Effective September 2021
Together, the following entities form the Infocus Wealth Management ABN 28 103 551 015 Group (the ‘Group’):
Each entity and their representatives are liable only for the services provided within their discipline.
In this Privacy Statement references to ‘we’, ‘us’ or ‘our’ are to the Infocus Group.
Personal information is information or opinion that allows others to identify you. It includes, but is not limited to, the following: your name, age, gender, contact details, and financial information; information on your health, sexual orientation, philosophical or religious beliefs, race or ethnic origin political opinions, details of membership of professional associations or trade unions, and genetic or biometric information.
We collect personal information to provide you with the products and services you request as well as to provide information on other products and services offered by or through us. The law requires us to collect and retain personal information. Personal information may be used and disclosed within the Group to administer our products and services, and, unless you tell us otherwise, to provide you with related marketing information. You can seek access to the personal information we hold about you. If the information we hold about you is inaccurate, incomplete, or outdated, please let us know so that we can correct it (refer to contact details in this document).
What personal information do we collect and hold?
Personal information is information or opinion that allows others to identify you. It includes your name, age, gender, and contact details. The kinds of personal information we collect and store will depend on what products and services you request from us. However, our ability to provide you with services and advice that meets your needs and objectives may entail us collecting information, including:
What sensitive information do we collect and hold?
Sometimes we may collect sensitive information about you. This could include information on:
We will collect, maintain, use, and disclose personal information which is necessary for us to adequately provide the services you have requested including:
As well as providing us with information upon which to provide a customised solution to your needs and objectives, we are required under the Corporations Act 2001 (Cth) and the National Consumer Credit Protection Act 2009 (Cth) to collect and hold this information.
How and why we collect information
Generally, we will not collect personal information about you except when you have knowingly provided that information to us or have authorised a third party to provide that information to us. Sometimes we collect information about you from other sources. We may collect information about you that is publicly available (for example from public registers or social media). However, in most cases collection of your personal information will be via face to face interviews, over the telephone, email or by way of your completion of a financial fact find. From time to time, other service providers may provide us with your information for the purpose of our providing a service to you (referral). In this case we will contact you to determine if we can be of any assistance.
We may seek your express permission to collect information from other entities such as product providers, accountants, solicitors, etc where this information may not be currently available to you. If we were to obtain information that is not information that could have been provided or authorised for collection by you, we will de-identify and destroy this information unless it is unlawful to do so.
Identification documentation is required for collection by law under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), as we are required to know our clients. In some instances, we are required to verify this documentation against other records. For instance, identification for Australian companies, trusts or registered co-operatives may need to be verified by a search of records held by regulatory bodies such as Australian Securities and Investments Commission (ASIC) or the Australian Taxation Office (ATO) etc.
Use and disclosure of information
We will not use or disclose personal information collected by us for any purpose other than:
We are obliged to maintain records which include personal information and make those records available for inspection by [the] ASIC or other regulators under a relevant law. If we provide information for the purpose of law enforcement activities, we will make a record of that provision.
If you chose not to provide your information
The effectiveness of our services is specifically dependent on information you provide and it being relevant, complete, accurate and up-to-date. Without this, our services may not meet your needs or may result in unforeseen financial con- sequences. If you elect not to provide us with your personal information, as and when requested, we may not be able to provide you with financial services. Similarly, we may not be able to provide other services such as credit assistance.
We may use personal information collected from you for the purpose of providing you with direct marketing material; however, if you do not wish to receive such information you can request not to receive it. Simply contact us by any of the methods detailed in this document. There is no cost for this request, however, please allow two weeks for your request to be actioned.
We adhere to the Spam Act 2003 (Cth), accordingly, we will:
Disclosing information to other parties
In order to provide our services, we may disclose your personal information to external parties, including, but not limited to:
If we have used an example to describe when we might exchange personal information, the exchange of personal information may not be limited to those examples or examples of a similar kind.
We disclose personal information when we outsource certain functions, including paraplanning, telemarketing, bulk mailing, market research, direct marketing, and information technology support; we may also seek expert help from time to time to help us improve our systems, products, and services.
In all circumstances where personal information may be- come known to our contractors, agents, AFSLs, authorised representatives or their agents and outsourced service providers, there are confidentiality arrangements in place. Contractors, agents, other AFSLs, authorised representatives or their agents and outsourced service providers are not able to use or disclose personal information for any pur- poses other than our own. The Group takes its obligations to protect client information very seriously and we make every effort to deal only with parties who share and demonstrate the same attitude. If we have used an example to describe when we might exchange personal information, the ex- change of personal information may not be limited to those examples or examples of a similar kind.
Sending personal information overseas
We take reasonable steps to ensure that overseas recipients adhere to the APP. We may disclose your personal information to contractors overseas to provide services to you; however, when doing so you should be aware of the following:
We allow access to relevant personal information for external organisations that help us provide services. These organisations are bound by confidentiality arrangements. From time to time we may use service providers whose staff accesses our data outside of Australia to provide services. Where this is the case, these service providers have com- mitted to adhere to the Australia Privacy Principles. These service providers may be located in a number of countries including the Philippines, India, Serbia, Vietnam and/or Sri Lanka.
Website, Social Media and Email
Government Related Identifiers
We will not adopt as our own any identifiers that you may provide to us such as TFNs, Centrelink, Medicare numbers etc. If you have provided us signed consent, we may hold your identifiers on file so that we can provide ongoing services to you. If you chose not to provide this consent, we will not hold this information on file. The circumstances in which an organisation may use or disclose government related identifiers are narrower in scope than the circumstances in which an organisation may use or disclose other personal information. Government related identifiers will not be dis- closed except in the following circumstances:
Accessing and Correcting your Information
Our goal is to ensure that the personal information we hold about you is accurate, secure, complete and up-to-date.
Please contact us if you believe that the information, we have about you is not complete, accurate or up-to-date. You can ask us to update or change information in your file at any time. Prior to providing this access we will require you to provide evidence of your identity. We may ask you to put your request in writing and any charge we make for providing access will be reasonable. We may take steps to update information, for example, an account balance from your account service provider where you have provided us with access rights or an address or contact number from publicly available information such as telephone directories or websites.
If you ask, we will tell you what personal information we hold about you within your client file and what we do with it. On receipt of your request we will, subject to the limitations out- lined below, facilitate access to you by allowing an inspection of your client file in person, or by providing copies or an accurate summary of relevant documents, depending on what we believe is most appropriate in the circumstances.
If for whatever reason we refuse to change information we hold on your file, we will arrange for a statement from you to be associated with the relevant information so that it can be included in any future use or disclose of that information should you wish to do so.
When we make reference to your client file we are referring to documents, including, but not limited to: data collection forms; written communications (such as letters and emails) from you to the Group, and from the Group to you (or our subsidiaries); Statements of Advice (SoAs), Records of Advice (RoAs); tax returns; credit guides; transaction letters; signed authorities; investment, superannuation and personal insurance applications or statements produced by the issuers of financial products, and fee invoices.
In accordance with the APP, we will not provide you with access to your personal information if:
In the event we refuse your request to access to your personal information; we will provide you with a written explanation for that refusal. We will endeavour to respond to any request for access within 14-30 days depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.
Keeping your Information Secure
Your personal information is generally held in your client file and on our computer database. We will always seek to ensure that your personal information is protected from mis- use, loss, unauthorised access, modification, or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential.
Our security measures include, but are not limited to:
In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in our secure storage facility for a period of 7 years in order to comply with legislative requirements. Where information we hold is identified as no longer needed for any purpose, we ensure it is effectively and securely destroyed.
Postal: PO Box 1856 Sunshine Plaza QLD 4558
Telephone: 1300 191 952
We recognise that even in the best run organisations things can go wrong. If you have a complaint about privacy please tell us, as we’d like the chance to fix the problem. We offer a free complaints resolution process for all our clients.
If you have any complaints about your privacy please contact:
Privacy Officer, Equity Trustees
GPO Box 1665 Melbourne VIC 3001
Phone: 1300 168 905
If, after having raised the issue with us, you are still dis-satisfied with the outcome, you are entitled to escalate the complaint to an external dispute resolution scheme. We are a member of the Australian Financial Complaints Authority (AFCA). You can contact them on the following details:
Telephone: 1800 931 678 (free call)
Mail: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001.
Additional Privacy Information