Privacy Policy (April 2017)

1. Your rights in relation to privacy

The privacy of personal information is important to Property Funds Management Australia Pty Ltd (PFM Australia) (ABN 65 166 548 661) and its related bodies corporate. The PFM Australia is committed to protecting the privacy of an individual’s personal information. This statement sets out how PFM Australia aims to protect the privacy of your personal information, your rights in relation to your personal information managed by PFM Australia and the way PFM Australia collects, holds, uses and discloses your personal information.

In handling your personal information, PFM Australia will comply with the Privacy Act 1988 (Cth) (Privacy Act), as amended from time to time, and the 13 Australian Privacy Principles.

This privacy statement may be updated from time to time.

2. What kinds of personal information does PFM Australia collect?

Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its services, PFM Australia may collect your personal information.

The personal information PFM Australia collects depends on, and is specific to, the products and services you engage us to provide. Generally, the kinds of personal information PFM Australia collects includes:

  • contact and identification information such as your name, address, telephone number, email address and date of birth;
  • other identification verification information, including photographic information, from documents including your birth certificate, passport, driver’s license, pension card, citizenship certificate, tax notice assessment, Medicare card and utilities notices;
  • financial information about your assets, occupation and income, account balances, bank account details, account activities, trust arrangements, payment history and transactions with us and third parties;
  • tax information including your tax file number, tax returns and related information;
  • professional and business information about your membership of a professional association, partnerships, directorships, business names and trust arrangements.

In some circumstances, PFM Australia may also hold other personal information provided by you.

3. How does PFM Australia collect personal information?

Generally, PFM Australia collects your personal information directly from you, through:

  • completion of an application or other form either online or in hard copy;
  • provision of original, or copies of, documentation whether delivered in person, by post or electronically;
  • face-to-face meetings or telephone meetings and exchanges;
  • recordings of conversations (in which case you will be informed of such recording prior to the recording commencing);
  • email, or other electronic, correspondence; or
  • receipt of mail which you have directed to be sent to PFM Australia.

There may be occasions when PFM Australia collects your personal information from other sources such as from an information services provider, publicly maintained record or third parties such as your family members or professional advisors where we are authorised to do so. Generally, PFM Australia will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.

4. Why does PFM Australia need your personal information?

PFM Australia collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of providing its products and services to you, including providing:

  • wealth management and investment products and services;
  • tax, accounting and superannuation products and services including audit insurance;
  • estate and succession planning products and services;
  • treasury services;
  • funds management products and services;
  • document and asset custody services;
  • family office services, being financial and intergenerational wealth management products and services specific to family groups;
  • products and services in accordance with any agreement you enter into with PFM Australia;
  • accounting, billing and other administrative purposes;
  • identifying and informing you of products and services that may be of interest to you from PFM Australia or other selected third parties; and
  • any legal requirements, including PFM Australia’s obligations under: o the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
    • applicable taxation law;
    • the Corporations Act 2001 (Cth);
    • the Australian Securities and Investments Commission Act 2001 (Cth); and
    • the Bankruptcy Act 1966 (Cth).

In particular, tax file numbers are collected for tax-related purposes only. PFM Australia does not adopt government agency identifiers, for example, tax file numbers, as a primary means of identifying you. Some identity verification information is collected in order to satisfy PFM Australia’s obligations under anti-money laundering laws.

Where personal information is used or disclosed, PFM Australia takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information but without certain personal information, PFM Australia may not be able to provide the products or services you require.

5. To whom does PFM Australia disclose your personal information?

PFM Australia discloses your personal information for the purpose for which PFM Australia collects it. That is, generally, PFM Australia will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to various entities within PFM Australia and third parties where necessary to provide you with our products and services. These third parties may include government departments or other regulatory authorities, financial market and clearing and settlement facility operators, lenders, credit providers, audit insurance providers, custodians, share registries, certain software providers, third parties engaged to perform administrative tasks, professional advisors or, if authorised by you, your staff, family members, associated entities and other professional advisors. This disclosure is always on a confidential basis. PFM Australia may also disclose your personal information with your consent or if disclosure is required or authorised by law.

6. Overseas disclosure

PFM Australia may disclose personal information to overseas investors in order to provide its products and/or services and for administrative or other business management purposes.

Before disclosing any personal information to an overseas recipient, PFM Australia takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or authorised by law.

7. Credit Checks

PFM Australia does not provide loan or credit facilities and therefore, does not generally handle credit information. However, in the event you default on a payment owing to PFM Australia, PFM Australia may, in some circumstances, undertake a credit check for the purpose of collecting payments that are overdue.

8. Direct marketing

PFM Australia may use and disclose your personal information in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting PFM Australia Privacy Officer on the contact details set out in paragraph 11 or through any opt-out mechanism contained in a marketing communication to you.

9. Security of your personal information

PFM Australia regards the security of personal information as very important and takes steps reasonable in the circumstances to ensure the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. PFM Australia holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised personnel. PFM Australia has a number of physical and electronic protection measures in place including:

  • confidentiality requirements for employees;
  • confidentiality statements on all outgoing correspondence including email;
  • document storage security policies;
  • security measures for systems of access including encryption, firewalls, site monitoring and intrusion detection;
  • providing a discreet environment for confidential discussions; and
  • only allowing access to personal information where the individual seeking access has satisfied PFM Australia’s identification requirements.

However, PFM Australia cannot guarantee the security of personal information provided to PFM Australia by way of email nor can it guarantee the safe delivery of personal information via ordinary post. The security arrangements are reviewed and tested from time to time.

PFM Australia will destroy or de-identify personal information in circumstances where it is no longer required, unless PFM Australia is otherwise required or authorised by law to retain the information.

10. Can you access and correct the personal information that PFM Australia holds about you?

PFM Australia takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that PFM Australia collects and holds. If at any time you would like to access or correct the personal information PFM Australia holds about you, or you would like more information on PFM Australia’s approach to privacy, please contact PFM Australia’s Privacy Officer on the details set out in paragraph 11. PFM Australia will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate. To obtain access to your personal information:

  • you will have to provide proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
  • PFM Australia requests that you be reasonably specific about the information you require; and
  • PFM Australia may charge you a reasonable administrative fee, which reflects the cost to PFM Australia, for providing access in accordance with your request.

If PFM Australia refuses your request to access or correct your personal information, PFM Australia will provide you with written reasons for the refusal and details of complaint mechanisms. PFM Australia will also take steps reasonable in the circumstances to provide you with access in a manner that meets your needs and the needs of PFM Australia.

PFM Australia will endeavor to respond to your request to access or correct your personal information within 30 days from your request.

11. How to contact us - further information, enquiries, requests or complaints 8 | P a g e

For further information, enquiries, requests or complaints regarding your personal information, or if you would like to opt-out of receiving any promotional and marketing communications, please contact:

The Privacy Officer
Mr Barry Daniels PFM Australia
Aldersgate House,
Level 2, 405 Collins Street
Melbourne VIC 3000

Phone: +61 3 9618 6888

12. Complaint handling processes

Please direct all privacy complaints to PFM Australia’s Privacy Officer on the details set out in paragraph 11. At all times, privacy complaints:

  • will be treated seriously;
  • will be dealt with promptly;
  • will be dealt with in a confidential manner; and
  • will not affect your existing obligations or affect the commercial arrangements between you and PFM Australia.

PFM Australia’s Privacy Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Federal Office of the Australian Information Commissioner.