The collection of personal information about individuals by organisations is governed by the Privacy Act 1988 (the Privacy Act) which contains a national scheme for the collection, use, correction, disclosure and transfer of personal information by organisations in the private sector.
The Policy explains our policies and practices with respect to the collection and management of personal information we collect from you.
The Privacy Act requires us to handle your personal information in accordance with a set of principles, known as the Australian Privacy Principles (APPs). Those Principles and our approach to those Principles are set out below.
The Policy applies to Intello Pty Ltd, together referred to in this Policy as “Intello”, “us”, “our”, or “we”.
We will collect and hold your personal information for the purposes of:
- Providing products and services to you
- Managing and administering the products and services
- Letting you know about our other products and services
The type of information collected from you includes information that is necessary to operate your account or for us to provide advice to you. We may ask you to provide personal information such as your:
- Email address
- Residential and/or postal address
- Date of birth
- Contact details
- Bank account details
- Financial details
- Tax File Number (TFN)
Much of this information is collected through application forms, the use of our online facilities or through ongoing communications with you.
We will not collect any personal information about you except where you have knowingly provided that information to us or we believe you have authorised a third party to provide that information to us.
The company will only collect sensitive information where you consent to the collection of the information and the information is reasonably necessary for one or more of the Company’s functions or activities. Sensitive information includes, but is not limited to, information or an opinion about racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, membership of a trade union, sexual preferences, criminal record, health information or genetic information.
We will always seek your consent before collecting this kind of sensitive information.
We may also need to collect information from third parties. For example, we may need to collect information from your financial adviser, product issuer and employer.
We are also required to ask for certain information by law. Wherever there is a legal requirement for us to ask for information about you, we will inform you of the obligation and the consequences of not giving us the requested information. For example, in addition to obtaining personal information from you, whenever you acquire a new product or service from us, we will need to obtain certain documentary evidence from you as to your identity. Such evidence may include items such as a certified copy of your driver’s licence, passport or birth certificate.
The Company must collect personal information only by lawful and fair means. The Company will collect personal information directly from you if it is reasonable or practicable to do so.
The Company may collect personal information in a number of ways, including without limitation:
- Through application forms
- By email or other written mechanisms
- Over a telephone call
- In person
- Through transactions
- Through our website
- Through surveillance camera
- Through publicly available information sources (which may include the internet and social media sites)
- Direct marketing database providers
- By technology that is used to support communications between us;
Anonymity and Pseudonymity
You have the option of not identifying yourself, or using a pseudonym, when dealing with the Company in relation to a particular matter. This does not apply
- Where the Company is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves; or
- Where it is impracticable for the Company to deal with individuals who have not identified themselves or who have used a pseudonym.
However, in some cases if you do not provide the Company with your personal information when requested, the Company may not be able to respond to your request or provide you with the goods or services that you are requesting.
How do we use the information that we collect from you?
We use your personal information for the purposes for which it has been obtained. We collect your personal information so that we are able to act on your request, such as:
- Provide financial advice to you
- Establish and manage your investments and accounts
- Implement your investment instructions
- Provide accounting, taxation and audit services to you
- Establish and maintain insurance protection
- Process contributions, transfer monies or pay benefits
- Report the investment performance of your account
- Keep you up to date on other products and services offered by us.
Personal information will also be used where you have consented to such disclosure or where it is required or authorised under law, in circumstances relating to public health and safety or in connection with certain operations by or on behalf of an enforcement body.
We are generally exempt from the Privacy Act when it collects and handles employee records. However, Intello’s policy is to protect the personal information of its employees as it does other personal information.
An employee record is a record of personal information relating to the employment of an employee. Examples of personal information relating to the employment of the employee include, but are not limited to, health information and information about the engagement, training, disciplining, resignation, termination, terms and conditions of employment of the employee. Please see the Act for further examples of employee records.
Where personal information is disclosed there are strict controls in place to ensure information is held, used and disclosed in accordance with the APP’s.
The types of external organisations to which we often disclose your personal information include:-
- Any organisations involved in providing, managing or administering our products or services such as actuaries, custodians, external dispute resolution services, insurers, investment managers
- Your financial adviser
- Your employer (relates only to employer sponsored superannuation arrangements)
- Any fund (administrator or trustee) to which your benefit is to be transferred or rolled over
- Medical practitioners and other relevant professionals, where you have applied for insurance cover or made a claim for disablement benefit
- Your personal representative, or any other person who may be entitled to receive your death benefit or any person contacted to assist us to process that benefit
- Any financial institution who holds an account for you
- Any professional advisers appointed by us
- Businesses that may have referred you to us (for example your Credit Union or Bank)
Like other financial services companies, there are situations where we may also disclose your personal information where it is:-
- Required by law (such as to the Australian Taxation Office)
- Authorised by law (such as where we are obliged to disclose information in the public interest or to protect our interests)
- Necessary in discharging obligations (such as to foreign governments for the purpose of foreign taxation) required to assist in law enforcement (such as to a police force)
We will also disclose your information if you give your consent. We do not disclose your personal information overseas.
Access and correction of information
You may request access to the personal information we hold about you. We will not charge you for responding to such a request, unless costs are incurred in providing the information.
There may be circumstances where we are unable to give you access to the information that you have requested. If this is the case we will inform you and explain the reasons why.
We will take reasonable steps to ensure that the personal information we collect, hold, use or disclose is accurate, complete, up to date, relevant and not misleading.
You have a right to ask us to correct any information we hold about you if you believe it is inaccurate, incomplete, out of date, irrelevant or is misleading. If we do not agree with the corrections you have supplied and refuse to correct the personal information, we are required to give you a written notice to that effect and a statement if requested. If you wish to access your personal information, you should contact us through our offices or by writing to the Privacy Officer. Details of how to contact the Privacy Officer are set out below.
How do we protect the security of your information?
The Company will take such steps (if any) as are reasonable in the circumstances to ensure that the personal information that it:
- Collects is accurate, up to date and complete; and
- Uses or discloses is, having regard to the purpose of the use or disclose, accurate, up to date and complete.
The Company will take steps as are reasonable in the circumstances to protect the personal information from misuse, interference, loss and from unauthorised access, modification or disclosure.
Risks of using the internet
You should note that there are inherent security risks in transmitting information through the internet. You should assess these potential risks when deciding whether to use our online services. If you do not wish to transmit information through our website, please feel free to contact Intello by telephone or post.
How long do we retain your personal information?
We are required by law to retain certain records of information for varying lengths of time. Depending on the context surrounding the information, we may be required to retain records which include your personal information from 7 years to permanently. Where your information is not required to be retained under law, we will take reasonable steps to permanently destroy or de-identify your personal information when it is no longer required for the purpose for which it was collected.