This privacy statement is made on behalf of ICA Partners Pty Ltd [BZ1] (ACN 158 181 241 AFSL 470003). ICA Partners Pty Ltd is committed to protecting your privacy and complying with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).
This Privacy Statement sets out our policy in managing personal information. We recognise that you are concerned about the privacy, confidentiality and security of information that you provide us.
Personal Information is information about an individual which can readily ascertain their identity. The information we collect will depend on what services we provide to you, or may be required by law, particularly to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.
Collection of Personal Information
We generally collect personal information directly from you. We may also obtain information from a third party when absolutely required. This is only necessary for the provision of our services and will only be conducted by lawful means. Your personal details will generally be sought through application forms, where the purpose of the information collection will be disclosed to you. You must consent to any collection of your personal information before we provide our services. The type of information we will collect typically include:
– name, age and address
– phone number and/or email address
– information regarding products and services you require
– Identification and verification information.
We may also collect demographic information, including, birth date, education, occupation. We may also request your approximate annual income and net worth to assess your financial position.
- your Internet service provider’s address;
- the number of users who visit the web site;
- the date and time of each visit;
- the pages accessed and the documents downloaded;
- the type of browser used.
Circumstances where we may collect, use or disclose your information without consent are:
- Where we are required to by law
- Where there is an emergency with serious and imminent threat to life, health and safety
- Where there is a serious threat to public health or safety
- For the purpose of investigating or reporting a suspected unlawful activity
Unsolicited Personal Information
Where we receive personal information which is unsolicited by us and not required for the provision of our services, we will destroy the information provided it is reasonable and lawful to do so.
Notification of the collection of personal information
When we obtain personal information about you, you will be notified of this collection and our purposes for doing so. As such, you will know of any time we collect your personal information.
Security of Personal Information
We take reasonable precautions to secure personal information from loss, misuse or unauthorised access, modification or disclosure. Your personal information will be treated strictly in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) and the ‘private sector amendments’ contained in The Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth).
We will investigate any illegal actions with a view of prosecuting and/or taking civil proceedings to recover damages against those responsible. We constantly review our systems and data to ensure the best possible security for personal information. Where information is no longer required for our services or for legal obligations, we will take practical steps to destroy or de-identify the information.
You should be aware that there are inherent risks in transmitting information over the internet. We do not have control over information on the internet and cannot guarantee its security.
Use of Personal Information
We will only use your personal information for the main purposes disclosed at the time of collection, and any service related to the main purpose when it is reasonably expected to be used in this manner and necessary to do so. We may use your personal information to:\
- respond to any specific requests you may make of us;
- notify you of any products that may be of interest to you;
- update your personal files;
- disclose to our affiliates information required to provide the product or service you have requested, or to provide you with an opportunity to participate in their products or services;
- disclose to our agents, contractors or third party service providers to enable them to provide administrative and other support services to us; and
- where the disclosure is required by law, for example to government agencies and regulatory bodies as part of our statutory obligations, or for law enforcement purposes.
In certain situations we will request your consent to any collection, use or disclosure of your personal information. We may disclose your personal information without consent when it is required by law.
We may engage another business to help us to carry out certain internal functions relevant to our business. We may provide a third party client information to help us analyse and identify client needs and notify clients of products or service offerings. We apply a due diligence process during our selection of outsourced service providers and provide in the service agreement for them to report regularly in line with the obligations outsourced.
We will use personal information obtained for the secondary purpose of direct marketing where:
– we collected the personal information from the individual
– our contact details are provided in each communication
– the individual would reasonably expect ICA Partners to use or disclose the information for the purpose of direct marketing
– ICA Partners provides and informs the client of a simple means through which an individual can request to not receive marketing communications
– The individual has NOT requested that such communications cease
– There is no fee charged for receipt of direct marketing material or removal from mailing list.
Access to personal information
Where a person requests access to their personal information, our policy is to permit access. No fee will be applicable for your access request but we my charge a cost for processing your request.
However, there are circumstances in which we will be unable to provide access. If this is the case, we will prove you a written explanation for your refusal. The circumstances include:
1. Where we reasonably believe this may pose a serious threat to the life, health of safety of any individual or to public health/safety;
2. Which would unreasonably impact the privacy of another individual;
3. Where such request is reasonably considered to be frivolous or vexatious;
4. Which relates to existing or anticipated legal proceedings which would otherwise not be accessible in the discovery process relating to such proceedings;
5. Which would be unlawful or prohibited by law or a court/tribunal order;
6. Which relates to suspected unlawful activity or serious misconduct, where access would likely prejudice the taking of appropriate action in relation thereto;
7. Where enforcement activities conducted by or on behalf of an enforcement body may be prejudiced; or
8. Where access would reveal details regarding a commercially sensitive decision-making process.
Correction of personal information
We will take all reasonable steps to ensure that the information about you is accurate, up-to-date and complete. We may deem it necessary to verify this information upon collection. We encourage you to notify us immediately if you change any of your details. No fees are payable for these requests. We will similarly advise third parties of such corrections when necessary, practical and lawful to do so. We will take all reasonable steps to correct such information within a reasonable time frame. If we intend to refuse to comply with your request to correct personal information, we will notify you in writing of our reasons for the refusal. You may wish to challenge the decision through the complaints process.
If you any queries regarding our policy statement or your privacy rights, please contact us.
If you have a complaint relating to our compliance with privacy laws or use of your personal information, please contact us. We will investigate your complaint and resolve the issue. If you are not satisfied with the outcome, you have the right to lodge a complaint with the Office of the Australian Information Commissioner.
ICA Partners Pty Ltd
Governor Macquarie Tower
1 Farrer Place
Sydney NSW 2000
Phone Number: + 61 2 9133 9000
Contact the Privacy Commissioner
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
[BZ1]Note: name change to ICA Partners