Togethr Financial Planning Pty Ltd ("Togethr") trading as MyLife MyAdvice and Equip Financial Planning is required to comply with the Privacy Act (Cth) 1988 and the Australian Privacy Principles in relation to the protection of your personal information. In this document Togethr Financial Planning Pty Ltd is referred to as “we”, “our” and “us”.
2. How do we collect and hold personal information and why?
In providing financial services to clients, we collect and hold personal, and sometimes health, information about you. This information can be held in both hard copy and electronic format.
We collect this personal information directly from you when your client profile is created and when you meet or talk with us about your financial planning needs. We also obtain information about your super account, balance, membership status contribution history and related details from Togethr Trustees Pty Ltd, the trustee for Equipsuper and Catholic Super. We will only collect sensitive information with your consent. In limited cases we will also collect your information indirectly, for example, from your attorney or professional adviser or financial product provider, but only when you have provided your consent to this.
In some instances, you will provide us with the personal information of other individuals (such as your nominated beneficiaries) and you should notify them that you have provided their details to us.
Personal information about you is collected to:
- Establish and verify you as a client;
- Establish your identity;
- Provide advice to you about investments and strategies;
- Prepare a financial plan for you;
- Assist in implementing investments recommendations for you;
- Manage and resolve complaints relating to you; and
- Conduct research regarding our clients generally.
3. What kinds of personal information do we collect?
Personal information is any information or opinion that identifies you or enables you to be reasonably identified. Personal information also includes sensitive information, which includes information about your health.
The kinds of information that we hold and collect about you includes:
- Personal particulars (name, date of birth, gender);
- Tax File Number;
- Proof of identity (for example, certified copies of a valid driver's licence, birth certificate or passport);
- Contact details (including addresses, email and phone numbers);
- Details of assets and liabilities of all types;
- Centrelink and other government agency information;
- Bank account details;
- Superannuation membership, balance and contribution history;
- Occupation and salary details;
- Family details (including dependants);
- Level of insurance cover;
- Level of general insurance held; and
- Sensitive health information about you if you have applied for insurance cover or lodged a claim for an insurance benefit with us or an insurer.
4. To whom do we disclose your personal information?
There are some instances when we will need to provide your personal information to third parties. These third parties include:
- Insurers, medical consultants; professional advisers, financial institutions, lawyers, mailing houses, auditors and external service providers who are contracted by us for the purpose of providing the services;
- Dispute resolution bodies such as the Australian Financial Complaints Authority (AFCA) and the Office of the Australian Information Commissioner (OAIC) for the purpose of dispute resolution;
- External research houses to assist us in the provision of services and product research;
- Togethr Trustee Pty Ltd, because it provides business services to us;
- International government agencies where expressly required by law; and
- Government agencies such as the Australian Prudential Regulation Authority (APRA), the Australian Transaction Reports Analysis Centre (AUSTRAC), the Australian Securities and Investments Commission (ASIC), the Australian Taxation Office (ATO) and other bodies where expressly authorised by law.
Outside of these disclosures, your information is kept confidential and is only disclosed to you or to your authorised representative. An authorised representative is a person to whom you have given consent to access your personal information and may include a lawyer, spouse or legal personal representative.
Whenever we disclose your personal information to a third party, we seek to ensure that your privacy is protected to the same standards as required by us.
5. Do we disclose personal information overseas?
We utilise the services of a financial planning software provider, Iress, who has offices located in the European Economic Area, Singapore and South Africa. Information that you share with us may be stored on servers located in and/or disclosed to recipients in these overseas locations.
More information about whether there may be overseas disclosure of your personal information can be found below. We will still only disclose and collect your information in accordance with Australian laws and standards, including the Australian Privacy Principles.
- European Economic Area
- South Africa
6. How do we keep your personal information secure?
We have security measures in place and take all reasonable steps to ensure that your information in both hard copy and electronic format is stored in a secure environment and protected from misuse, interference or loss, and from unauthorised access, modification or disclosure.
Our information technology systems use up-to-date security software and hardware and virus protection. Your personal information is also protected through the use of secure passwords, usernames and different levels of access. At all times, access to your information is restricted to staff who require the information to administer your account and provide information and services to you. It is also restricted through the use of security identification checks performed by staff before any disclosure of personal information over the phone. We train our staff who handle personal information on the importance of protecting the personal information and the privacy of individuals.
In certain circumstances we are required to collect government identifiers such as a tax file number, Medicare number or pension card number. We do not use or disclose this information other than when required or authorised by law or unless you have consented to disclose this information to a third party.
As required under the Privacy Act, when we no longer need the information for any purpose and it is not required under Australian law to retain the information, it is destroyed in a secure manner or deidentified. This includes the secure disposal and erasure of hard copy and electronically stored personal information.
7. How can you access your personal information?
You will, with limited exceptions, be able to access the personal, sensitive and health information that we hold about you by either making an appointment to come to our office to view it personally, calling to request a copy of the information, or by sending us a written request. You will not be charged for accessing your personal information, however, if we incur a cost in giving you access to your personal information, we may need to charge you a reasonable fee for the associated costs.
We will aim to respond to requests for access within 30 days. Requests should be made to the Manager, Financial Planning (see contact details below). In certain circumstances, we may not be able to grant you access to the personal information that we hold about you if doing so would unreasonably impact the privacy of other individuals or would undermine legal proceedings or negotiations currently in progress. If your request is refused, we will notify you with reasons for the refusal.
8. How can you correct your personal information?
In order to provide financial planning services to you, we rely on your personal information being complete, up-to-date and accurate. If you believe that any of the personal information that we hold about you is incorrect, you can contact us to request that we amend the information.
Requests can be made to the Manager, Financial Planning (see contact details below). We will take reasonable steps to ensure that the information is corrected.
9. How can you manage your communications with us?
Unless you have asked us not to, we will from time to time send you communications about products or services that may impact your financial planning arrangements, or other opportunities that we think may be of interest to you.
If you no longer wish to receive such information, you can opt out by contacting us to update your details, or click the unsubscribe link within the email you received.
10. What information do we collect when you browse on our website?
If you decide to delete or block certain cookies, your experience on our websites may be limited or you may discover that some parts of the website will not work correctly (or at all), especially where cookies are used for security and fraud detection functions.
In using cookies, we do not try to identify you or your browsing activities. We also do not collect data from user-based cookies when a user accesses our website from within the European Union.
11. How can you make a complaint regarding your privacy?
If you wish to make a complaint about a possible breach of your privacy or of the Privacy Act, please contact the Manager, Financial Planning (see contact details below). The Manager, Financial Planning will work together with our Complaints Officer to ensure that the matter is resolved. Please provide sufficient details for your complaint to be investigated.
If your complaint is not resolved to your satisfaction within 30 days, you can lodge a complaint with our external dispute resolution agency, the Australian Financial Complaints Authority (AFCA), or with the Office of the Australian Information Commissioner (OAIC).
12. Contact details
You can contact us in relation to any client rights as follows:
The Manager Financial Planning
Post: Level 12, 330 Collins Street Melbourne VIC 3000
Phone: 1800 065 753
For specific enquires about privacy please contact:
The Privacy Officer
Post: Level 12, 330 Collins Street Melbourne VIC 3000
Phone: 1800 065 753
Updated July 2022