Privacy Policy

General

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.

Collection

Types of information collected

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:

  1. name, gender, address, date of birth, phone number, facsimile number, email address, bank account details, occupation, place and type of business;
  2. details of your financial needs and objectives, including in respect of financial planning, investment decisions and insurance policies;
  3. details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, insurance cover and superannuation;
  4. identification details such as your passport, Medicare and drivers’ licence, and tax file numbers;
  5. details of your marital status, financial dependants, and other familial situations and commitments;
  6. legal documentation such as trust deeds, company constitutions, company meeting minutes;
  7. financial documentation such as financial statements, balance sheets, profit and loss statements, tax returns, details of trust distributions;
  8. details of your investment preferences and aversion or tolerance to risk;
  9. details of your personal, investment and business objectives in the near and longer terms;
  10. personal information necessary for satisfying obligations in respect of obligations pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth); and
  11. other information relevant to providing you with the services you are, or someone else you know is, seeking.

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.


Method of collection

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.


Purpose of collection

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:

  1. providing services to you or someone else you know;
  2. preparing your financial plan;
  3. provision of financial planning advice to you as requested by you or from time to time as we believe appropriate;
  4. making securities and investment recommendations;
  5. reviewing your financial plan;
  6. reviewing securities and investment recommendations;
  7. responding to your enquiries;
  8. facilitating our internal business operations, including the fulfilment of any legal requirements;
  9. analysing our services and customer needs with a view to developing new or improved services;
  10. providing you with direct marketing material such as articles that may be of interest to you, however, you may, by contacting us, request not to receive such information and we will endeavour to give effect to that request within approximately two weeks of your request;
  11. providing you with material and other information about other services that we and other organisations that we have affiliations with, offer that may be of interest to you;
  12. providing you with information relevant to your type of business or other area of expertise or interest; or
  13. contacting you to provide a testimonial for us.

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.


Failure to provide information

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.


Internet users

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.

Our website uses cookies.  The main purpose of cookies is to identify users and to prepare customised web pages for them.  Cookies do not identify you personally, but they may link back to a database record about you.  We use cookies to monitor usage of our website and to create a personal record of when you visit our website and what pages you view so that we may serve you more effectively.

Use and disclosure

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:

  1. the FPAA, pursuant to our obligations under the Rules of Professional Conduct of the FPAA, for inspection by the FPAA on request to ensure ongoing compliance with mandatory professional standards;
  2. the Australian Securities and Investments Commission (ASIC), pursuant to our obligations under the Corporations Act 2001 (Cth) to maintain certain transaction records and make those records available for inspection by ASIC;
  3. superannuation fund trustees, insurance providers, and product issuers for the purpose of giving effect to your financial plan and the recommendations made by us;
  4. (in the event that we propose to sell our business) potential purchasers for the purpose of them conducting due diligence investigations, and in circumstances where 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;
  5. (in the event that a sale of our business is effected) the purchaser of the business, and in circumstances where you, as a client, will be advised of any such disclosure; and
  6. third party service providers, who assist us in operating our business, and providing services to you (including information technology service providers) and these service providers may not be required to comply with our privacy policy.

Disclosure of personal information overseas 

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.

Security

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.

Access and correction

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.

Complaints and feedback

If you wish to make a complaint about a breach of the Privacy Act, the APPs or a privacy code that applies to us, please contact us using the details below and we will take reasonable steps to investigate the complaint and respond to you.

If after this process you are not satisfied with our response, you can submit a complaint to the Office of the Information Commissioner.  To lodge a complaint, visit the ‘Complaints’ section of the Information Commissioner’s website, located at http://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the Information Commissioner’s office.

If you have any queries or concerns about our privacy policy or the way we handle your personal information, please contact our privacy officer at:

Street address:  Level 16, 300 Queen Street, Brisbane QLD 4000

Email address:  advisers@goodmanwealth.com.au

Telephone:       07 3221 0333

Website:           https://www.goodmanwealth.com.au/

For more information about privacy in general, you can visit the Office of the Information Commissioner’s website at www.oaic.gov.au.