Australian Ethical Investment Limited (AEI)
Australian Ethical Superannuation Pty Ltd (AES)
Our adoption of the National Privacy Principles and the requirements of the Privacy Act 1998 (Cth) ('Privacy Act') formalizes our commitment to ethical conduct and practice in regards to privacy. AEI and AES seek to observe the privacy safeguards laid down by the Privacy 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 a unitholder or a member of our superannuation fund or a shareholder of AEI, 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 the companies and their products. As our information management develops, this policy may change from time to time.
COLLECTING INFORMATION ABOUT YOU
Almost all the information we collect about unitholders and superannuation members is supplied by you when the application form is filled out. Your broker may give us further information. We also keep records of correspondence.
In every case for both unitholders and superannuation members, we endeavour to ensure that your details are correct by sending you a letter of confirmation upon receipt of an application. We ask that you contact us immediately you become aware that your details require up-dating or alteration.
The information we collect about superannuation members may also come from a variety of other sources. In particular employers will send us information about you to establish superannuation accounts. We may also receive information from third parties, such as doctors, insurance related companies etc. in the event we are requested to process a Total & Permanent Disability claim, hardship case or death benefit.
We maintain records of our shareholders through our registry manager, Registries Limited (callcentre@registriesltd.com.au; 02 9290 9600). We seek to keep our shareholders informed of the business activities of Australian Ethical as well as meeting our legal obligations towards our shareholders.
USING AND PASSING ON INFORMATION ABOUT YOU
What we use your information for
AEI and AES use the information collected about you for three main purposes:
- to administer your unitholding or superannuation membership
- for market analysis
- for product development
Who we might give your information to
You should be aware that information may pass between AEI and its subsidiary, AES for marketing analysis and product development.
Both companies use a custodian for the holding of assets of the trusts and superannuation fund. In the normal administration of the trusts and fund , information about you may be passed to the custodian. AES also uses the services of an administrator who will also have your details if you are a superannuation fund member. Please note that these companies are also subject to the provisions of the Privacy Act and have an additional contractual obligation to our companies to abide by the law and protect your information.
It is our companies’ policy not to pass on personal information to unrelated parties for their marketing purposes. We would seek your informed consent in the event this policy changes.
Your information may be passed to third parties in the normal administration of your account. For example, to a mail house for the mail-out of distribution statements.
Information regarding your account will be given to third parties when necessary or authorized by you. For example, to your broker. Information regarding your account is accessible over the telephone where your unitholder code or fund membership number is quoted. Please notify us immediately if you do not wish any person you have previously authorized to have access to your information.
If you are a member of the superannuation fund, information about you may also be passed between other superannuation funds, your insurance company and agent, retirement savings accounts, or other roll-over 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 (ie. disclosures we must make) provides you with examples but is not intended to be exhaustive or complete:
- in accordance with legislative requirements or authority (such as 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))
- in accordance with the legislative requirements of the administration of the trusts or 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 (say, protection of public revenue)
- 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
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 inform 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 unauthorized access or modification or disclosure of your information. These include the use of a code which must be quoted in order for information about unitholdings or superannuation accounts to be given out over the telephone, restricted access to files, security checks on computer data, private computer cabling between the superannuation trustee and administrator. 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
At the time you make an application, our Product Disclosure Statements will alert you to various matters you need to be aware of when supplying us with your information. Unitholders and superannuation members can contact our Privacy Officer if they have any individual concerns relating to the collection, use or security of information about them.
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 (7) 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
WHAT IS A COOKIE AND HOW DOES AUSTRALIAN ETHICAL USE COOKIES?
A cookie is a very small text file placed on your hard drive by a Web Page server. It is essentially your identification card, and cannot be executed as code or deliver viruses.
We use cookies to make our website easier to use. We do not store any personal information in our cookies.
We may also use independent external service providers to track the traffic and usage on the web site.
Cookies are frequently used on many websites on the internet and you can choose if and how a cookie will be accepted by changing your preferences and options in your browser. Our website will still work if you reject cookies.
USING THE IDENTIFIER OF ANOTHER ORGANIZATION
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 organization as prescribed by that organization.
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 account without identifying yourself first.
TRANSBORDER DATA FLOWS
Generally, information about you or your account would only be sent to a foreign country at your request. At present, there are no contracts between either company which would require the transfer of any information regarding you or your account.
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. In information in respect of your health is also sensitive information.
Generally we would not collect sensitive information about unitholders. However, superannuation members may find that they need to send us 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 you make a claim and provide us with the information.
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.
Please also note, if you are not satisfied with our response or would like to know more about your privacy rights, you can contact the Privacy Commissioner by calling the Privacy Hotline on 1300 363 992 or visiting the website at www.privacy.gov.au.