Privacy policy

This policy explains our policies and practices with respect to the collection and management of personal information we may collect from you

  1. About Netwealth
  2. Collection of personal information
  3. Use of personal information
  4. Sharing of personal information
  5. Accessing and updating your information
  6. Keeping your information secure
  7. Making a privacy complaint
  8. Contact us

 

Privacy Policy current as of 31 December 2018


1. About Netwealth

This Privacy Policy (policy) applies to Netwealth Group Limited (ABN 84 620 145 404) and its subsidiaries (the Group) (Netwealth, we, us, our). The Group includes Netwealth Holdings Limited (ABN 57 133 790 146), Netwealth Investments Limited (ABN 85 090 569 109), Netwealth Group Services Pty Ltd (ABN 89 135 940 840), Bridgeport Financial Services Pty Ltd (ABN 99 140 783 491) and Pathway Licensee Services Pty Ltd (ABN 13 114 805 104).

Your privacy is important to us. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), and this policy explains how we manage your personal information and the safeguards we have in place to protect your information. For the avoidance of doubt, this policy also applies to how we manage the personal information of AFS Licensees and their advisers and representatives, and our employees.

We may update this policy from time to time for any reason and without notice, so recommend that you regularly review this policy from the links provided on our website (located at the bottom of each web page). Alternatively, you can contact us to request a copy free of charge.


2. Collection of personal information

2.1 What personal information we collect

We will collect information from you to provide you with services and products.  This includes, collecting information when you:

  • Use our website – we will collect information about your preferences, your location, third party websites you visit and your IP address. This includes the use of cookies.  For more information on how we manage cookies, please see our information on cookies (located at the bottom of each web page)
  • Use our mobile application (Netwealth app) – we will collect information about your preferences, device(s) used to access the app and usage of app features.
  • Contact us – we will require information to verify who you are, such as your name, address, date of birth, email and other personal information (unless you contact us via phone to make a general inquiry or comment only, in which case you may choose to be anonymous or use a pseudonym although we may require further information to respond to your inquiry or comment).
  • Wish to provide your representatives or clients products and services offered by or available via us (where you are an AFS Licensee, adviser or representative) – we will require information to verify who you are, your bank details and other credentials as required by us to assess, record and review matters relevant to our obligations and risks.
  • Open one or more of our products or services, or one or more products or services that we administer for a third party issuer * – we will require your personal information, along with other information to enable us or the third party issuer, whichever relevant, to offer that product, such as name, date of birth, contact details, identification documents, tax information, residency status, bank account details, occupation status, and any other personal information for us to comply with our obligations and manage risks . If you have a financial, legal or other adviser or representative, broker or agent, we will require their personal information to facilitate communications and relevant authorities.
  • Utilise one or more of our optional services/functionality connected with the products or services offered or available via platform, such as nominating beneficiaries or requesting particular investment options – we will request details to be able to provide these services, such as the beneficiary details, and specific authorisations around the investment option.
  • Subscribe to receive information or attend events that we provide/host or a third party provides/hosts – we will require some contact information to facilitate your request, such as your name, email address and phone number.
  • Request for us to facilitate any another arrangement involving a third party who provides services in accordance with your request * – such as where we provide a link to a third party website and you request that third parties send us your personal information (for example, bank feeds and other data feed arrangements).
  • Request additional products or services provided by a third party – such as a request for insurance through your superannuation, in which case we will request health information from you.
  • Seek employment or contracting opportunities with us – we will require personal information from you to identify who you are, your employment history, and sensitive information where required and with your consent, to assess your application. Information about referees may also be requested and if so please ensure you obtain their prior consent before providing us with their personal information. If employed/engaged by us, from time to time we may require attestation of past information provided and/or additional personal information, including sensitive information with your consent, in accordance with policies or procedures or to meet other obligations and manage risks.
  • Sensitive information – the collection of sensitive information is restricted by the Privacy Act. This includes such as information about your ethnicity, health, religion or criminal record. If we need this type of information, we will ask for your permission, except where otherwise permitted by law.

* Where Netwealth is an administrator for a third party issuer, or where you have asked a third party to send us your personal information, you should read the privacy section of the relevant issuer’s disclosure document and the privacy policies of any third parties involved in that arrangement to understand details about how your personal information will be managed and who you should contact in the first instance.


2.2 How we collect personal information

Most of the personal information we collect will be directly from you (including via your financial, legal or other adviser or representative) when you submit an application or other form, login online and make changes or when you talk to us in person or over the phone.

Sometimes, we collect information about you from other parties without your direct involvement, such as:

  • Third party product and services providers, such as your insurer or annuity provider, or an online electronic services provider for the purposes of verifying your identify or other information
  • When you request to use digital services, for example our bank feeds service, we will collect financial information via a third party.
  • AFS Licensees and their advisers and representatives
  • Family members (for example where they have named you as a beneficiary of their interest in a product or service) or your appointed agent or personal legal representative
  • Regulators and government agencies, such as the Australian Tax Office, and various publicly or commercially available sources including individual and business registers
  • Employers
  • Brokers
  • Agents

 

2.3 What if you do not provide us with the information that we request?

You are not required to give us the information that we request. However, if you do not provide us with the information, or provide us inaccurate information, it may:

  • Prevent us from being able to offer you with products and services or, where we administer products or services for a third party issuer, prevent that issuer from being able to offer you the products or services
  • Prevent us from providing you with information on your products and services if we are unable to verify your identity
  • Cause delays in processing your request(s)
  • Impact the tax treatment on your account
  • Affect your eligibility for certain insurance cover



3. Use of personal information

3.1 How we handle your information

We handle your personal information carefully. We collect and hold your personal information for the purposes of:

  • Verifying your identity (including via an online electronic service where you have consented to electronic use of your personal information for that purpose)
  • Assessing or processing your application for a product or service
  • Providing you information, services and product updates
  • Providing you with products and services
  • Enabling us to contact you and to manage our relationship with you
  • Providing information to us about our products and services, the way they are utilised and managed
  • Improving our service to you
  • Facilitating the provision of products and services to you from third parties, where you have requested the use of those products and services or where you have agreed or not opted out to the sharing of your personal information with such a third party
  • Comply with laws, and assist government or law enforcement agencies
  • Managing risks, fraud and security (including using your mobile phone number and any other relevant identifier for two-factor authentication purposes)
  • Assessing and managing employee and contractor applications and records
  • Marketing our products and services to you*

* If you do not want to receive direct marketing messages, you must inform us. You can do this by contacting us on Freecall 1800 888 223 (within Australia) or by writing to us.

From time to time we may also combine information that we have about you with other data we hold or have collected from a third party. This information helps us understand trends in the industry as a whole or in particular segments and tailor marketing strategies accordingly.

We may also collect, use and exchange your information for other reasons where the law allows or requires us to do so.



4. Sharing of personal information

4.1 Sharing your information with third parties

We share your information with other entities within the Group and we also share your information with third parties.

These third parties may include:

  • AFS Licensees, their advisers and representatives and other third parties who you may engage to act on your behalf, such as your parent (if you are under 18), guardian or Power of Attorney;
  • Other financial services organisations, including banks, insurance companies, superannuation funds, stock brokers, custodians, fund managers and annuity providers (for AFS Licensees and advisers, please note that your personal information may be provided to annuity or other product providers when you register with us, or at a later time, unless you opt out in writing or phone); Complaint resolution schemes, for example the Australian Financial Complaints Authority;
  • Agents of listed company who are authorised to collect shareholding information;
  • Entities requesting your personal information with a valid court order;
  • Domestic and foreign regulators, government bodies and law enforcement agencies;
  • Organisations that help identify illegal activities and prevent fraud;
  • Organisations that provide online electronic services to verify your personal information, where you have consented to such use;
  • Organisations that provide employee background screening services;
  • Our contractors and external service providers, for example, auditors, mail house, marketing, printers and technology service providers;
  • Other people (such as family members) that are linked on your account; and
  • Third parties engaged by your Nominated Financial Adviser (such as provision of your data to your Nominated Financial Adviser’s client relationship management system).

 

4.2 Sending information overseas

The data centres of some organisations that we share information with may be located overseas, which means your personal information may be stored or accessed in overseas countries, including Canada, Malaysia, New Zealand, United Kingdom and United States of America. In addition, we may share some information of some financial advisers and clients with international fund managers to fulfil their obligations where we have an agreement in place and obligation to do so.. For further information on applicable privacy and data obligations that may arise from time to time under international privacy, data sharing and other laws (such as the European Union General Data Protection Regulation (GDPR) and the United States Foreign Account Tax Compliance Act (FATCA)) and how we satisfy any such applicable obligations, please contact us via one of the means in Section 8 below.



5. Accessing and updating your information

5.1 How you can access your personal information

You can request access to your personal information held by us. In most cases, we will grant you access after receiving sufficient information to verify your identity. Access requests may be made in writing, by email or by telephone using the contact details in the Contact us section below.

We do not charge a fee to you when you request a copy of the personal information held about you and generally will not charge you for the provision of your personal information. However, if the request is likely to take us a longer period of time to produce, we will let you know the charge, so you can choose if you want to go ahead. The fee will be an hourly rate to cover the expense of providing you with the data and you will need to make payment before we start.

Information will generally be provided within 30 days of successful verification of your identity and payment of any charge to provide the information (if applicable).


5.2 Can we refuse to provide you with information?

In some cases, we can refuse to provide you with access to information or provide you with access to only some information. This could occur where the information requested is commercially sensitive, would breach the privacy of another person or where we have another lawful reason to refuse. Where we cannot provide you with information we will write to you to provide an explanation of our decision.


5.3 Updating your information

We will take reasonable steps to ensure that the personal information we hold is accurate, up to date, complete and relevant. If you believe your personal information requires updating, you can contact us over the phone or complete the update yourself through our online service or a relevant form.

 


6. Keeping your information secure

6.1 Protecting your information

We may hold your personal information in secure data centres or paper-based files and have implemented a range of physical and electronic security measures to protect your personal information from misuse, unauthorised access and improper disclosure. We also monitor and maintain our security system to ensure that our online services are secure and your personal information is protected appropriately.

To protect privacy, we encourage you to keep passwords and access codes confidential and secure at all times. This means that you should not disclose your password or access codes to others and should contact us immediately if you believe that your password or access codes may have been disclosed to another person or if you would like to change your password.


6.2 Destroying or de-identifying your information

We try to ensure that we only keep personal information only for the period we need it. When we no longer require your personal information we will take reasonable steps to destroy or de-identify the data securely.


6.3 Data breach response 

In accordance with the Notifiable Data Breaches scheme, established by the Privacy Amendment (Notifiable Data Breaches) Act 2017 , organisations with existing personal information security obligations under the Privacy Act must notify any individuals likely to be at risk of serious harm by a data breach. The Office of the Australian Information Commissioner must also be notified.

If an unforeseen event were to occur and our data, including client personal information was interfered with or accessed by unauthorised persons, we have in place mechanisms to contain the breach and assess the impact. If your personal information were to be accessed or interfered with by unauthorised persons, we would comply with any applicable legal notifications to notify you.



7. Making a privacy complaint

7.1 How to make a complaint

If you are not happy with the way we handle your personal information, please contact us. We take complaints seriously and will try to resolve your concern according to our Complaints Handling and Compensation Policy.

We aim to respond to your complaint as soon as possible, and will provide you with a final response to your complaint within 45 days of receiving the complaint. If we cannot respond in this time, we will provide you with reasons why and what we are doing to try to resolve your complaint.

7.2 Other options if you are not satisfied with our response

If you are not satisfied with the response we provided to your complaint, you can approach the following free and independent dispute resolution services.

Under the Privacy Act you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information.

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone 1300 363 992
www.oaic.gov.au

The Australian Financial Complaints Authority (AFCA) deals with most complaints from consumers in the financial system, including complaints about superannuation (complaints relating to privacy matters should however be made to the Office of the Australian Information Commissioner as per above contact details).

Australian Financial Complaints Authority
GPO Box 3
Melbourne VIC 3001
Phone 1800 931 678
www.afca.org.au  


8. Contact us

If you wish to contact us about the privacy related matters, you may contact us by email, telephone or in writing to:

The Privacy Officer
Netwealth Group Limited
PO Box 336
South Melbourne VIC 3205

Freecall 1800 888 223 (within Australia)
Phone 03 9655 1300
Email privacy@netwealth.com.au