Date of issue: 1 September 2022

Anova Advice Group Pty Ltd

ABN              40 653 741 247| AFSL 537916

Address:       Level 5, 128 Bundall Road, Bundall QLD 4217

Phone:          (07) 5655 1099

Email:            info@anovaadvice group.com.au

Website:       www.anovaadvicegroup.com.au

 

1.0 Introduction

Anova Advice Group is committed to protecting your personal information.

Protecting our clients’ privacy is very important to us. To ensure our compliance with the Privacy Act and as part of our commitment to ensuring the safety of your private and confidential information, we have established and implemented this Policy.

We understand that the privacy of your information is important to you and we respect the confidentiality of the information that you provide to us. Protecting your information is an important part of maintaining trust between our clients and us and by handling information in a secure manner, we build strong business relationships.

This document provides information and details about how we manage the personal information that we collect, hold, use and disclose about individuals. The Privacy Policy applies to all organisations within the Licensee and all subsidiary companies which are set out at the end of this policy. We are bound by the Privacy Act and we apply the obligations contained in the Privacy Act and the Australian Privacy Principles to our practices for handling personal information.

 

2.0 Why we collect and use personal Information

Pursuant to the Corporations Act 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. Alternatively, we may elect to terminate our relationship with you if we believe we are unable to provide you with adequate service.

We collect, hold, use and disclose personal information so we can provide you with financial advice, services and products relevant to your needs. We may also collect, use and disclose your information for related purposes such as:

• Complying with legal and regulatory requirements;
• Verifying your identity for anti-money laundering and counter-terrorism financing purposes;
• Managing your ongoing requirements, our ongoing relationship with you and to improve our services;
• Assisting with your questions and complaints
• Arranging for services to be provided by third parties
• Internal operations, such as record keeping, data analytics, auditing or training
• Giving you educational information, newsletters or opportunities that we believe may be relevant to your financial needs and circumstances.
• Promotion of other products and services that may be of interest to you

We collect, use, hold and sometimes disclose personal information about financial advisers and other people who we do business with (including employees) in order to administer and manage our business operations. This information is afforded the same standard of care as that of our clients.

 

3.0 How we collect your personal information

Generally, we collect your personal information directly from you. We could do this in a number of ways, including through face to face interviews, email correspondence and other online mediums.

We may also collect personal information about you from third parties such as:

• other professionals who act on your behalf, such as a lawyer or accountant,
• a mortgage broker or other credit representative,
• health professionals,
• other organisations, who jointly with us, provide products or services to you, and
• social media and publicly available sites.

 

4.0 What personal information we collect

We ask people for a range of personal information to assist us in providing appropriate advice. The information we collect could include (but is not limited to):

• Name, address, date of birth and phone number;
• Details of your financial needs and objectives;
• Details of your investment preferences and risk tolerance;
• 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, health and lifestyle information required for the purposes of risk insurance.

It’s your choice whether to provide your personal information. You have the right to not to provide personal information, including about your identity. However, in this case, your adviser will warn you about the possible consequences and how this may impact on the quality of the advice provided. Your adviser may also decline to provide advice if they feel they have insufficient information to proceed.

Further, in some circumstances the law requires us to obtain and verify details of photographic and non-photographic identification documents.

 

5.0 Accessing and updating your personal information

You can request access to personal information we hold. There may be a cost involved with locating, copying or sending you the information you request. The cost will be discussed and agreed with you at the time.

There may be circumstances where we refuse to provide you with the information you request, for example when the information is commercially sensitive. In these situations, we will inform you and provide an explanation as to why.

We will deal with requests for access to your personal information as soon as possible and aim to respond within seven (7) business days. The time we require will depend on the type of information requested. We will update your personal information if you contact us. In most cases, you can update your personal information over the phone, by contacting your adviser or broker or electronically.

If you wish to remain anonymous or to use a pseudonym when dealing with us, we may only be able to provide you with limited information or services. In many cases it will not be possible for us to assist you with your specific needs if you wish to remain anonymous or use a pseudonym.

 

6.0 Disclosure of Personal Information

We will not use or disclose personal information collected by us for any purpose other than to perform the professional services you have contracted us to do. We will not use it for anything other than:

• The purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
• Where you have consented to such disclosure; or
• Where we are 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

Depending on the product or service concerned and particular restrictions on sensitive information, this means that personal information may be disclosed to:

• Other areas within our group who provide financial and related services;
• Financial planners, credit providers and brokers and those who are authorised by us;
• Service providers and specialist advisers to us who have been contracted to provide us with administrative, financial, insurance, accounting, legal, information technology, research or other services;
• Other insurers, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law;
• Credit reporting or reference agencies or insurance investigators;
• AUSTRAC, the government agency who oversees Anti Money Laundering and Counter Terrorism Financing;
• External dispute resolution bodies to handle your complaint; and
• Other companies in the event of a corporate sale, merger, reorganisation, dissolution or similar event.

Additionally:

• We may be required to make certain information available for inspection by Professional Associations which we or our Authorised Representatives are members of, as part of ongoing compliance with standards. This may involve the disclosure of your personal information.
• We are also obliged pursuant to the Corporations Act to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission.
• We may disclose your personal information to superannuation fund trustees, insurance providers, credit providers and product issuers for the purpose of giving effect to your financial plan and the recommendations made by us.
• In order to ensure that you receive a personal and tailored service, your personal information may be transferred to one of our authorised representatives who will be your primary point of contact.

It is a condition of our agreement with each of our representatives that they adopt and adhere to this Privacy Policy. If you have any concerns in this regard, you should contact us by any of the methods detailed below.

Generally, we require that organisations outside our group who handle or obtain personal information as service providers acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with the privacy law.

 

7.0 Disclosure of personal information overseas

We may disclose your personal information to service providers who operate outside Australia. These are Australian based companies that have locations in countries such as the Vietnam, Philippines & Malaysia. . The most common example of when we share your personal information overseas is when we work with overseas service providers who prepare financial advice documents

Your adviser may enter into their own outsourcing arrangements to countries other than those detailed above. If so, your adviser will disclose these arrangements separately to you. When we send your personal information to overseas recipients, Anova Advice Group has taken all reasonable steps to ensure that these recipients comply with the Privacy Act 1988, do not breach the Australian Privacy Principles and have appropriate data handling and security arrangements in place.

Personal information is generally hosted on servers located in Australia. If you access our services from outside Australia, you consent to the transfer of your personal information to Australia, as the jurisdiction that may not provide the same high level of protection we apply in Australia.

 

8.0 Storing and protecting your personal information

We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to ensure that the personal information that you provide to us is stored safely and securely. We hold the information we collect from you in physical and electronic records, which may be stored at our premises or in secure data centres or in the cloud.

We take a number of precautions to protect the personal information we hold about you from misuse, interference and loss, and from unauthorised access, modification or disclosure. We have a range of practices and policies in place to protect personal information we hold, including:

• educating our staff and representatives about how to protect your personal information and updating them about cybersecurity developments, threats and scams,
• requiring our staff and representatives to use passwords when accessing our systems,
• where appropriate, using strict confidentiality arrangements restricting third parties’ use or disclose of personal information for any unauthorised purposes,
• employing physical and electronic means, including access controls (as required) to protect against unauthorised access to buildings,
• employing firewalls, intrusion prevention systems and virus scanning tools to protect against unauthorised persons, malware and viruses from entering our systems,
• some of the systems we use are on dedicated secure networks or transmit electronic data via encryption, and
• providing secure storage for physical records and securing paper files in locked cabinets and physical access restrictions.

We generally keep personal information for up to 7 years from the date our financial advice was provided to you or for as long as is reasonably necessary for the purpose for which is was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

Where personal information is no longer required, we take steps to de-identify or destroy or de-identify the information in a secure manner.

 

9.0 Contacting us about Privacy

If you have any queries or are concerned about how your personal information has been collected, used or disclosed and you wish to make a complaint, please contact the Privacy Officer on the information below:

Mail:                  PO Box 6147 GCMC QLD 9726
Phone:              (07) 5655 1099
Email:               info@anovaadvicegroup.com.au

Website:          www.anovaadvicegroup.com.au

Correspondence should be addressed for the attention of the Privacy Officer. Please ensure that you provide sufficient information for us to be able to contact you if we require clarification of the matters that you raise.

We will acknowledge receipt of a complaint immediately, however, where this is not possible, acknowledgement will be made as soon as practicable. We will then investigate the complaint and respond to you within 30 days. Some complex matters may require an extension to thoroughly investigate the complaint and bring it to resolution.

If you are not fully satisfied with our response, you can contact an external body. In cases of privacy related complaints, this is generally the Office of the Australian Information Commissioner (OAIC).

The contact details for OAIC are:

• Mail: GPO Box 5218, SYDNEY, NSW, 2001
• Phone: 1300 363 992
• Email: enquiries@oaic.gov.au
• Online: www.oaic.gov.au

You may also direct privacy complaints related to financial advice to:

The Australian Financial Complaints Authority (AFCA). AFCA provides fair and independent financial services complaint resolution that is free to consumers.

• Mail:       GPO Box 3, MELBOURNE VIC 3001
• Phone:   1800 931 678 (free of charge)
• Email:     info@afca.org.au
• Online:   www.afca.org.au

 

10. About this Policy

We may amend or update our Privacy Policy as required by law or as our business processes or technology changes. We will post the updated policy on our website – www.anovaadvicegroup.com.au. We encourage you to check our website from time to time to view our current policy or contact us for a printed copy.