Goodman Private Wealth Ltd ACN 009 938 514 and its related bodies corporate (referred to in this document as we, us or our) is committed to protecting the personal information it collects from you. However, we are not required to comply with the provisions of the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) and while not purporting to be a statement of compliance with the Privacy Act, this document sets out how we will manage your personal information.
We may collect and hold personal information about you, that is, information that can identify you, and is relevant to providing you with the services you are seeking.
The kinds of information we typically collect include:
We may also collect sensitive information where reasonably necessary for one or more of our functions or activities. This may include information about your health and any health conditions.
Personal information will generally be collected directly from you through the use of any of our standard forms, from documents you provide to us, by your other professional advisers where you have provided your express permission, via face-to-face interviews, over the internet, via email, or through a telephone conversation with you. We may also collect personal information about you from third parties acting on your behalf.
There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect personal information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
The personal information that we collect and hold about you depends on your interaction with us. Generally, we will collect, use, and hold your personal information if it is reasonably necessary for or directly related to the performance of our functions and activities and for the purposes of:
Except as otherwise permitted by law, we only collect sensitive information about you if you consent to the collection of the information and if the information is reasonably necessary for the performance of our functions, as set out above.
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, are seeking. Failure to provide certain requested personal information may expose you to higher risks in respect of the recommendations made to you and may affect the adequacy or appropriateness of advice we give to you. As we are required pursuant to the Corporations Act 2001 (Cth) and Rules of Professional Conduct of the Financial Planning Association of Australia (FPAA) 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 certain requested personal information, we may elect to terminate our service agreement with you if we believe we are unable to provide you with a complete service.
If you access our website, we may collect additional personal information about you in the form of your IP address and domain name.
Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.
Generally, we only use or disclose personal information about you for the purposes for which it was collected (as set out above); secondary related purposes in circumstances where you would reasonably expect such use or disclosure; where you have consented to such disclosure; where you have consented to such disclosure; or as authorised under law. We may disclose personal information about you to:
We may disclose your personal information overseas to our third party service providers or other recipients located in the United States of America, in order to provide you with the services.
We store your personal information in different ways, including in paper and in electronic form. The security of your personal information is important to us. We take all reasonable measures to ensure that your personal information is stored safely to protect it from interference, misuse, loss, unauthorised access, modification or disclosure, including electronic and physical security measures.
We take reasonable steps to treat your personal information (including sensitive information) as confidential. All paper files are stored at our office premises which is locked out of hours. Access to our premises is controlled. All record movements off premises are recorded in a central register. All computer-based information is protected through the use of access passwords on each computer and screen saver passwords. Data is backed up each evening and stored securely off site.
In the event you cease to be a client of ours, any personal information which we hold about you will be maintained in a secure off site storage facility for a minimum period of seven years in order to comply with legislative and professional requirements, following which time the information will be destroyed.
You may access the personal information we hold about you, upon making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making the request for access).
We may decline a request for access to personal information in circumstances prescribed by the Privacy Act, and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.
If, upon receiving access to your personal information or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.
If we refuse to correct your personal information, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.