The information presented in this document is the interpretation of Solutions2 Wealth Management Pty Ltd in relation to the recent amendments to the Privacy Act 1988. Should you require specialist advice in relation to this area you should contact a lawyer or other suitably qualified professional
Solutions2 Wealth Management Pty Ltd (Solutions2) is committed to protecting the privacy of its clients and the confidentiality of their personal information.
2. Open and transparent management of personal information
Solutions2 is obliged to:
(a) take reasonable steps to implement practices, procedures and systems that will ensure Solutions2 complies with the APP code, and is able to deal with related inquiries and complaints;
In accordance with the above requirements, it is the policy of Solutions2 that:
(a) all clients of Solutions2 its advisers and agents are entitled to access their private information upon request;
(b) any complaints by clients in relation to the handling of their private information should be referred immediately to Solutions2;
(c) Solutions2 management of private information will be set out in this policy;
(d) this policy will be freely available on any website operated by Solutions2 . Further, advisers and agents to whom this policy applies should also include a link to the policy on any website operated by them.
3. Collection of solicited personal information
Solutions2 is required to only collect information that is reasonably necessary for one or more of its functions. It is anticipated that personal information will be required to be collected due to the financial services provided by Solutions2. Information such as name, address, date of birth, income, tax file number (TFN), investment preferences, family circumstances, social security eligibility and other personal information will often be required for services such as:
- financial advice;
- insurance; and
- other miscellaneous financial services.
Where personal information is required to be obtained from clients in order for them to be provided services from companies within Solutions2, those clients must consent to the collection of their personal information.
4. Dealing with unsolicited personal information
If a member of Solutions2 or its advisers and agents collects any unsolicited personal information it should immediately assess whether that information could have been obtained in accordance with clause 3.0. If the information could not have been obtained under clause 3.0 (for example, a client provides extra information that would not normally be required without being prompted to do so) then steps must be taken to destroy or de-identify the information as soon as practicable, if it is lawful and reasonable to do so.
If the information could have been collected in accordance with clause 3.0 then it should be dealt with in accordance with this Policy.
5. Notification of the collection of personal information
If personal information about an individual is collected then reasonable steps must be taken to notify the individual, or otherwise ensure that the individual is aware of certain matters. These matters include:
- the identity and contact details of who collected the information;
- the fact and circumstances of collection;
- whether the collection is required or authorised by law;
- the purposes of collection;
- the consequences if personal information is not collected;
- the usual disclosures of personal information of the kind collected by Solutions2;
- whether it is likely that personal information will be disclosed to overseas recipients, and if practicable, the countries where they are located.
If a member of Solutions2 or its advisers and agents collects personal information they are obliged under this Policy to provide the above information.
6. Use or disclosure of personal information
If information has been collected, Solutions2 must not use or disclose the information unless the person consents to the use or disclosure of the information;
We may disclose your information to:
- other organisations involved in providing the financial advice you have requested such as fund managers who assist us in providing financial advice;
- insurance providers, superannuation trustees and product issuers in connection with the provision to you of the financial advice you have requested;
- organisations that assist in operating a financial planning business such as those that provide administrative, financial, accounting, insurance, research, legal, computer or other business services;
- your representatives or service providers such as your accountant, solicitor, tax agent, stockbroker or bank;
- organisations involved in a business restructure or a transfer of all or part of the assets of our business or the due diligence procedures prior to any such sale or transfer;
- government authorities and other organisations when required by law; and
- organisations that you have consented to your personal information being disclosed to
7. Direct marketing
If personal information about an individual is held, that information must not be disclosed for the purpose of direct marketing.
For the purposes of this Policy, Solutions2 may distribute marketing material that is explicitly provided for clients, eg monthly magazines.
Any client of Solutions2 or its advisers and agents may opt out of receiving any direct marketing materials by contacting Solutions2 at:
216 Station Street
Fairfield Vic 3078
P: (03) 9489 6644
8. Cross-border disclosure of personal information
There are obligations to ensure that personal information is not transferred to another country. It is the policy of Solutions2 that no personal information should be transferred outside of Australia without the client’s prior approval.
9. Adoption, use or disclosure of government related identifiers
An organisation must not adopt a government related identifier, such as a tax file number, as its own. Practically, this means that you could not for example, use a tax file number as a client reference for filing purposes.
10. Quality of personal information
Solutions2 or its advisers and agents should seek to update the personal information of its clients as often as possible.
11. Security of personal information
Reasonable steps should be taken to ensure the security of all client personal information is kept secure. What these reasonable steps will be will vary depending on the situation. However, some practical steps that may be applicable are:
- Personal information stored on a computer is password protected and not available on a public network.
- Personal information stored in hard copy is kept in a lockable cabinet.
Further, if personal information has been obtained, it should be destroyed or de-identified once it is no longer required. Please note that there are certain obligations imposed that require client information to be retained for a certain period of time. You should contact Solutions2 if you have any queries as to how long personal information should be retained for.
12. Access to personal information
If a member of Solutions2, or its advisers and agents holds personal information about an individual, then on request by the individual they must give access to that information within a reasonable period of time.
There are exemptions to the above rule, such as if disclosing that information would post a serious threat to the individual or if giving access would be unlawful.
13. Correction of personal information
If personal information is held and either:
- It is apparent that the information is inaccurate, out of date, incomplete, irrelevant or misleading; or
- The individual requests Solutions2 to correct the information;
then steps must be taken to ensure that the information is accurate, up to date, complete, relevant and not misleading. Any request to correct information should be dealt with within a reasonable period after the request was made.
14. Payway – On line strata levy payment facility
(a) Solutions2 provides a Pay Way Online webpage which gives you a URL link redirecting your browser directly to our Westpac Payment Facility page maintained by the Westpac Bank.
15. Payway Refund Policy
Please make sure to use correct reference details when making your payment from the Westpac Payment Facility page.
No refund is available for incorrect data entry.
All payments are processed in AUD.
16. Privacy complaints
216 Station Street
Fairfield Vic 3078
P: (03) 9489 6644
The complaint will be considered within seven days and responded to accordingly. It is our intention to use our best endeavour’s to resolve any complaint to an individual’s satisfaction; however, if they are unhappy with our response, they are entitled to contact the Office of the Australian Information Commissioner who may investigate the complaint further.
This Policy will be reviewed by Solutions2 Compliance Committee at least annually or as changing circumstances warrant.