Super Simpler Pty Ltd (ABN 74 150 240 421)
Level 4, 150 St Georges Terrace, Perth WA 6000
Super Simpler Pty Ltd is a Corporate Authorised Representative (CAR: 468201) and operates under the Australian Financial Services License (AFSL: 233680 as held by AXIS Financial Group Pty Ltd (ABN 21 092 889 579)
What is this policy about?
The Privacy Act, 1988 requires us to manage personal information we may hold about you in an open and transparent way.
As a financial services organisation, we are committed to protecting the privacy of our clients. Information collected is only used to fulfil our responsibilities as your adviser. This Policy describes how we collect, hold, use and disclose personal information as well as how you can access your information, correct it or how to make a complaint.
Why do we collect your information?
We collect personal information about you for the purpose of providing you with superannuation, financial planning and/or insurance services. We may also collect personal information from third parties once authorisation has been provided by you.
This includes the following purposes:
In assessing your financial planning needs for superannuation, investment and insurance purposes
In the establishment and ongoing administration of investments and insurance policies
In support of decisions affecting your long term wealth
In reviewing progress against agreed investment strategies
In communication with product suppliers on changes to your investment strategy or to administer claims on an insurance policy
We are also bound to collect personal information to meet the requirements of corporate superannuation and taxation laws. 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.
Where reasonable and practical, we will collect your personal information directly from you and from third parties, once authorisation has been provided by you. We will notify you at the time we collect information providing details of who we are, the purpose and use, consequences of non-collection and our complaints handling process.
Without your consent, we will not collect sensitive information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership or professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record.
This is subject to some exclusions:
The collection is required by law
When the information is necessary for the establishment, exercise or defence of a legal claim
You have a right to refuse us authorisation to collect information from a third party.
You can deal with us anonymously where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.
Collecting information from our website
Our website provides links to third party websites. The use of your information by these third party sites is not within the control of Super Simpler and we cannot accept responsibility for the conduct of these organisations. Other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review these websites directly to ascertain their privacy standards, policies and procedures.
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.
What if I choose not to provide you with the information you request?
We only ask for information where it is necessary for the purposes outlined in this Policy. If the information is not provided, we may not be able to provide our services to you.
Will my information be disclosed to others?
We will only disclose your personal information to people or organisations for the purposes outlined in this Policy. When appropriate, we may disclose your personal information to or collect it from:
Administrative staff with Super Simpler
Loss assessors and claim investigators
Your employer *
Claims reference providers
Hospitals, medical and other health professionals
Legal and other professional advisers
Trustees and administrators of other superannuation plans or eligible rollover funds
*When you are a member of an employer-sponsored superannuation plan, your employer will need to provide certain information to us and to the adviser who assists your employer with the superannuation plan. Some of the information may be provided to us by your employer in order that it meets its obligations under superannuation law. You may also provide personal information to us to assist us in providing your superannuation in relation to your plan membership to your employer and to their adviser. However, this information would never be of a sensitive nature, such as information about your health.
We collect information about you for the purpose of reporting to AUSTRAC under the Anti-Money Laundering and CounterTerrorism Financing Act 2006.
In the event 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.
We will not under any circumstances disclose your personal information to an overseas recipient.
Is there anything else I need to know about how my information may be used?
At times we may also use your personal information for the purpose of providing you with additional information about the benefits of superannuation, financial planning and/or insurance or to let you know about other products and services that we can provide. This may be by way of an invitation to attend a seminar or briefing on a particular topic by a specialist in that area. It may be by providing written publications either electronically or by mail.
Generally, this is done as part of our advisory role in providing information for your consideration.
From time to time we may provide you with direct marketing material. If at any time, you do not wish to receive this information, you can contact us by either writing to us, emailing us or alternatively calling us on the Freecall number listed below.
Storage & security of personal information
We keep your personal information in your client record. These files are accessible to authorised personnel only and are appropriately secured. Your personal information is held on our computer database. All computer-based information and data transfers are protected through the use of access passwords with encryption. Reports and documents are kept in secure folder locations. Data is backed up regularly and stored securely offsite. Other measures taken are:
Confidentiality requirements for our employees
Additional security measures for system access
Providing a discreet environment for confidential discussions
Personal information will be treated as confidential information and sensitive information will be treated highly confidential.
It is a legislative requirement that we keep all personal information and records for a period of seven years. Should you cease to be a client of ours, we will maintain your personal information on or offsite in a secure manner for seven years. After this, the information will be destroyed.
Super Simpler takes its obligations to protect your information seriously. This includes when we operate throughout Australia and overseas as part of our operations. Some uses and disclosures of your information may occur outside of your State or Territory and/or outside of Australia. In some circumstances, we may need to obtain your consent before this occurs.
Accuracy of information
Super Simpler takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up to date. To ensure we maintain this level of accuracy and completeness, we recommend that you:
Inform us of any errors in your personal information as soon as possible; and
Update us with any changes to your personal information as soon as possible
How do I request access to personal information you hold about me?
You can request access to the personal information we hold about you by calling or writing to Super Simpler. In some circumstances, however, we do not have to provide you with that information. You will need to give full details of what you would like to know or see. If you contact us by telephone, we will ask you questions to help us identify you. We do this to protect the confidentiality of your personal information.
Some exceptions exist where we will not provide you with access to your personal information if:
Providing access would pose a serious threat to the life or health of a person
Providing access would have an unreasonable impact on the privacy of others
The request for access is frivolous or vexatious
The information is related to legal proceedings between us and would not be discoverable in those proceedings
Providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations
Providing access would be unlawful
Denying access is authorised by or under law
Providing access would be likely to prejudice operations by or on behalf of an enforcement body or an enforcement body requests that access be provided on grounds of national security
Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal. If charges are applicable in providing access to you, we will disclose these charges to you prior to providing you with the information.
Making a privacy complaint
Please contact our Privacy Officer if you wish to complain about any breach or potential breach of your privacy rights. Your complaint will be responded to within seven days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Australian Information Commissioner by calling them on 1300 363 992
Privacy and the internet
Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including the IP address) will be transmitted to and stored by Google on servers in the United States.
Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
Notifying you of certain data breaches
A data breach occurs when personal information held by us is lost or subjected to unauthorised access or disclosure. If we suspect or know of a data breach, we will take immediate steps to limit any further access or distribution of the affected personal information or the possible compromise of other information.
When we have reasonable grounds to believe that a data breach is likely to result in serious harm – for example identity theft, significant financial loss or threats to your physical safety we will notify individuals at likely risk as soon as practicable. We will also notify the Office of the Australian Information Commissioner.
Notifications will be made using our usual method of communicating with you such as by a telephone call, email, SMS, physical mail, social media post, or in-person conversation. If we are unable to contact you, (or your nominated intermediary) by any of the above methods we will publish a statement on the front page of our website.
The Privacy Officer
Level 4 150 St Georges Terrace, Perth WA 6000, Australia
The Privacy Officer
PO Box 7259, Cloisters Square, Perth WA 6850, Australia
T: 08 9426 5888
F: 08 9426 5850
Freecall: 1800 467 467
Version 2 – July 2020