At GPS Wealth Limited, we recognise that your privacy is important. GPS Wealth includes all our financial planning, insurance, broking, finance, accounting, technological, superannuation and fund management affiliates.
We are bound by, and committed to supporting the National Privacy Principles (NPP). The information set out below is largely a summary of our obligations under the NPP.
At times it may be necessary for us to collect personal or sensitive information from you. The purpose of collecting personal information is to facilitate financial planning, provision of financial products or services, insurance policies or related services, and to update our records.
In collection this information, we will take reasonable steps to inform individuals as to:
- Why we are collection that personal information
- Who else we might disclose that personal information to
- What may happen if individuals do not provide personal information to us
- How to gain access to that information
Use and Disclosure
We are subject to certain legislative and regulatory requirements that necessitate us obtaining and holding detailed information that personally identifies you and/or contains information or an opinion about you. In addition, our ability to provide you with a comprehensive financial planning and advice service is dependent on us obtaining certain personal information about you, including:
- Employment details and employment history;
- Details of your financial needs and objectives;
- Details of your investment preferences and aversion or tolerance to risk;
- Details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, etc;
- Information about your employment history, employment circumstances, family structure, commitments and social security eligibility;
- Any other relevant information including medical history and/or reports required for the purposes of risk insurance.
GPS Wealth Limited may use the personal information collected from you for the purpose of providing you with direct marketing material such as articles that may be of interest to you. You may, by contacting us by any of the methods detailed in this policy statement, request not to receive such information and we will give effect to that request. Please allow two weeks for your request to be actioned.
Pursuant to the Corporations Act and Life Insurance Code of Practice, we are required to collect sufficient information to ensure appropriate advice can be given in respect of recommendations made to our clients. If you elect not to provide us with the personal information you may be exposed to higher risks in respect of the recommendations made to you and this may affect the adequacy or appropriateness of advice given to you.
We take reasonable steps to protect the information we retain from misuse, loss and from unauthorised access, modification or disclosure. We will not retain any of your information for any longer than it is required by us, except to satisfy legal requirements. We will destroy or de-identify your personal information when it is no longer required.
We also ensure data security and privacy by:
- Ensuring that personal records and documentation remains separated on a person by person / client by client basis
- Taking necessary steps to ensure that we protect any personal information that we obtain. We have controls in place where only certain groups or certain levels of authority can access particular information
- Not disclosing your information to third parties, unless there has been prior written consent by you
- Ensuring that your client files are stored appropriately in a secure place
- Maintaining client confidentiality. Although advisers are the main people that will deal with your information, if GPS employees or officers have access to any client information it must be kept confidential at all times
- Not revealing or discussing any suspicious transaction reports that may have been made about a client and are being investigated, except where required by law
If advisers receive any legal requests for you, for example, from authorities such as ASIC, the Family Law Courts, the Australian Police, they should contact GPS Wealth Head Office immediately before disclosing any information.
We may use and disclose personal information for the purposes for which it was provided or secondary purposes in circumstances where you would reasonably expect such use or disclosure.
The information we collect from you may also be disclosed to third parties if the disclosure is required by or permitted by law or in accordance with the rules and policies of the Association of Financial Planners.
In the event that we propose to sell our business we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Any such disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them. In the event that a sale of our business is affected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer.
Access and Correction
You may have the right to access and request corrections of the personal information held by us. You may access the personal information we retain and request corrections. This right of access is subject to some exceptions allowed by law.
We will not provide you access to personal information which would reveal any confidential formulae or the detail of any in-house evaluative decision making process, but may instead provide you with the result of the formulae or process or an explanation of that result.
GPS Wealth Limited reserves the right to charge a fee for searching for and providing access to your personal information. In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal.
We will endeavour to ensure that at all times the personal information about you that we hold is up to date and accurate. The accuracy of the personal information is dependant to a large degree on the information you provide and you should advise us if there are any errors in your personal information.
In some circumstances we are required to collect government identifiers, for example, your Tax File Number (TFN's). We will not use or disclose this information other than when required to do so by law or, when consented to by you.
We require that when collection TFN's that they are kept appropriately. It is permissible under section 17 of the TFN Guidelines to retain TFNs where there is an on-going requirement on condition that:
- TFNs are held in a secure environment; and
- TFNs are destroyed when they are no longer required.
You may deal with us anonymously where it is lawful, practicable and reasonable to do so.
Without your consent, for example where information is provided by you for insurance and or risk purposes, we will not collect sensitive information about you. Exceptions to this include where the information is required by law, or for the establishment, exercise or defence of a legal claim.