Privacy Policy

Our adoption of the National Privacy Principles and the requirements of the Privacy Act 1988 (Cth)(‘the Act’) formalises our commitment to ethical conduct and practice in regard to privacy. Australian Ethical seeks to observe the privacy safeguards laid down by the Act when collecting, storing, using and disclosing personal information. We also give individuals access and correction rights in relation to their personal information in compliance with the Act. If you are an investor in superannuation or managed funds, please be assured that your personal information will only be used in the manner and for the purposes set out below.

Please note: this policy reflects the on-going life of Australian Ethical and its products. As our information management develops, this policy may change from time to time.

Collecting information about you

We collect information from investors in our products and from people who make enquiries about our products.

We will collect name, address and other contact information from you if you make an enquiry about our product.

We collect information about our investors when they complete application or other forms or transactions related to their investments. We may also obtain information about you from your financial adviser.

We may also collect information about superannuation members from employers, doctors and insurance companies, particularly where a member requests insurance coverage, makes an insurance claim, or request early release of benefits.

In all cases we endeavour to ensure that information collected is correct. If you are an investor you will receive transaction confirmations, correspondence and periodic statements from us. We ask that you contact us immediately you become aware that your details require updating or alteration.

Using and passing on information about you

What we use your information for

We use information collected about you for a number of purposes:

  • to provide information to you and to ask you whether you are interested or satisfied with our products;
  • to administer your investments with us
  • for market research and analysis
  • for product development
  • to meet regulatory obligations.

Who we might give your information to

You should be aware that information may pass between members of the Australian Ethical group for marketing analysis and product development.

Information about you may also be passed to our custodian, an external organisation that holds assets on behalf of our managed investment schemes and superannuation fund. If you are an investor in Australian Ethical Superannuation, your details will also be held by our superannuation member administrator. This is an organisation which we contract to undertake administration of the superannuation fund for us.

Please note that these service providers are significant companies and are also subject to the provisions of the Act. Under our contracts with them, they have a contractual obligation to abide by privacy law and to protect your information.

Your information may be passed to third parties in the normal administration of your account, for example to a mail house to mail out distribution or periodic statements.

Information regarding your account will be given to third parties when necessary or authorised by you, for example to your authorised financial adviser. Information regarding your account is accessible over the telephone where appropriate verification information is supplied. Please notify us immediately if you do not wish any person you have previously authorised to have access to your information.

If you are an investor in Australian Ethical Superannuation, information about you may also be provided to other superannuation funds, your insurance company and agent, retirement savings accounts, or other rollover entities.

You should also be aware that there are instances where we are legally obliged to pass on information about you. The following list of compulsory disclosures (i.e. disclosures we must make) provides you with examples but is not intended to be exhaustive or complete:

  • in accordance with legislative requirements or authority (e.g. your tax file number and the taxable income of your account; deposits reportable under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)(‘AML’));
  • in accordance with the legislative requirements of the administration of managed investment schemes or the superannuation fund – reporting or assisting in the investigation of unlawful activity where there is a basis for suspecting such activity;
  • to enforcement bodies with statutory authority (e.g. protection of public revenue (tax));
  • in any criminal procedure with court authority;
  • laws relating to the confiscation of the proceeds of crime;
  • proceedings by any enforcement or administrative body in a court or tribunal.

We will not pass on your personal information to unrelated parties for their marketing purposes. We would seek your informed consent in the event this policy changes.

The quality of the information we collect

We endeavour to ensure that any information we collect, use or pass on is up-to-date and accurate. We request that you contact us in the event your details change.

The security of information about you

It is not appropriate for information about you to be de-identified or destroyed. In some cases, we have statutory requirements to maintain our records for up to a period of ten years and, as the administration of the accounts is personal to you, it is not appropriate for your information to be de-identified.

However, we take precautions to prevent the misuse, loss and unauthorised access or modification or disclosure of your information. These include the use of verification data before information about investments is provided over the telephone or via the internet, restricted access to files, security checks on computer data, securing of data held on company networks, and a contractual requirement for service providers to use appropriate mechanisms to protect personal information. Information management is subject to an in-house compliance system with defined standards and monitoring.

Please note that we cannot guarantee the privacy of your information if you choose to correspond with us via email.

Information about our management of your information

If you decide to invest with us, our product guides (PDS) will alert you to various matters you need to be aware of when supplying us with your information. A brief statement of our privacy policy is outlined in the product guides (PDS). This policy is available to any person who requests it. In addition, we would like to encourage you to contact our Privacy Officer (see below) if you have any individual concerns relating to the collection, use or security of information about you.

Access and/or correction of the information we hold about you

Please contact us immediately you become aware that any information we have about you is incorrect. In the event we dispute a correction you wish to make, we shall place your disputed information on the file, together with the unaltered statement of information, until such time as the matter can be resolved.

Unless there are exceptional circumstances around the openness of your files, we will provide you with copies of our current records about you. If you wish to see your information, we ask that you make a request in writing and allow us seven working days in which to forward it to you.

Circumstances in which access to your records might be denied or restricted could be as follows. Please note this list is not intended to be exhaustive:

  • providing access would have an unreasonable impact on the privacy of another individual;
  • the request is frivolous or vexatious;
  • the information relates to existing or anticipated legal proceedings between you and us and would not be available by a process of discovery in those proceedings;
  • providing access would prejudice negotiations we have with you;
  • providing access would be unlawful or likely to prejudice an investigation into unlawful activity.

Using the identifier of another organisation

We use only our own identifier codes and records to identify you and maintain records holding information about you. Although we may have your Australian business number or tax file number, for instance, it would be used only for the purposes for identification with the relevant organisation as prescribed by that organisation.

Your ability to deal with us anonymously

You may contact us and seek to obtain any general information or assistance you wish without identifying yourself. However, for reasons of security, you will not be able to obtain information about your investments without identifying yourself first.

Transborder data flows

Generally, information about you or your investment would only be sent to a foreign country at your request. At present, we have no arrangement which would require the transfer of any information regarding you or your investment to a foreign country.

Sensitive information

Sensitive information is information about you which is information or an opinion about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union or criminal record. Information in respect of your health is also sensitive information.

Generally, we would not collect sensitive information about enquirers or investors. However, investors in Australian Ethical Superannuation may need to send information regarding their health, including copies of records, reports and opinions. We require your consent to have this information and we will request you provide this in writing at the time it is required, typically if you apply for insurance or make an insurance claim. We may also need to collect sensitive information as part of the AML requirements. We will only seek to collect from you the minimum amount of information that is required.

Have you a comment or complaint about your privacy?

If we have breached any of our obligations in keeping your information, or you are uncomfortable about any of our information management practices which have come to your attention, please do not hesitate to contact our Privacy Officer by calling 1800 021 227 or by writing to us at GPO Box 2435, Canberra ACT 2601.

We expect our conduct to deliver standards and performance of the highest order and welcome your comments.

If you are not satisfied with our response or would like to know more about your privacy rights, you can contact the Office of the Privacy Commissioner by calling 1300 353 992 or visiting the website at www.privacy.gov.au.