive a request from an individual to correct their information, then we will seek to correct it within 30 days. If we disagree with an individual about the accuracy, completeness or currency of our records, then they have the right to request that we note their disagreement on those records.
We do not use any government-issued identifiers (such as TFNs, Medicare numbers and Drivers Licence numbers) for use as our own identifier for individuals. Instead, we create our own unique identifiers such as investor numbers and account numbers are used to identify individuals.
Given legal requirements on financial institutions to identify their customers, in most situations we cannot allow transactions on the basis of anonymity (including the use of a pseudonym). Access to our public website, may be done anonymously, or in the case of general enquiries, using a pseudonym. However, we may not be able to respond to queries unless we are provided with certain information.
We will not use personal information for direct marketing purposes unless:
We will not use any sensitive information for direct marketing purposes.
A1.16 Use of our website
Our web analytics providers use "cookies" and in some cases "clear gifs/web beacons" to collect information.
Cookies are pieces of information that are transferred to a computer when a person visit a website so that sites can record usage and, in some cases, provide tailored content or targeted advertising. Most web browsers are set to accept cookies, or they can be rejected. However, if all cookies are rejected, some parts of the website may be inaccessible.
Clear gifs (also known as web beacons) are used in combination with cookies to help us understand how visitors interact with our website. A clear gif is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. The use of a clear gif allows us to measure the actions of the visitor opening the page that contains the cleargif.
A1.17 Contacting us
The Compliance Officer may be contacted regarding any questions in relation to this Policy:
Nick Reeves
contact@bluesana.com.au
A1.18 Complaints about privacy
Clients may raise any concerns about any breach or potential breach of their privacy, by contacting the Compliance Officer and we will make every effort to resolve the complaint internally.
To make a complaint:
The complaint may also be taken to the Office of the Australian Information Commissioner (OAIC)
For more information on how to lodge a complaint with the OAIC, please contact the OAIC hotline service on 1300 363 992 or email enquiries@oaic.gov.au
A1.19 Changes to our Privacy Policy
We may make changes to this policy from time to time for any reason and we will update our website in a timely manner.
A1.20 Training & Awareness
The Compliance Officer is responsible for ensuring that all Staff are aware of the requirements in this Policy.
A1.21 Non-compliance
Instances of non-compliance with this Policy must be reported under our Incidents & Breaches Policy & Process. Intentional non-compliance is considered serious and may result in disciplinary action including dismissal.
A1.22 Reporting
The Compliance Officer must report to the Board periodically on any privacy complaints under this policy as well as any instances of non-compliance.
