1. YOUR PRIVACY
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”).
2. PERSONAL INFORMATION WE COLLECT
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. Primarily this is to identify you when you are dealing with us.
This personal information may include:
- your name and date of birth;
- your contact details including your address, phone number(s) and email;
- your employment details;
- your Tax File Number(TFN) ( if you have chosen to provide it);
- your contribution history;
- your nominated beneficiary details; and
- your benefit payment and claims history.
We may also collect health information about you in connection with insurance benefits provided to you through the Fund.
Your health information is not only personal information but also sensitive information and we will not collect your sensitive information without your prior consent.
3. YOUR RIGHTS TO PRIVACY
You have the option of not identifying yourself, or of using a pseudonym, when dealing with us in relation to the following matters:
- when you browse the websites, we do not collect your personal information; and
- you can make a general inquiry without providing your personal details by telephone.
The option of remaining anonymous however is very limited given the nature of information needed for us to provide you with our services.
3.2 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. For example, if you do not provide us with your TFN additional tax may be taken out of your account.
4. HOW WE COLLECT AND HOLD PERSONAL INFORMATION
4.1 Collection of Personal Information
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 or through our contact with you or your employer. 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;
- 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
- 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 a financial adviser you refer us to and authorise us to talk to;
- information that is publicly available;
- professional associations;
- health care professionals specific to insurance underwriting and/or claims; and
4.2 Circumstances where we may collect your personal information without consent
The Privacy Act permits us to collect personal information without consent, where required by law or court order.
4.3 Information collected from our website
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 you. 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.
4.4 Disposing of unsolicited information collected
In the event that we ‘collect’ unsolicited personal information, 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.
4.5 How your personal information is held
Any personal information received is held by us, our Administrator or our Insurer on your behalf.
Your personal information may be held in paper-based and electronic files. We, our Administrator and Insurer, 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, our Administrator and Insurer all have physical security controls at our premises and in respect of electronic files have secure electronic networks.
Members can access their account online by using their login and unique password. The traffic between the Fund’s website and the member’s browser is encrypted.
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 – that are required by law to review the Fund’s accounts for compliance with accounting standards and internal controls;
Mailing companies – that compile and send out documents to members such as annual statements;
Market research companies – that undertake research and client satisfaction surveys on our behalf and on behalf of the Fund;
Our lawyers or service providers – that are contracted to perform services for or give advise to the Trustee; and
Regulators - where disclosure is required by law to the Australian Taxation Office (ATO), the Australian Prudential Regulation Authority (APRA), the Australian Securities and Investments Commission (ASIC) and the Australian Transaction Reports and Analysis Centre (AUSTRAC).
Unless disclosure is required by law, we ensure parties who receive information about participants have appropriate systems in place to comply with applicable privacy laws before permitting them to handle information.
5. PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
The purpose of collecting, holding, using and disclosing your personal information is so that we can provide you with the services and benefits that the Fund offers.
Unless you have agreed, we will only use and disclose your personal information for:
- the purpose for which it was given to us; and
- related purposes which you would reasonably expect.
We will use and disclose 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;
- to verify your identity;
- to help you combine you super accounts and check if you have lost super when you ask us to;
- to give to other superannuation funds if you transfer your investment to another fund;
- to provide you with information about products and services, which we consider may be of interest to you. 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;
- when engaging third party providers to perform services for the Fund which involves third parties handling personal information;
- to research, develop and improve our services, including testing and improving systems for the management of the services provided;
- for security and audit purposes, service monitoring, internet traffic monitoring, trouble shooting, maintenance, to protect against and identify security breaches, inappropriate behaviour, fraud and unauthorised access to our IT systems;
- manage and resolve complaints;
- to and from your employer where relevant for the management of superannuation contributions; and
- where required to do so by Law.
5.1 Financial Advisers
Where you have consented, we may provide your personal information to a financial adviser.
6. CROSS-BORDER DISCLOSURE
Generally, we will not be required to disclose personal information to overseas recipients. There may be some instances, though, where personal information is required by overseas authorities or pension schemes where information is required for benefit payment purposes. In the event that we are required to disclose your personal information for cross-border disclosure purposes, you will be advised accordingly.
7. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
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.
7.1 Accessing your personal information
To access your personal information, you may contact us by phone or in writing and request that we provide you with this information. You will be required to provide acceptable proof of identity with your request 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 an appropriate format and within a reasonable timeframe that will be agreed with you. We may recover reasonable costs in relation to requests to access personal information.
Exceptional circumstances may arise which prevent us from providing you with access to your personal information because of reasons outlined in the APP’s. 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.
To access your personal information you may call us on 1800 680 627 or mail Club Plus Super at Locked Bag 5007, Parramatta NSW 2124.
7.2 Correcting your personal information
If you believe the personal information we hold about you is incorrect, you may also notify us of this by using the contact details above. 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 the exceptional circumstances we have received a request to correct your personal information but are unable to implement the correction you have requested, we will advise you in writing of the grounds of refusal and mechanisms available should you wish to lodge a complaint.
8. INQUIRIES AND COMPLAINTS
- 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 a reasonable timeframe to address your complaint.
The Contact Details for our Privacy Officer are:
(02) 9376 9400
(02) 9231 6955
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
As at 27 October 2016