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Your Privacy with Insight Investment Services
Our privacy assurance to you
At Insight Investment Services your privacy is important to us. From 21 December 2001 new privacy laws apply to how we collect, maintain, use and disclose your personal information. We comply with these new laws.
This document explains how the new laws affect Insight Investment Services 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 serviced or 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 document.
What information does Insight Investment Services 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 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, ban 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.
- we collect information about you for the purpose of reporting to AUSTRAC under the Anti-Money Laundering and Counter Terrorism Act 2006. This information will be held securely on your file.
All information sought is required for our business purposes, which is detailed in this document.
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 a representative for others when collecting information about you, such as for the insurer underwriting insurance products (‘the Insurer’) or on behalf of other parties eg Fund Managers or ‘Institutional Business clients’ when placing Managed Funds and investments such as Superannuation.
We may also assist you in preparation of Wills or other Estate Planning initiatives by collecting information about you to be passed on to a law firm agreed to by you.
How do we collect your information?
Generally, we only collect personal information about you from you, unless it is not reasonable or practical for us to do so, or if you consent. For example, we may collect information from a third party like your employer for superannuation purposes, or you may be named as a beneficiary in another application for one of our products or services. We may also collect information about you from other members of Insight Investment Services or other companies associated with the Davies Knox Maynards Group, or from a publicly available source.
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 or Risk Protection 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 and conducting confidential systems maintenance.
If you acquire products or services from a member of Insight Investment Services or other companies associated with the Davies Knox Maynards Group, your personal information may also be used by other members of Insight Investment Services to analyse products and services which allows us then to fully evaluate all the needs of our customers. 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 Insight Investment Services or other companies associated with the Davies Knox Maynards Group, or use that information ourselves, to inform you of products and services offered by any member of Insight Investment Services or other companies associated with the Davies Knox Maynards Group or other supplier 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. Sometimes the law requires or allows us to give out information about you. For example, we must give 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, if it is necessary we may also disclose your personal information to:
- 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
- anyone who holds amounts on your behalf which will be transferred to, from or by 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
If you acquire a product or service for which we act as an Authorised Representative, Administrator, Trustee, Responsible Entity, Custodian or Operator on behalf of an Institutional Business client, we may disclose personal information about you to that Institutional Business client without getting your consent. Similarly, for insurance or investment products, we may disclose personal information about you to the Insurer or Fund Manager without getting your consent. These parties are required to comply with the privacy laws in using any such information.
Use of your personal information by Institutional Business clients
If you acquire a product or service for which we act as an Authorised Representative, Administrator, Trustee, Responsible Entity, Custodian or Operator on behalf of an Institutional Business client, that Institutional Business client may use personal information about you for purposes as disclosed in its own privacy policy and in the disclosure document for the product or service you choose.
You can obtain a copy of the relevant Institutional Business client’s privacy policy by contacting them directly or through us.
Use of your personal information by the Insurer
If you acquire an insurance product underwritten by the Insurer, the Insurer may use personal information about you for purposes as disclosed in its own privacy policy and in the disclosure document for the product or service you choose.
You can obtain a copy of the Insurer’s privacy policy by contacting the Insurer directly or through us.
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, and in electronic database requiring logins and passwords for access and/or at a secured warehouse. We require all staff to maintain the confidentiality of customer information.
We use secure methods to destroy or de-identify 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 document 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, fulfil 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 Policy.
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 permitted 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, that 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.
Opting out of receiving marketing information
If we send you any information about services or products, or you do not want us to disclose your personal information to any other organisation (including related bodies corporate), you can opt out by contacting an Insight Investment Services representative as mentioned in your Lifestyle Assessment and Financial Overview form. Your details will be maintained on our ‘Opt Out’ Register.
If there is anything you would like to discuss, please contact us
If you have any questions or concerns about our privacy policy or practices, please contact:
> Insight Investment Services
PO Box 6640
Upper Mt Gravatt QLD 4122
> Phone: 07 3340 3888
> Fax: 07 3422 1766
We will try to answer any questions you may have, correct any error on our part or resolve any complaint that you may have about our information handling practices. If we do not resolve a complaint to your satisfaction, you also have the right to complain to the Privacy Commissioner.
INSIGHT INVESTMENT SERVICES PTY LTD
ABN: 22 122 230 835
AUSTRALIAN FINANCIAL SERVICES LICENSEE 309996
Version 3 - 01/04/2008
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