Cornish Wealth Management is committed to providing you with the highest levels of client service. We recognise that your privacy is very important to you and as such our aim is to both support and ensure that we comply with the National Privacy Principals as set out in the Privacy Act 1988 (Cth).
Your Personal Information
As a financial planning organisation we are subject to certain legislative and regulatory requirements which necessitate us to obtain personal information about you in order for us to:
- Provide you with the relevant product or service;
- Manage and administer the product or service; and
- Protect against fraud.
Detailed below is some of the information you are required to provide:
- your name, date of birth, tax file number, current addresses, telephone/mobile/fax numbers, e-mail address;
- information regarding your spouse, dependents, occupation, employment history, social security eligibility, health information or other information Cornish Wealth Management considers necessary.
- your financial needs and objectives;
- your assets and liabilities (current and future), income, expenses;
- your superannuation and insurance details;
- your risk profile details.
If we are arranging life insurances, then sensitive information such as your health history may be required.
How We Collect Personal Information
Cornish Wealth Management collects personal information in a number of ways, including:
- directly from you, when you attend a face-to face interview;
- directly from you, when you provide information by phone, email or the internet; and
- directly from product issuers once authorisation has been provided by you. You have a right to refuse us authorisation to collect information from a third party.
How We Use Your Personal Information
Primarily, your personal information is used in order to provide comprehensive and/or limited financial planning services to you. We may also use the information that is related to the primary purpose and it is reasonable for you to expect the information to be disclosed.
From time to time, we may provide you with direct marketing material. This will include articles and newsletters that may be of interest to you. If, at any time, you do not wish to receive this information any further, you may contact us with this request. We maintain a Register for those individuals not wanting direct marketing material.
Please note: If you provide inaccurate or incomplete information we may not be able to provide you with the products or services you are seeking.
When We Disclose Your Personal Information
In line with modern business practices common to many financial institutions and to meet your specific needs, we may disclose your personal information to the organisations described below.
The Corporations Act has provided the Australian Securities and Investments Commission with the authority to inspect certain personal information that is kept on our files about you. We are also required to collect information about you for the purpose of reporting to AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.
For the purposes set out above, we may disclose your personal information to organisations outside Cornish Wealth Management Pty Ltd. The organisations to which we disclose information may include:
- superannuation fund trustees, insurance providers, fund managers and other product providers in order to manage or administer your product or service;
- compliance consultants to ensure that our representatives are meeting our compliance standards;
- your professional advisers, including your solicitor or accountant as authorised by you;
- information technology service providers to maintain, review and develop our business systems, procedures and infrastructure including testing or upgrading our computer systems;
- government and regulatory authorities and other organisations, as required or authorised by law;
- another authorised representative of Cornish Wealth Management Pty Ltd if necessary; and
- a new owner of our business that will require the transfer of your personal information.
In addition, our employees and the outsourcing companies/contractors are obliged to respect the confidentiality of any personal information held by Cornish Wealth Management.
Cornish Wealth Management takes its obligations to protect your information seriously, this includes when we operate throughout Australia and overseas, as part of our operations some uses and disclosures of your information may occur outside your State or Territory and/or outside of Australia. In some circumstances we may need to obtain your consent before this occurs.
In the event of that we propose to sell the business, we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them.
How We Store and Secure Your Personal Information
We keep your personal information in your client file. These files are accessible to authorised personnel only and are appropriately secured. Your personal information may also be held on our computer database. All computer-based information is protected through the use of access passwords. Data is backed up regularly and stored securely off site. Other measures taken are:
- Confidentiality requirements for our employees; and
- Security measures for our systems.
Personal information will be treated as confidential information and sensitive information will be treated highly confidential.
It is a legislative requirement that we keep all personal information and records for a period of 7 years. Should you cease to be a client of ours, we will maintain your personal information on or off site in a secure manner for 7 years. After this, the information will be destroyed.
Ensure Your Personal Information Is Correct
Cornish Wealth Management takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. To ensure we can maintain this level of accuracy and completeness, we recommend that you:
- inform us of any errors in your personal information as soon as possible; and
- update us with any changes to your personal information as soon as possible.
Access to Your Personal Information
You have a right to access your personal information, subject to certain exceptions allowed by law. We ask that you provide your request for access in writing (for security reasons) and we will provide you with access to that personal information.
If charges are applicable in providing access to you, we will disclose these charges to you prior to providing you with the information.
Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal.
Dealing with us anonymously
If you wish to remain anonymous or to use a pseudonym when dealing with us, we may be able to provide you with limited information or services, such as general details about our products. However in many cases it will be impracticable for us to assist you if you wish to remain anonymous or use a pseudonym and we therefore may not be able to provide you with a service.
Your sensitive information
Without your consent we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record. This is subject to some exceptions including:
- the collection is required by law; and
- when the information is necessary for the establishment, exercise or defence of a legal claim.
Cornish Wealth Management’s website provides links to third party websites. The use of your information by these third party sites is not within the control of Cornish Wealth Management and we cannot accept responsibility for the conduct of these organisations. Other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to ascertain their privacy stands, policies and procedures.
You may register with us to receive newsletters and other information. By doing so, your name and email address will be collected and stored on our database.
Spam is a generic term used to describe electronic junk mail sent to a person’s email account or mobile phone. In Australia, spam is defined as unsolicited commercial electronic messages.
Electronic messaging includes emails and SMS instant messaging but not cover normal voice-to-voice communication by telephone.
Cornish Wealth Management complies with the provisions of the Spam Act when sending commercial electronic messages. Equally importantly, Cornish Wealth Management makes sure that our practices are in accordance with the National Privacy Principles in all activities where they deal with personal information. Personal information includes our clients contact details.
The three key steps Cornish Wealth Management follow are:
- Consent – electronic messages are only sent with the addressee’s inferred or express consent.
- Identify – electronic messages will include clear and accurate information about the organisation that is responsible for sending the message.
- Unsubscribe – we ensure that a functional unsubscribe facility is included in all our commercial electronic messages.
Commercial messages will only be sent to you when you have given consent. This may be express consent or inferred consent based on our relationship with you.
Cornish Wealth Management ensures that Commercial Communications that include a Forwarding Facility contain a clear recommendation that the Recipient should only forward the Commercial Communication to persons with whom they have a relationship, where that relationship means that person could be said to have consented to receiving Commercial Communications.
Comply with the age sensitive content of commercial communication
Where the content of a Commercial Communications seeks to promote or inspire interaction with a product, service or event that is age sensitive, Cornish Wealth Management takes reasonable steps to ensure that such content is sent to Recipients who are legally entitled to use or participate in the product service or event.
Please contact our Privacy Officer (details below) if you wish to complain about any breach or potential breach of your privacy rights. Your complaint will be responded to within 7 days. If you are not satisfied with the outcome of your complaint, or require further information on privacy, you are entitled to contact the Office of the Federal Privacy Commissioner (http://www.privacy.gov.au).
Privacy Officer: Chris Cornish –
Address: 6/37-39 Railway Parade, Mt Lawley, WA, 6050
Telephone: 08 6143 3792