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Today is
Privacy Policy
[ 13 Jan 2004 ]
Our Commitment
At Cochrane Shaw Capital Management Pty Ltd (CSCM) we recognise that your privacy is very important. As a financial planning organisation we are subject to certain legislative and regulatory requirements which necessitate us obtaining and holding detailed information which personally identifies you. By personal information we mean information or an opinion about you where your identity is apparent or can reasonably be ascertained.
We are bound by, and committed to supporting, the National Privacy Principles (NPP's) set out in the Privacy Amendment (Private Sector) Act 2000. A copy of these NPP's can be obtained by contacting us. Our aim is to ensure that we comply with the NPP's that form the basis of laws introduced to strengthen your privacy protection. The information set out in this Privacy Policy is a summary of our obligations under the NPP's and how they will affect you as a client of CSCM.
We believe that this Privacy Policy will address any potential concerns you may have about how personal information you provide CSCM is collected, held, used, corrected, disclosed and transferred. You can obtain more information or clarify any areas about the way we manage the personal information we hold. This can be done by contacting our Privacy Officer via any of the ways listed under the Contact Us section of this document.
All staff of CSCM are covered under this Privacy Policy, and will collectively be referred to as CSCM. Staff do not act independently, but are representatives of CSCM, who are bound to behave in accordance with this and other policies as a condition of their employment.
Collection
Your personal information will be collected by your adviser or other staff of CSCM and held by CSCM, a licensed securities dealer and registered life insurance broker. Our ability to provide you with a comprehensive financial planning and advice service is dependent on us obtaining certain personal information about you.
Generally collection of your personal information will be effected in face to face interviews, over the telephone or by mail and email. From time to time additional and/or updated personal information may be collected thought one or more of those methods.
The type of personal information we collect includes:
- your name, contact details and date of birth;
- employment details and history;
- financial details including information about your financial needs and objectives, your current financial circumstances including your assets and liabilities, income, expenditure, insurance cover and superannuation;
- details of your investment preferences and risk tolerance;
- family circumstances and social security eligibility which may include reference numbers;
- bank account details;
- Tax File Number;
- your interests and hobbies;
- health information;
- any other information that we consider necessary.
We will only collect sensitive information, such as health information or information about your membership of a professional or trade association, if it is required to perform our duties and consented to by you, or the collection is required by law. All health information will be collected in accordance with rules established by competent health or medical bodies that deal with obligations of professional confidentiality.
Our main purposes for collecting your personal information include:
- to provide you with financial advice that you request and that is suitable for your investment objectives, financial situation and particular needs;
- to review your financial plan;
- to complete forms and applications on your behalf;
- to manage our relationship with you;
- to contact you about products and services in which you may be interested and which we believe are relevant to your situation.
We will only collect personal information from you that is necessary for one or more of our functions and activities. This primary purpose of collection will be established from the breadth of advisory services as agreed to between you and your adviser. The primary purpose may be wide (eg. a complete review of your financial situation) or limited (eg. advice on your superannuation). We will not give out advice or make recommendations without considering your situation. You have the option to provide us with your limited personal information, however this may mean that we are unable to provide services to you fully and properly.
We will only collect personal information for you by lawful and fair means, without being unreasonably intrusive, such as when you complete forms or applications. Due to the nature of our relationship, we are not able to deal with you anonymously. Where reasonable and practicable, we will only collect personal information about you, from you. The exception to this is if you have authorised the collection from a third party, if you are under 18 years of age (where we will deal with your parents or guardians) and when you have a Power of Attorney who deals with us on your behalf.
At or before the time we collect personal information from you we will take reasonable steps to inform you why we are collecting that personal information, who else we might disclose that personal information to and what will happen if you do not provide that personal information to us.
If we are referred to you by a third person we will not use any information we receive about you without your consent and verification of the details. We will take reasonable steps to inform you about who we are and how we can be contacted, along with other details about the way we deal with your personal information.
Use and Disclosure
We will not use or disclose your personal information collected by us for any purpose other than:
- the purpose for which it was provided or a related purposes in circumstances where you would reasonably expect such use or disclosure;
- where you have consented to such disclosure;
- 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.
- where required to comply with legal requirements of our Australian Financial Services Licence.
In the process of performing our job as your financial adviser, it may be necessary to give information about you to third parties. The main reason for this will be when dealing with other financial institutions for the purpose of giving effect to your financial plan and the recommendations made by us. By signing an application with a superannuation fund trustee, insurance provider or product issuer, you are consenting to them retaining the information you have provided. They may also be in contact with CSCM to obtain additional information which is required to effect or maintain your relationship with them. While there is certain information that you must provide to have your application processed, the provision of some information is optional. You should carefully read the prospectus, including any privacy information, before you chose to proceed. CSCM has obtained the privacy policies of all third party companies that we deal with. Copies of these may be obtained by contacting the Privacy Officer.
Other third parties who may request information from CSCM about you include your other advisers i.e. accountant or solicitor. We require that you sign an authority form allowing us to disclose information to these people. In some cases we are asked to provide or accept information from clients' relatives, friends or other third parties. We can not do this without your written consent. If you require us to deal with third parties please contact the Privacy Officer to obtain an authority form. When we establish a relationship with you we will ascertain if you wish your personal information to be shared with your partner or spouse. In all cases any changes to your accounts, including redemptions and switches, will need to be confirmed by your signature.
We do not use external providers to assist with any of our business functions. There may be reason to disclose information to an outside party in order to fulfil the requirements of our Australian Financial Services Licence, including such times as when we are audited or to ensure compliance with certain organisations including the Financial Planning Association of Australian Limited and the Australian Securities and Investments Commission. We may also disclose your personal information to government authorities and other organisations when required by law.
All staff of Cochrane Shaw Capital Management Pty Ltd have access to your information. If you want your file to remain private to everyone except your adviser please notify the Privacy Officer. Please note that in this case you may not be able to receive the same level of service, as your file will not be available when your adviser is inaccessible.
In relation to marketing, we will seek your consent before we use your personal information for this purpose. You may tell us at any time you do not wish to receive any further marketing materials - if you do, we will stop sending you such materials.
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 CSCM is sold, we may transfer your personal information to the purchaser of the business. As a client of CSCM you will be advised of any such transfer.
Access and Correction
If you ask, we will tell you what personal information we hold about you, and what we do with it. We will facilitate access to you by allowing an inspection of your personal information, including your physical file and all computer records. You can inspect your information in person or we can provide copies or a summary of the relevant documents, depending on what you request and what is most appropriate.
Clients wishing to obtain their information must make a written request to the Privacy Officer, including the type of information required. This request will be acknowledged within 7 days, and you will be able to have access within 14 days, excluding when access is denied. Note that we need not provide access to personal information in several types of situations, for example where a request is frivolous, would unreasonably interfere with another person's privacy, relates to existing or anticipated legal proceedings, or would be a breach of the law. If we refuse access we will advise you in writing of our reasons for doing so. There may be a charge payable by you to obtain your information, although there will be no charge to lodge the request. Any charge we make for providing access will be reasonable. Further information can be obtained from the Privacy Officer.
We endeavour to take reasonable steps to ensure that the personal information that we collect, use or disclose is accurate, complete and up-to-date. If you believe that any of the personal information that we hold is not accurate, complete or up-to-date please contact us and provide us with evidence to show this. If you can show us that your personal information requires correcting we will take reasonable steps to do so. If we do not correct your personal information we will provide you with the reason for this, and you may request that we attach with your information a statement claiming that the information is not accurate, complete and up-to-date. We endeavour to keep your personal information accurate at all times.
Security and Storage of Information
We will protect personal information from misuse and loss, unauthorised access, modification and disclosure and destroy or permanently de-identify any personal information that we no longer need. This includes information stored both in your file and on our computer system.
Your personal information is:
- stored in our secure office premises;
- stored in a secure offsite storage facility;
- stored in our secure electronic client databases, requiring passwords for access; and
- subject to strict employee guidelines in relation to access and use.
In the event you cease to be a client of CSCM any personal information which we hold about you will be maintained either in our office or in a secure offsite storage facility for a period of seven years in order to comply with legislative and professional requirements, following which time the information will be destroyed.
Web Page
If you choose to contact CSCM via our webpage we will respond to you through the means requested. We will not use your details for any other purpose, unless you consent, apart from this initial contact.
When you visit our website, details (known as cookies) may be recorded about your visit, such as the time and date, your server address, pages accessed, time spent and type of browser. This information is used in an anonymous form for statistical purposes and as such cannot identify you individually.
Identifiers
We will not adopt as our own any identifiers that have been assigned by a Commonwealth government agency or contracted service provider that you have provide to us such as your Tax File Number or Medicare number.
Sending Data Overseas
We will not send any personal information about you overseas unless you consent to this in writing, or we reasonably believe that the other country has privacy laws substantially similar to our own, or we provide the information in other circumstance giving like protection.
Complaints Resolution
We are committed to providing clients with a fair and reasonable system for the handling of their complaints.
If at any time you have complaints in relation to privacy, please contact our Privacy Officer. We will seek to address any concerns that you have through our complaints handling processes, but if you wish to take matters further you may refer your concerns to the Office of the Federal Privacy Commissioner;
Email Address:
privacy@privacy.gov.au
Postal Address:
GPO Box 5218
SYDNEY NSW 1042
Telephone Number: 1300 363 992
Fax Number: 02 9284 9666
Contact Us
If you seek any further information from CSCM about our Privacy Policy please contact our Privacy Officer, Andrew Cochrane, at one of the reference points below:
Email Address:
Postal Address:
PO Box 191
BLACKBURN VIC 3130
Street Address:
Suite 2
41 Railway Road
BLACKBURN VIC 3130
Telephone Number: 03 9894 3788
Fax Number: 03 9894 1015
Additional Privacy Information
Further information on privacy in Australia may be obtained by visiting the web site of the Office of the Federal Privacy Commissioner at www.privacy.gov.au
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