Information we collect
As a financial services organisation we are subject to certain legislative and regulatory requirements which necessitate us obtaining and holding detailed information which personally identifies you and/or contains information or an opinion about you (“personal information”). In addition, our ability to provide you with comprehensive financial service(s) is dependent on us obtaining certain personal information about you, information including:
- name, address, phone number, email address, date of birth and bank accounts;
- employment details and history;
- details about your family history and dependants;
- details of your current financial circumstances, needs and objectives, including your assets and liabilities (both actual and potential), income, expenditure, insurance and superannuation(and including your Tax File Number);
- your investment preferences and aversion or tolerance to risk.
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, have requested from us.
We may also collect sensitive personal information, such as:
- if you are a DNR Capital employee, details of any allergies or dietary requirements you have or other medical conditions which you consider important for us to be aware of; and
- criminal record information obtained through our screening processes before you commence, or during the course of, your business or employment relationship with us.
We recommend that you do not provide such information to us unless specifically requested by us.
The privacy laws impose greater obligations on us regarding any collection, use or disclosure of your sensitive information. We will only collect your sensitive information if:
- you have expressly consented to us doing so
- the information is reasonably necessary for, or directly related to our business activities or functions
- we are required or authorised to do so by law, or
- a permitted health or general situation exists.
Method of collection
Generally collection of your personal information will be effected in either face-to-face interview, over the telephone, by email or by way of a client application form. From time to time additional and/or updated personal information may be collected through one or more of those methods.
There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect personal information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected. Where we receive unsolicited personal information about you, we will determine within a reasonable period whether we may retain it or are required to destroy or de-identify it and take the appropriate action.
In general, you can visit our website without telling us who you are or revealing any personal information about yourself. If you access our website, we may collect additional personal information about you in the form of your IP address and domain name.
Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.
Purpose of collection
We will only collect, maintain and use personal information about you if it is reasonably necessary or directly related to our functions and activities, including for us to adequately provide to you the services you have requested such as:
establishing your identity;
- making securities and investment recommendations;
- making asset allocations recommendations;
- reviewing securities and investment recommendations;
- reviewing asset allocations;
- the provision of financial advice to you;
- monitoring, auditing and evaluating our products and services;
- providing you with marketing information about other services that we, our related entities and other organisations that we have affiliations with offer that may be of interest to you;
- maintaining our relationship with you;
- complying with any legal or regulatory requirements; and
- dealing with any complaints or enquiries.
Use and disclosure
We will not use or disclose personal information collected by us for any purpose other than:
The purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
Where you have consented to such disclosure; or
Where the Australian Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body;
We are obliged pursuant to the Corporations Act to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission;
We may use the personal information collected from you for the purpose of providing you with direct marketing material such as articles that may be of interest to you, however you may, by contacting us by any of the methods detailed below, request not to receive such information and we will give effect to that request. Please allow 2 weeks for your request to be actioned;
Superannuation fund trustees, insurance providers, and product issuers for the purpose of giving effect to your financial advice and the recommendations made by your adviser;
We may disclose your personal information to third party service providers, who assist us in operating our business, such as technology service providers or other professional services providers, including any custodian or sub-custodian. These providers may be based overseas or use overseas infrastructure to perform services for us, including Canada, Malaysia and the United Kingdom.
In the event that we propose to sell our business we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Any such 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. In the event that a sale of our business is affected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer.
Your personal information may be stored on paper and in electronic form.
We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, interference, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential. All paper files are kept in lockable storage. Access to our premises is controlled by allowing only authorised personnel to access the premises. All computer based information is protected through the use of access passwords on each computer and screen saver passwords. Data is backed up each evening and stored securely off site.
In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in a secure storage facility for a period of 7 years in order to comply with legislative and professional requirements, following which time the information will be destroyed.
Your personal and sensitive information will be stored in servers located in Australia, Canada and the USA for the purposes set out above.
Access and correction
You may at any time, by contacting us by any of the methods detailed below, request access to your personal information and we will (subject to the following exceptions) provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. We will, prior to providing access in accordance with this policy, require you to provide evidence of your identity.
We may charge you a reasonable fee for providing access to your personal information (but not for making a request for access).
We will not provide you with access to your personal information if:
- providing access would pose a serious threat to the life, or health or safety of a person or public safety;
- providing access would have an unreasonable impact on the privacy of others;
- the request for access is frivolous or vexatious;
- the information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
- providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
- providing access would be unlawful;
- denying access is required or authorised by or under an Australian law or court/tribunal order;
- we have reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been, is being or may be engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter;
- providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security, or.
- giving access would reveal evaluative information generated within the organisation in connection with a commercially sensitive decision-making process.
In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal which sets out the reasons (unless it would be unreasonable to provide those reasons).
We will endeavour to ensure that, at all times, the personal information about you which we hold is accurate, up to date and complete. In the event that you become aware, or believe, that any personal information which we hold about you is inaccurate, incomplete or outdated, you may contact us by any of the methods detailed below and provide to us evidence of the inaccuracy or incompleteness or out datedness and we will, if we agree that the information requires correcting, take all reasonable steps to correct the information.
If we do not agree that your personal information requires correcting, we will provide you with a written notice setting out our reasons (unless it would be unreasonable for us to do so) and the mechanisms available to you to make a complaint, and you also have the right to request that a statement be associated with your personal information noting that you disagree with its accuracy.
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.
Postal address: Resolutions Officer
GPO Box 3263
Brisbane QLD 4001
Phone: 07 3229 5531
Email: [email protected]
For more information about privacy in general, you can visit the federal Information Commissioner’s website at www.oaic.gov.au.
Postal address: Chief Executive Officer
GPO Box 3263
Brisbane QLD 4001
Phone: 07 3229 5531
Email: [email protected]
Changes to this Policy