Club Plus Superannuation Pty Limited (“we”, “us”, “our”) as the trustee of Club Plus Superannuation Scheme (“Fund”) is required to comply with the Australian Privacy Principles (APP’s) contained in the Privacy Act 1988 (“Privacy Act”).
This Policy has been developed to inform you of your rights and our obligations, including how we collect, hold, use and disclose your Personal Information. It was last updated on 30 October 2019 and may change from time to time. You can access an up-to-date copy on our website or contact us to request a hard copy free of charge.
You should know that your Personal Information may also be handled on behalf of us by:
- Australian Administration Services (AAS) who we use to provide administration services for the Fund; and
- Our insurance providers.
‘Personal Information’ is information or an opinion (whether it is true or not) about an identified individual, or an individual who is reasonably identifiable.
Personal Information includes Sensitive Information. ‘Sensitive Information’ is information or an opinion about a person’s health as well their personal attributes such as 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, sexual preferences or practices, criminal record, genetic or biometric information.
To allow us to provide you with the services and activities of a superannuation fund, it is necessary for us to collect, use and hold your Personal Information. This Personal Information includes all or some of the following:
- your name, date of birth and gender;
- your contact details including your address, phone number(s) and email;
- your employment details, employment history and salary information;
- your Tax File Number (TFN) (if you have chosen to provide it);
- your contribution details;
- your nominated beneficiary details;
- super account details such as the date you joined the fund and investment option choices;
- super accounts in other superannuation funds or with the Australian Taxation Office (ATO);
- your bank details where we will be paying you a cash lump sum benefit or pension or where we have received a request to set up a direct debit;
- details to verify your identity if you request a cash payment or to open a pension account;
- information such as Court Orders or Agreements between you and your spouse where the Family Law Act applies;
- benefit payment and insurance claims history; and
- health and medical information about you in connection with insurance benefits provided to you through the Fund.
We will only collect Sensitive Information, such as health and medical information, about you where that information is reasonably necessary for us to administer your account.
The purpose of collecting, holding and using your Personal Information is so that we can admit you as a member of the Fund and provide you with the services and benefits the Fund offers. Unless you have agreed, we will only collect, hold and use your Personal Information for:
- the purpose for which it was given to us; and
- related purposes which you would reasonably expect.
We will collect, hold and use your Personal Information for the following purposes:
- to open and administer your super accounts and keep you informed about your super and insurance available to you as a member;
- ensure you are eligible for products and services (such as pension accounts and insurance cover);
- where applicable, to determine the cost of providing insurance cover to you;
- where you request new or increased insurance cover, to allow for underwriting of the cover;
- to verify your identity;
- to help you combine your super accounts and check if you have lost super (if you ask us to);
- to report information required by law or regulations;
- to provide you with information about products and services which we consider may be of interest to you, including financial education. This includes marketing and promotion by way of direct mail, telemarketing, email, SMS and MMS messages. However, you may at any time “opt out” of receiving direct marketing;
- to research, develop and improve our services, including testing and improving systems for the management of the services provided; and
- manage and resolve complaints.
At the time of your death we will need a copy of your death certificate. If you do not have a current binding death benefit nomination for your account or reversionary nomination for your pension account, we may also need Personal Information about who is entitled to be considered for distribution of your death benefit. This includes your spouse, children any other dependant, and your executor or administrator. The information we may ask for about those people will include their name, address, date of birth, their financial position and needs, and any other information that will assist us in deciding to whom the death benefit should be distributed. We may also need financial details of your estate to determine if the estate was solvent at the time of your death. If the Trustee then determines a death benefit is to be paid to a person, they may need to provide their bank details and information to verify their identify.
We will only collect Personal Information by lawful and fair means.
Personal Information will generally be collected from you, although if you are an employee of a participating employer in the Fund, we may also collect Personal Information from your employer.
The information we collect will typically come from what you have provided in your membership application forms (including online applications) or through our contact with you or your employer (including through their clearing house). We may be provided with your TFN from your employer for the purposes of managing your superannuation account.
The means by which we may collect Personal Information include:
- phone, which may include recording telecommunications with your consent;
- web chats you have with us through our website;
- forms, websites and portals and tools that may include your Internet Protocol (IP) address;
- email when you provide information to us via email, or ask to be on an email list, including the email address itself; and
- any other written material you provide to us.
At times it may not be practical or reasonable to collect Personal Information directly from you. In these cases, subject to your consent, we may collect Personal Information from the following:
- third parties, including your financial adviser, accountant or lawyer you authorise us to talk to;
- information that is publicly available;
- your employers;
- your other superannuation funds and insurers;
- the ATO;
- professional associations;
- health care professionals specific to insurance underwriting and/or claims.
On your death, the Personal Information about people who are entitled to be considered for distribution of your death benefit may be collected from your executor or administrator or whoever notifies us of your death.
Collection of Sensitive Information
We will not collect your Sensitive Information without your prior consent, except where we are required or permitted by law to do so.
We or our insurers may collect Sensitive Information, including health information, about you from third parties, such as doctors or other relevant persons, to assess and process claims for benefits, including insured benefits.
Collection of your Personal Information without consent
The Privacy Act permits us to collect Personal Information without consent, where required by law or court order. We may collect Sensitive Information without your consent if the collection of the information is required or authorised by or under an Australian law or a court/tribunal order or a permitted general situation (as set out in the Privacy Act) exists in relation to the collection of the information.
In the event that we receive unsolicited Personal Information (Personal Information about you that we have not requested), and if we determine that we could not have lawfully collected that information under Privacy Act if we were to request it, we will destroy or de-identify this information, if it is both lawful and reasonable to do so.
If we determine that we could have lawfully collected the Personal Information, we will deal with the information as outlined in this Policy, as if we had solicited the information.
Any Personal Information received is held by us, our Administrator (AAS) or our Insurers (currently OnePath and previously CommInsure) on your behalf.
Your Personal Information may be held in paper-based and electronic files. We, AAS and our insurers, will take all reasonable steps to ensure that your Personal Information is protected from:
- misuse, interference and loss; and
- unauthorised access, modification or disclosure.
With respect to paper-based information, we, AAS and our insurers all have physical security controls at our premises and in respect of electronic files, all have secure electronic networks. The transfer of information between us, AAS and our insurers is through secure portals.
Access to your Personal Information is restricted to staff who require access to administer your account and provide services to you. A system of passwords and different levels of access is used to protect the information held on our systems.
Where you access your account details online, the traffic between our website and your browser is encrypted
Notwithstanding the security measures above, we have procedures in place if your Personal Information is accessed or disclosed without authorisation or is lost. This may include notifying you and the Office of the Australian Information Commissioner (known as the Privacy Commissioner).
We will disclose your Personal Information to other parties where it is required to act on your instructions or where required by law. This includes other superannuation fund trustees and administrators, your employer, the ATO, the Australian Financial Complaints Authority (AFCA), the Australian Prudential Regulation Authority (APRA), the Australian Securities and Investments Commission (ASIC), the Australian Transaction Reports and Analysis Centre (AUSTRAC) the Office of the Australian Information Commissioner (OAIC) and online data verification services.
This disclosure could include:
- to verify your identity;
- in helping you combine your super accounts and check if you have lost super when you ask us to;
- to other superannuation funds if you transfer amounts or insurance to or from another fund;
- when engaging third party providers to perform services for the Fund which involves third parties handling Personal Information;
- when managing and resolving complaints;
- to and from your employer where relevant for the management of superannuation contributions;
- where required to do so by Law.
Where you have authorised us to, we may provide your Personal Information to a financial adviser, accountant, lawyer or other third party.
If you die while you are a member of Club Plus Super, we may share details about your super and insurance with your dependants and/or legal personal representative (the executor or administrator of your estate).
If you submit a claim an insurance benefit for either Total and Permanent Disablement or Income Protection, the insurer may pass information to claims investigators, medical practitioners, reinsurers, insurance reference bureaus and certain organisations to whom they outsource some functions.
In order for us to comply with requirements under the Family Law Act, if a request is received on the prescribed form, we may need to disclose your Personal Information to certain persons who are entitled to request information about your interest in a superannuation fund. Entitled people are your spouse or a person who intends to enter into an agreement with you about splitting their superannuation interests in the event of separation. The information may be provided directly to the entitled person or to their lawyer.
Other organisations that are contracted to provide services to us on behalf of the Fund may also receive compile and store Personal Information on our behalf, without acquiring rights in or to the information. These include:
Auditors – to review the Fund’s accounts for compliance with accounting standards and internal controls;
Printing and mailing companies – that compile and send out documents to members such as annual statements and transaction confirmation letters;
Digital communication and distribution companies – contracted to electronically communicate and distribute materials from us, including direct marketing;
Market research companies – that undertake research and client satisfaction surveys on our behalf and on behalf of the Fund;
Lawyers, consultants and other service providers – that are contracted to perform services for or give advice to the Trustee.
Unless disclosure is required by law, we will ensure parties who receive information about our members have appropriate systems in place to comply with applicable privacy laws before permitting them to handle information.
Cross Border Disclosure
Generally, we will not be required to disclose Personal Information to overseas recipients. There may be some instances, however, where Personal Information is required by overseas authorities or pension schemes where information is required for benefit payment purposes.
In the event we are required to disclose your Personal Information for cross-border disclosure purposes, you will be advised accordingly.
You can use our website to find out general information about the Fund such as the products and services offered and our performance. You can also use the secure are of our website to access your account details online by using your login and unique password.
When you visit our website, our server attaches a small data file known as a cookie on your hard drive to collect the following information:
- the time and the date that you visited;
- any information or documentation that you have downloaded;
- your browser type; and
- server address.
We may collect this information to assist us in identifying what information is of interest or use to our members. Cookies are safe and cannot be used to pass on a virus.
You may change the settings on your internet browser to reject cookies. However, this may impact on your experience with our website.
Links on our website
Our current policy is to retain member records for at least 10 years following their departure from the Fund. When we no longer require Personal Information for you (including when it is no longer required by law to keep records relating to you), we will ensure that the Personal Information is destroyed or de-identified.
You have the option of not identifying yourself, or of using a pseudonym, when dealing with us as follows:
- when you browse our website we do not collect your Personal Information; and
- you can make a general inquiry about the Fund without providing your personal details.
The option of remaining anonymous is very limited given the nature of information needed for us to provide you with our services. Membership of the Fund requires us to obtain Personal Information and should you refuse to provide identifying information, we may not be able to provide you with membership in the Fund.
We may also not be able to give specific information to you about your account or your situation if you wish to remain anonymous.
Right to refuse
You also have the right to refuse to provide us with Personal Information if we request it. However, if you choose to do so, you may not meet the minimum requirements for us to set up or maintain your membership or provide you with all the benefits and services you could receive if you had provided us with this information.
Specific Instances Relating to a Refusal to Provide Information
- If you refuse provide your TFN, we will be unable to accept personal after-tax contributions for your account and additional tax deductions will be taken from contributions made by your employer, including salary sacrifice contributions, or personal deductible contributions.
- If you refuse to provide medical information, we may not be able to provide insured death or disability benefits for you, other than any insurance granted under automatic acceptance provisions by the insurer.
- If you refuse to provide medical information, we will not be able to assess a claim for insured disability benefits for you.
You have the right to access your own Personal Information that is held by us, and if this information is incorrect, request that we correct this information.
We will not generally charge you for the making of the request, for correcting the Personal Information or for associating a statement with the Personal Information, however we reserve the right to recover reasonable costs in relation to requests to access Personal Information.
Accessing your Personal Information
You can access your account details at any time through our secure online member portal on our website. You may also access your Personal Information by contacting us by phone, web chat or in writing and request that we provide you with this information. You will be required to provide acceptable proof of your identity before we will be able to provide you with access to ensure your Personal Information is protected.
We will provide access to the information fairly and efficiently, in the manner you request if it is reasonable and practicable to do so and within a reasonable timeframe that will be agreed with you which will not be more than 30 days from your request.
Exceptional circumstances may arise which prevent us from providing you with access to your Personal Information. In these cases, we will advise you in writing why we cannot provide you with the information and mechanisms available to you should you want to lodge a complaint.
If we refuse to give access in the manner you request, we will take such steps as reasonable to give access in a way that meets the needs of us and you. This may include access being given through the use of a mutually agreed intermediary.
Correcting your Personal Information
To allow us to keep your Personal Information current, we ask that you let us know of any changes to your personal details.
We take reasonable steps to make sure the Personal Information collected, used or disclosed is accurate, up-to-date, complete and relevant. Where we believe that the Personal Information held is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information within a reasonable time.
If you believe the Personal Information we hold about you is incorrect, in some cases, such as your contact information, you will be able to update your account details online through MemberAccess. You can also provide the correct details by phone, web chat, email or advising the correct details on a form.
If the information is confirmed to be incorrect, we will correct it as quickly as possible and provide a confirmation to you that the correction has been made. In some cases, for example changes to your name or date of birth, we may require proof of your correct details before we make a change you request.
If we have previously disclosed Personal Information about you to another entity and it is corrected, we will advise the other entity of the correction if you request us to do so, unless it is impracticable or unlawful to do so.
Refusing to correct Personal Information
In the exceptional circumstances we have received a request to correct your Personal Information but are unable to make the correction you have requested, we will advise you in writing of the reasons for not making the correction you have requested and the mechanisms available should you wish to lodge a complaint.
If we refuse to correct your Personal Information, you can request that we associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. We will take such steps as are reasonable in the circumstances to associate the statement in such a way that will make the statement apparent to users of the information.
- if you wish to access your Personal Information; or
- if you believe that the privacy of your Personal Information has been compromised or is not adequately protected.
Once a complaint has been lodged, the privacy officer will respond to you within 30 days to address your complaint.
The contact details for our privacy officer are:
Phone (02) 9376 9400
Fax (02) 9231 6955
Postal Privacy Officer
Club Plus Super
GPO Box 3774
SYDNEY NSW 2001
If you are dissatisfied with the response from the Privacy Officer, you may also lodge a complaint with the Office of the Australian Information Commissioner to the following details:
By email: firstname.lastname@example.org
By phone: 1300 363 992
By post: GPO Box 5218 Sydney NSW 2001
The current version of the Policy will be available on our website.
This Policy is available free of charge. You may request a printed version of this Policy by contacting the Member Hotline on 1800 680 627, emailing us at email@example.com, web chat at or by mail to Locked Bag 5007, Parramatta NSW 2124.
As at 30 October 2019.