Aylesbury Financial Group Pty Ltd
Your privacy is important to us. This policy explains how we handle, store and use your personal information. Aylesbury reviews its policies, statements and procedures to keep up to date with changes in the law, technology and best practice. As a result, we may update and change this Privacy Policy.
Collection of Personal Information
As a financial planning organisation we are subject to legislative and regulatory requirements which necessitate us obtaining and holding detailed information which personally identifies you and/or contains information or an opinion about you (“personal information” and “sensitive information”). Our ability to provide you with comprehensive advice is dependent on us obtaining certain personal information or sensitive information about you, including:
- ID information including names, addresses, phone, email address;
- Personal details including date of birth, associated entities, visa and residency status;
- Financial details including TFN, financial needs and objectives;
- Details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, insurance cover and superannuation;
- Investment preferences including past experience and risk preference;
- Health information including personal and family medical history, smoking status, lifestyle pursuits;
- Occupation details including employment history, employment circumstances, family commitments and social security eligibility;
- Relationship details including marital status, sexual orientation and estate planning details;
- Other information we think is necessary
How we collect personal information
Where reasonable and practicable, we shall only collect personal information about you, from you, or as directed by you. Once we hold personal information we take reasonable steps to keep it accurate, complete and up-to-date.
We may with your consent collect information about you from other parties such as:
- Services providers, such as your insurer
- Accountants
- Family members or your appointed agent
- Regulators and government agencies, such as the Australian Tax Office
- Employers
- Brokers
Should we receive unsolicited personal information about you, if this information is not necessary for Aylesbury Financial Group Pty Ltd (Aylesbury) to perform our duties then this information will be de-identified or destroyed.
What if you do not provide us with the information that we request?
You may choose not to give Aylesbury your personal information. This may result in Aylesbury not being able to provide the most appropriate advice for your circumstances.
Sharing of personal information
We shall not use or disclose personal information collected by us for any purpose other than:
- The purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
- Where you have consented to such disclosure; or
- Where the National Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.
Other parties we may be required to share information with:
- Other staff of Aylesbury
- Australian Securities and Investments Commission (ASIC), Australian Prudential Regulation Authority (APRA), Australian Taxation Office (ATO)
- Other financial services organisations, including banks, insurance companies, superannuation funds, stock brokers, custodian fund managers, accountants.
Aylesbury will only disclose personal information of its clients to overseas recipients where such disclosure is required to give effect to the instructions of a client (for example, where a client receiving financial advice wishes to invest in overseas equities). It is not practical to list all countries to which this information may be disclosed due to the variety of overseas financial services available to clients.
Accessing and updating your information
How you can access your personal information
You can request access to your personal information held by us. In most cases, we will grant you the access after receiving sufficient information to verify your identity. Access requests can be made in writing, by email or by telephone using the contact details in the Contact us section below.
Fees will not be charged to request or provide you with your personal information. However, if we are required to go through archived records this may incur a charge which will be discussed before proceeding.
Information will generally be provided within 30 days of successful verification of your identity.
Can we refuse to provide you with information?
In limited circumstances, we may deny access to the personal information or provide you with access to only some information. This could occur where the information requested is commercially sensitive or would breach the privacy of another person. Where we cannot provide you with information we will write to you to provide an explanation of the decision.
Updating your information
We will take reasonable steps to ensure that the personal information we hold is accurate, up to date, complete and relevant. If you believe your personal information requires updating, you can contact us over the phone, via email or post using the details under contact us.
Keeping your information secure
The security of your personal information is important to us and at all times we seek to ensure the information is secure and protected from misuse, loss and unauthorised access.
Aylesbury may hold your information in either electronic or hard copy form, and will destroy or de-identify personal information when it is no longer required or when we are no longer required by law to retain it (whichever is the later). In order to maximise the protection of data within our control Aylesbury educate our staff about their obligations with regard to your personal information. Access to personal information is only granted to those who require the information to perform their duties.
Aylesbury takes steps to establish and maintain practices, procedures and systems to ensure compliance with the Privacy Act 1988(Privacy Act) which includes the Australian Privacy Principals (APP). Due to the annual turnover of Aylesbury Financial Group Pty Ltd we are not required to report through the Notifiable data breach scheme (NDB), but Aylesbury chooses best practice principals in relation to Privacy.
Making a privacy complaint
If you are not happy with the way we handle your personal information, please contact us. You should contact us by any of the methods detailed below and request that your complaint be directed to the Privacy Officer. Your complaint will be considered within seven (7) days and we will provide you with a final response to your complaint within 45 days of receiving the complaint. If we cannot respond in this time, we will provide you with reasons why and what we are doing to try to resolve your complaint.
Other options if you are not satisfied with our response
If you are not satisfied with the response we provided to your complaint, you can approach the following free and independent dispute resolution services.
Under the Privacy Act you can complain to the Office of the Australian Information Commissioner about the way we handle your personal information:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone 1300 363 992
www.oaic.gov.au
The Australian Financial Complaints Authority (AFCA) can consider most complaints involving financial services providers:
Australian Financial Complaints Authority (AFCA)
GPO Box 3
Melbourne VIC 3001
Phone 1800 931 678
www.afca.org.au
