Privacy Policy

Last revised: 15 June 2016

We respect and protect your privacy

Protecting our clients’ privacy is very important to us.  To ensure our compliance with the Privacy Act 1988 (Cth) (Privacy Act) and as part of our commitment to ensuring the safety of your private and confidential information, we have established and implemented this Policy.

This Policy applies to Edwards Marshall Advisory Pty Ltd ABN 18 600 878 555 and Edwards Marshall Financial Solutions Pty Ltd ABN 45 096 439 842  (referred to in this Policy as “we,” “us,” and “our”).

We are bound by the Privacy Act and the Australian Privacy Principles (APPs) set out in the Privacy Act.  This Privacy Policy sets out our approach to gathering personal information, and our approach to the use and dissemination of such information.

This Privacy Policy may be supplemented or amended from time to time.

If you have any questions or concerns regarding this Privacy Policy, please contact the Privacy Officer using the contact details below.

1.     Collection of information

What personal information do we collect?

'Personal information' means information or an opinion about an individual whose identity is apparent or can reasonably be ascertained.

In providing services to you, we may ask you to provide personal information about yourself, such as:

• your name and birth date;
• your contact information, including postal and residential addresses, telephone and facsimile numbers, and email addresses;
• your financial information (including bank account and other financial details);
• your tax file number (TFN);
• your occupation; and/or
• your employer details and other employment information (for example, salary and regular work hours).

We may also ask you to provide ‘sensitive information’ (e.g., data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation) about yourself, such as:

• your health information (for example, when you apply for insurance, or information we collect from medical practitioners when you make an insurance claim); and
• details of your dependants, including whether you have a legal or de facto spouse (including same sex spouse).

We will, where necessary, obtain your explicit consent to collect and use such information.

We will only collect personal information about you if you voluntarily submit it to us, including application forms you complete for our use, your use of our online facilities and through ongoing oral or written communications with you, or if you authorise us to obtain the information on your behalf.

We will generally hold your personal information as either physical records, records on our servers, and in some cases, records on third party servers, which may be located overseas.

What will we tell you when we collect your personal information?

Whenever we collect information from or about you, we will do everything we can to let you know:

• how to contact us;
• why we are collecting the information;
• whether we collect any of that information from third parties;
• the organisation or types of organisations to which we usually disclose that kind of information;
• if we are required by law to collect the information;
• the consequences for you if the information is not provided;
• how you may access and correct the information;
• how to complain about a breach of the APPs; and
• whether we will disclose your information to overseas recipients, and the countries in which such recipients are likely to be located.

When reasonable and practicable to do so, we will collect personal information directly from you or someone authorised by you and not from third parties.  Third parties that we may need to collect information from include your accountant or solicitor, employer, product issuer (eg financial institution, insurer or superannuation trustee), your medical practitioner (for insurance-related matters), or government agencies (including the Australian Taxation Office and Centrelink).

2.     Use and disclosure of information

When will we use and disclose your information?

In general, we will collect, hold, use and disclose personal information for the purposes of providing or offering goods and services to you, such as:

• providing financial advice to you;
• establishing and managing your investments and accounts;
• implementing your investment instructions;
• establishing and maintaining insurance protection for you;
• arranging superannuation contributions, transfers/rollovers or benefit payments;
• reporting the investment performance of your investment account(s); and
• keeping you up-to-date on other financial products and services offered by us.

We may also collect, hold, use and disclose your personal information for any purposes that you may reasonably expect, for any other purpose authorised by law, or for any other purposes disclosed to or authorised by you.  This may include disclosures to organisations that provide us with technical and support services or professional advice.

By providing us with your personal information, you consent to us using and disclosing your personal information for:

• providing you with news and information about our goods and services;
• purposes necessary or incidental to the provision of our goods and services;
• personalising your experience with our products and services, for example, via connectivity with social media services;
• sending you marketing and promotional material that we believe you may be interested in, either from any of our related entities or a third party business which we consider may be of interest to you; and
• seeking your feedback on our services, or for market research purposes.

You may at any time request that we discontinue sending you emails or other communications.

Your personal information may also be used and disclosed to protect our rights or property and, where appropriate, to comply with legal processes, which may include disclosures to law enforcement, regulatory or government agencies.

Disclosure of information to third parties

Information we collect may be disclosed to other entities within the Edwards Marshall group and third parties we engage to assist in providing services to you (e.g., administration support services), or in the course of carrying out your investment instructions.

Cross border disclosures of information

We may need to disclose your information to overseas recipients in carrying out your investment instructions. We may use third party service providers who hold or process data offshore (e.g., the Philippines). We may use cloud storage or third party servers to store information we hold about you, which may be located overseas.

Depending on the circumstances, the relevant countries in which your information is disclosed will vary such that it is not practicable to list them here.

We will not disclose your personal information to overseas recipients without your prior consent unless there are appropriate contractual or other measures in place requiring the overseas entity to protect your personal information in accordance with the Privacy Act and APPs.

3.     Access and correction

Who will see or have access to your personal information?

Unless we are required to provide your personal information to others for purposes of public safety and law enforcement, your information will only be seen or accessed by persons working with us or for us, including our contracted service providers, or as authorised by you.

Accessing and checking the personal information we hold about you

We will take reasonable steps to ensure that your personal information is accurate, complete, up to date, and relevant whenever it is used, collected or disclosed.  You have a right to request access to your personal information and to request its correction by contacting the Privacy Officer.  Subject to any legal restrictions we would be happy to advise you what personal information we hold about you if you request this.  We will respond to all requests within a reasonable period.

There may be some cost to you to cover the cost of retrieving and processing the information if it requires a significant amount of time to locate or collect your information or to present it in an appropriate form.  We will let you know in advance if any charges will apply.

We rely on the accuracy of the information you provide to us.  If you think that we may hold information about you that is incorrect in any way, please contact us and we will correct any errors or inaccuracies where required.

If we are unable to provide you with access to your information, or make any amendments which you have requested, we will advise you of our reasons.

If at any time you wish to know what information we are holding about you, you are welcome to request your details by contacting the Privacy Officer.

4.     Information security

We have in place reasonable commercial standards of technology and operational security to protect all personal information provided to us from misuse, interference, loss, unauthorised access, modification or disclosure.

5.     Questions and complaints

If you have any questions or concerns regarding your privacy, or if you would like to make a complaint about a possible breach of this Privacy Policy or the APPs, you may direct your correspondence to:

The Privacy Officer
Edwards Marshall Advisory Pty Ltd
GPO Box 2163
ADELAIDE  SA  5001
t: +61 8 8139 1111
f: +61 8 8139 1100
e: privacy@edwardsmarshall.com.au

We take all complaints seriously, and will respond to your complaint within a reasonable period.

If you believe that we have not adequately handled your complaint, you may complain to the Office of the Australian Information Commissioner whose contact details are as follows:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
t: 1300 363 992
e: enquiries@oaic.gov.au

Additional information

For further information about privacy and the protection of privacy, visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.

EMFS is a  corporate representative of Edwards Marshall Advisory Pty Ltd (EMA), ABN 18 600 878 555, AFSL 479792. Edwards Marshall Advisory Pty Ltd holds the licence to provide financial planning services and product advice. EMFS has four individual authorised representatives of Edwards Marshall Advisory Pty Ltd. They are James Scott-Young, Alana Lesan, Grant Edwards and Steven Wild.