Acorn Financial Group Pty Ltd Privacy Policy

The Privacy Act and the National Privacy Principles (NPPs)

Acorn Financial Group has always valued the privacy of personal information. From 21 December 2001, we are bound by the Privacy Act 1988 (Cth). It sets out standards to be met in the collection, use, disclosure and handling of personal information.

About our Privacy Policy

This Privacy Policy outlines how we manage personal information. It applies to any personal information you provide to Acorn Financial Group and any personal information we collect, use, disclose or handle about individuals from other sources. It does not apply to our employee records which are not subject to the Act.

The Privacy Amendment (Private Sector) Act, 2000 sets out a number of National Privacy Principles (NPPs). Our aim is to both support and ensure that we comply with these principles. Further information on privacy in Australia may be obtained by visiting the website of the Office of the Federal Privacy Commissioner at http://www.privacy.gov.au.

As a financial services organisation we are subject to certain legislative and regulatory  requirements which necessitate us to obtain personal information about you, including s945A of the Corporations Act.

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.

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.

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.

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.

Why we collect personal information

We collect personal information to offer, provide, manage and administer the many financial services and products we and our group of companies are involved in.

These include insurance broking and claims management, risk management consulting, other forms of insurance services, employee benefits, superannuation and investment advisory services.

We also collect personal information to be able to develop and identify products and services that may interest you, conducting market or customer satisfaction research, developing, establishing and administering alliances and other arrangements with other organisations in relation to the promotion, administration and use of our respective products and services.

If, at any time, you do not wish to receive this information any further, you may contact us with this request . We will endeavour to meet your request within 14 days.

We maintain a Register for those individuals not wanting direct marketing material.

The usual type of personal information collected includes your name, postal or e-mail address, date of birth, financial details etc. We may also need to collect sensitive information about you in relation to life, information about your membership of professional or trade associations, health information, sexual preferences and criminal record.

In the event of that we propose to sell the business, we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. 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.

If you do not provide the information requested, we or those involved with the provision of the service or product, may not be able to provide the appropriate type or level of service or product.

How we collect personal information

We generally collect personal information directly from the relevant individual but in some cases we may collect it indirectly from a third party.

For example, an insured's representative may tell us about other persons wanting the benefit of our service or the relevant product such as a nominated driver, a director or officer or professional or other staff member.

Alternatively, we may collect through our own representatives, advisers or another third party, such as accountants, lawyers, insurers health care workers, publicly available sources etc.

You have a right to refuse us authorisation to collect information from a third party.

Who we disclose personal information to

We have a duty to maintain the confidentiality of our clients' affairs, including personal information. Our duty of confidentiality applies except where disclosure of personal information is with our client's consent or compelled by law.

We disclose personal information to third parties who we believe are necessary to assist us in providing, managing and administering the services we provide and products we are involved in.

For example:

• Our related companies and alliance partners who may wish to tell you about their services, products or promotional opportunities which may be of advantage to you, unless you tell us not to.
• Your representatives such as your lawyers, accountants, financial advisers etc.
• For banking and finance products - card producers, card schemes, credit and fraud reporting agencies, debt collection agencies, insurers, reinsurers.
•  For financial planning and investment products and trustee or custodial services - superannuation and managed funds organisations and their advisers and organisations in which you invest.
• For insurance broking and life insurance products - insurers, reinsurers, other insurance intermediaries, insurance reference bureaus, medical service providers, fraud detection agencies, our advisers such as loss adjusters, lawyers and accountants, and others involved in the claims handling process.
• As a financial service provider, we have an obligation under the Anti Money Laundering and Counter Terrorism Finance Act to verify your identity and the source of any funds. This means that we will ask you to present identification documents such as passports and driver’s license. We will also retain copies of this information. We assure you that this information will be held securely.
• We collect information about you for the purpose of reporting to AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

Your personal information may also be used in connection with such purposes.

What we expect of you

When you provide us with personal information about other individuals, we rely on you to have made or make them aware that you will or may provide their information to us, the types of third parties we may provide it to, the relevant purposes we and the third parties we disclose it to will use it for, and how they can access it (as described in this document).

If it is sensitive information we rely on you to have obtained consent to the above. If you have not done either of these things, you must tell us before you provide the relevant information.

If you collect, use, disclose or handle personal information on our behalf, or receive it from us, you and your representatives must meet the relevant requirements of the National Privacy Principles set out in the Privacy Act 1988 and only use and disclose it for the purposes we agreed to.

Security of your personal information

Your personal information may be stored in hard copy documents, as electronic data, or in our software or systems.

We endeavour to protect any personal information that we hold from misuse and loss, and to protect it from unauthorised access, modification and disclosure. Some of the ways we achieve this are:

• Confidentiality requirements on our employees
• Policies on document storage security
• Security measures for access to our systems
• Only providing access once proper identification has been given
• Controlling access to our premises

Transfer of information overseas

We may transfer your personal information overseas where it is necessary for the purposes described above. For example, some insurers are based overseas and we need to provide your personal information to them to arrange your cover.

Keeping information up to date and accessing it

We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect, disclose or use it.

We will, on request, provide you with access to information we hold about you, unless there is an exception which applies under the NPPs. Things that may affect a right to access include:

• Access would pose a serious threat to the life or health of any individual;
• Access would have an unreasonable impact on the privacy of others;
• A frivolous or vexatious request.
• The information relates to commercially sensitive decision making process.
• Access would be unlawful or denying access is required or authorised by law (e.g. we have a duty of confidentiality to our client's and will not provide access to personal information about you if it will breach that duty)
• Access would prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security function, or negotiations with the individual
• Legal dispute resolution proceedings

You can also gain access to correct or update your personal information.

If charges are applicable in providing access to you, we will disclose these charges to you prior to providing you with the information.

Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal.

Dealing with us Anonymously

Where lawful and practicable to do so you can deal with us anonymously e.g. general inquiries about the services we can offer you.

How to contact us

If you wish to gain access to your personal information, have a complaint about a breach of your privacy or you have any query on how your personal information is collected or used, or any other matter relating to our Privacy Policy you can:

• Speak directly with our staff who will do their best to try to resolve your issue as simply as possible.
• You can put your complaint in writing so the matter can be considered by our Privacy Officer.

We will respond to you as soon as reasonably possible.

For more information on privacy see the Privacy Commissioner's website http://www.privacy.gov.au