Privacy Policy

Infrastructure Access Managers Pty Ltd

ACN 630 991 614

Purpose

The Privacy Act 1988 requires that Infrastructure Access Managers Pty Ltd (“IAM”) handles your personal information in accordance with a set of Australian principles, known as the Australian Privacy Principles (APPs), which regulate the collection, use, correction, disclosure and transfer of personal information about individuals by organisations in the private sector.

Application

This policy applies to all IAM representatives that are in receipt of or deal with personal information that handles personal information.

Policy

Collection

What information do we collect?

We will collect and hold your personal information for the purposes of:

  • providing products and services to you;

  • managing and administering the products and services;

  • letting you know about our other products and services;

  • meeting our obligations under certain laws which require us to collect, store and disclose information about you, including personal information; and

  • meeting the requirements of the external trustee or responsible entity of financial products offered by us.

The type of information collected from you includes information that is necessary to operate your account or for us to provide general advice to you. We may ask you to provide personal information such as your:

  • name

  • e-mail address

  • residential and/or postal address

  • date of birth

  • telephone number

  • occupation

  • bank account details

  • financial details

  • employer

  • tax file number (TFN).

This information is collected from application forms you have completed,

your use of our online facilities or through ongoing communications with you. We will not solicit any personal information about you except where you have knowingly provided that information to us or we believe you have authorised a third party to provide that information to us. Third parties that we may need to collect information from include your financial adviser, product issuer, employer, accountant or solicitor.

We will inform you of any legal requirements for us to ask for information about you and the consequences of not giving us that requested information. For example, in addition to the personal information we will obtain from you, whenever you acquire a new product or service from us, we will require documents evidencing your identity. Such evidence may include a certified copy of your driver’s licence, passport or birth certificate.

 

What if you do not give us the information we request?

You are not obligated to give us the information that we request. However, if you do not give us the information that we ask for, or the information you give is not complete or accurate, this may:

  • prevent or delay the processing of your application; or

  • prevent us from contacting you;

  • impact the taxation treatment of your account.

 

Use of information

How do we use the information that we collect from you?

We use your personal information for the purpose for which it has been obtained. We also collect your personal information so that we may:

  • develop an understanding of the products and services offered by IAM that might interest you, and;

  • send you information about us;

  • keep you up to date on other products and services offered by us.

 

Disclosure

Who do we give your information to?

We may disclose your information to external parties. Where personal information is disclosed, there are strict controls in place to ensure information is held, used and disclosed in accordance with the APPs.

The types of external organisations to which we may disclose your personal information include:

  • our agents, employees and representatives, either in Australia or overseas. Any overseas disclosure does not affect our commitment to safeguarding personal information we collect and we will take reasonable steps to ensure overseas recipients comply with the APPs;

  • the trustee or responsible entity of financial products offered by or through us;

  • financial institutions and other similar organisations in connection with our corporate activities or that are nominated by you;

  • external service providers and professional advisers that provide services to us; and/or

  • any organisation which you request us to or any persons acting on your behalf, including your financial adviser, broker, solicitor or account.

Like other financial services companies, there are situations where we may also disclose your personal information where it is:

  • required by law (such as to the Australian Taxation Office, AUSTRAC, Australian Securities & Investment Commission, any other regulatory and government bodies in Australia or pursuant to a court order);

  • authorised by law (such as where we are obliged to disclose information in the public interest or to protect our interests);

  • necessary in discharging obligations (such as to foreign governments for the purposes of foreign taxation);

  • required to assist in law enforcement (such as to a police force).

We may also disclose your information if you give your consent.

 

What are your rights

We understand that you may choose not to disclose your personal information to us. If you choose not to provide the information however, we may not be able to provide you with the product or service you have requested.

Your rights are as follows in respect of the personal information we hold about you:

  • The right to be informed about processing of your personal data;

  • The right to have your personal data corrected if its inaccurate and to have incomplete personal data completed;

  • The right to object to processing of your personal data;

  • The right to restrict processing of your personal data;

  • The right to have your personal data erased (the “right” to be forgotten”);

  • The right to request access to a copy of your personal data and information about how we process it. Please make all requests for access by writing to us at Level 3, 25 Hunter St, Sydney 2000 and

  • The right to move, copy or transfer your personal data (“data portability”).

 

Access and correction of information

Can I access my information and what if it is incorrect?

You may request access to the personal information we hold about you. We may charge a reasonable fee to cover our costs.

There may be circumstances where we are unable to give you access to the information that you have requested. If this is the case we will inform you and explain the reasons why.

We will take reasonable steps to ensure that the personal information we collect, hold, use or disclose is accurate, complete, up to date, relevant and not misleading.

You have a right to ask us to correct any information we hold about you if you believe it is inaccurate, incomplete, out of date, irrelevant or is misleading. If we do not agree with the corrections you have supplied and refuse to correct the personal information, we are required to give you a written notice to that effect and a statement if requested.

If you wish to access or correct your personal information, you may contact us by writing to the Privacy Officer, whose contact details are set out in the ‘How do I contact the Privacy Officer section below.

 

Complaints

If you believe that we have breached the APPs by mishandling your information, you may lodge a written complaint addressed to the Privacy Officer, whose contact details are set below.

The Privacy Officer will respond to your complaint within 14 days of its receipt.

In the event that the Privacy Officer is unable to resolve your complaint, you may lodge a complaint with the Information Commissioner.

You can lodge a written complaint with the Information Commissioner by:

 

Protection of the personal and sensitive information that we hold

How do we protect the security of your information?

We have security systems, practices and procedures in place to safeguard your privacy. We may use cloud storage or third party servers to store the personal information we hold about you. These services are subject to regular audit and the people who handle your personal information have the training, knowledge, skills and commitment to protect it from unauthorised access or misuse.

Risks of using the internet

You should note that there are inherent security risks in transmitting information through the internet. You should assess these potential risks when deciding whether to use our online services. If you do not wish to transmit information through our website, there are other ways in which you can provide this information to us.

 

General

How long do we retain your personal information?

We are required by law to retain certain records of information for varying lengths of time and, in certain circumstances, permanently. Where your information is not required to be retained under law, we will take reasonable steps to irrevocably destroy or de-identify your personal information when it is no longer required for the purpose for which it was collected.

 

How do I contact the Privacy Officer?

You can contact the Privacy Officer by mail:         

The Privacy Officer
Infrastructure Access Managers Pty Ltd
PO Box 3013 Bellevue Hill NSW 2023