Updated Jan 2019, version 4
Australian Privacy Principles
EFDB Pty Limited is bound by the Australian Privacy Principles (APP) established under the Privacy Amendment (Enhancing Privacy Protection) Act.
What type of information does EFDB Pty Ltd hold?
As an organisation that variously provides risk, superannuation and / or financial planning advice, we are subject to legislative and regulatory requirements which necessitate us to obtain personal information about you, including s961B of the Corporations Act. This “personal information” may include the following: -
- Name and address
- Date of birth
- Contact details including telephone numbers
- Occupation and employment details including history
- Details of your financial needs and objectives
- Details of your current financial position including salary and other income, expenditure, assets and liabilities, risk protection, superannuation and other investments.
- Details of your risk preferences
- Details of your health
- Details of your social security eligibility and
- Details of your estate planning requirements
- Tax File Numbers.
However, you have a right to refuse us authorisation to collect information from a third party. We maintain a Register for those individuals not wanting direct marketing material.
You can deal with us anonymously or by using a pseudonym where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.
Our Website utilises cookies to provide you with a better user experience. Cookies also allow us to identify your browser while you are using our site – they do not identify you. If you do not wish to receive cookies, you can instruct your web browser to refuse them.
How does EFDB Pty Ltd use this information?
It is important for us to obtain this information as it enables us to provide appropriate and timely advice to our clients. Failure to obtain this information could well compromise the quality of advice provided to our clients.
We will only collect information from you in a face to face interview, by telephone or through the return of a data collection form. All information exchanged during meetings may be recorded for quality assurance and training purposes. We will not collect any information about you unless you knowingly provide it to us or authorise a third party to do so.
The personal information we collect about you is to enable us to provide the following services to you: -
- Preparation of advice regarding your life risk, superannuation or financial planning needs,
- Reviewing your current position with respect to life risk, superannuation, or financial planning,
- Making investment and securities recommendations,
- Considering any other areas relevant to your financial needs.
Although in certain circumstances we are required to collect government identifiers such as your 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 voluntarily consented to disclose this information to any third party
Without your consent we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or afflations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record.
This is subject to some exceptions including: the collection is required by law; and when the information is necessary for the establishment, exercise or defence of a legal claim.
Personal information will be treated as confidential information and sensitive information will be treated highly confidential.
We don't usually collect unsolicited personal information. Where we receive unsolicited personal information, we'll determine whether or not it would have been permissible to collect that personal information if it had been solicited. If we determine that collection would not have been permissible, to the extent permitted by law, we'll destroy or de-identify that personal information as soon as practicable.
Will EFDB Pty Ltd share this information with other companies?
Your personal information is generally held in your client file and on a computer database. We will at all times ensure that your personal information held by us is protected from misuse, loss, unauthorised access or disclosure. All computer-based information is protected through the use of access passwords. Data is backed up regularly and stored securely off site. Other measures taken are:
- Confidentiality requirements for our employees;
- Security measures for systems access;
- Providing a discreet environment for confidential discussions.
EFDB Pty Ltd shares information with its external services, product & compliance providers such as Associated Advisory Practice, insurance company administrators and underwriters, superannuation fund trustees and administrators and investment product managers and custodians.
Some of the recipients to whom EFDB discloses your personal information may be based overseas. It is not practicable to list every country in which such recipients are located but it is likely that such countries will include The Philippines and India. If this occurs, we will obtain your specific consent before such information is sent overseas.
We are required by law to share information with various regulatory authorities, examples of these are the ATO, Centrelink and ASIC. Additionally, your details may be shared and stored by related entities and / or our authorised representatives. We may also use your personal contact details for the purpose of providing you with direct marketing material, for example, newsletters, which we believe, may be of value to you. However, you may instruct us not to send this information to you. We are required to also collect certain information about you under the Anti-Money Laundering and Counter Terrorism Act 2006. This information will be held securely on your file and may only be divulged to others if required under the law.
EFDB Pty Ltd takes its obligations to protect your information seriously, this includes when we operate throughout Australia, as part of our operations some uses and disclosures of your information may occur outside your State or Territory and/or outside of Australia. We currently do not use outsourced providers, however, we may need to obtain your consent before this occurs.
It is a legislative requirement that we keep all personal information and records for a period of 7 years. Should you cease to be a client of ours, we will maintain your personal information on or off site in a secure manner for 7 years. After this, the information will be destroyed.
Finally, in the event that we propose to sell our business we may disclose your personal information to a potential purchaser in the course of them conducting due diligence investigations. All such disclosure will be in confidence and on the basis that no personal information will be used or disclosed by them. In the event our business is sold we may transfer your personal information to the purchaser of the business though you, as a client will be advised of any such transfer. EFDB Pty Ltd does not sell mail lists.
How would we handle a request for personal information?
Under the APP you are generally entitled to access the information we have about you. We will endeavour to respond to your request for information on a timely basis and, in the same manner in which you made the request.
We will always ask you to identify yourself to our satisfaction and provide us with a reason for asking for the information. We are entitled to charge a fee for providing information but, unless your request is time consuming or requires substantial reproduction of documents we will be unlikely to do so. If we do propose to charge a fee we will give you an estimate of the fee in advance. Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal.
Some exceptions exist where we will not provide you with access to your personal information if:
- providing access would pose a serious threat to the life or health of a person;
- providing access would have an unreasonable impact on the privacy of others;
- the request for access is frivolous or vexatious;
- the information is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
- providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
- providing access would be unlawful;denying access is required or authorised by or under law;
- providing access would be likely to prejudice certain operations by or on behalf of enforcement body or an enforcement body requests that access not be provided on the grounds of national security.
What if some of the information you hold is not accurate?
We will endeavour at all times to ensure that the personal information that we hold is accurate. If you believe that the information we hold is inaccurate or incomplete in any way, please contact us and provide evidence of the inaccuracy. If we accept that our information is wrong we will correct it.
If you provide inaccurate or incomplete information we may not be able to provide you with the products or services you are seeking.
How do I complain about breaches of privacy?
Please contact our Privacy Officer if you wish to complain about any breach or potential breach of your privacy rights. Our Privacy Officer will investigate the issue and determine the steps we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the determination of our Privacy Officer. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Australian Information Commissioner, www.oaic.gov.au.
How can I contact EFDB Pty Ltd?
|Call us:||Privacy Officer - 02 9223 0911|
|Fax us:||Privacy Officer - 02 9223 0922|
|Write to us:||
EFDB Pty Ltd, L13, 23 Hunter Street Sydney NSW 2000
Which companies are covered by this policy?
- EFDB Pty Ltd trading as Diamond Blue Financial Services