COMMITTMENT

White Robinson & Company Pty Ltd is committed to providing you with the highest levels of client service. We recognise that your privacy is very important to you. The Privacy Amendment (Private Sector) Act, 2000 sets out a number of National Privacy Principles (NPPs). The new privacy requirements were introduced to increase the privacy rights of the public. White Robinson & Company Pty Ltd will support the new requirements and comply with them fully. Further information regarding privacy may be obtained by visiting the website of the Office of the Federal Privacy Commissioner at www.privacy.gov.au.

White Robinson & Company Pty Ltd believes that this Privacy Policy discloses how the personal information you provide to us, and our representatives, is collected, used, held, disclosed and disseminated.

White Robinson & Company Pty Ltd is required to meet particular legislative and regulatory requirements. In order to provide comprehensive financial planning advice to you, we are required to collect certain personal information from you. We encourage you to regularly check our website for any updates to our Privacy Policy.

YOUR PERSONAL INFORMATION

Personal information held by White Robinson & Company Pty Ltd may include the following information:

• your name, date of birth, current addresses, telephone/mobile/fax numbers, e-mail address;
• information regarding your dependents and family commitments;
• your occupation, employment history and details, family commitments and social security eligibility;
• your financial needs and objectives;
• your assets and liabilities (current and future), income, expenses;
• your superannuation and insurance details;
• your social security entitlements; and
• your risk profile details.

If you choose not to provide certain personal information or provide incorrect information, the advice and/or recommendations may be inappropriate or inadequate. You can deal with us anonymously where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.

HOW WE COLLECT PERSONAL INFORMATION

White Robinson & Company Pty Ltd collects personal information in a number of ways, including:

• directly from you, when you attend a face-to face interview;
• directly from you, when you provide information through a data collection form;
• directly from you, when you provide information by phone;
• directly from you via an email or the internet;
• directly from fund managers, superannuation funds, life insurance companies and other product issuers once authorisation has been provided by you; and
• directly from our referral partners(only name and phone number) only after referral partner has authorisation from you.

HOW WE USE YOUR PERSONAL INFORMATION

Primarily, your personal information is used in order to provide comprehensive and/or limited financial planning services to you.

From time to time, we may provide you with direct marketing material. This will include articles, questionnaires and newsletters that may be of interest to you. If, at any time, you do not wish to receive this information any further, you may contact us with this request. We will endeavour to meet your request within 2 weeks. We maintain a register for those individuals not wanting direct marketing material.

WHEN DO WE DISCLOSE YOUR PERSONAL INFORMATION

As we adopt a Code of Ethics under the Financial Planning Association of Australia, we are required to meet a level of professional standards. From time to time, we may need to provide the Association with access to your personal information to ensure that we are meeting our compliance requirements.

We collect information about you for the purpose of reporting to AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

The Corporations Act has provided the Australian Securities and Investments Commission with the authority to inspect certain personal information that is kept on our files about you.

For the purposes set out above, we may disclose your personal information to organisations outside White Robinson & Company Pty Ltd. The organisations to which we disclose information may include:

• superannuation fund trustees, insurance providers, fund managers and other product providers in order to implement your financial plan/recommendations;
• compliance consultants to ensure that our representatives are meeting our compliance standards;
• temporary staff to handle workloads during peak periods;
• professional advisers, including solicitors or accountants as authorised by you;
• information technology service providers to manage our IT systems;
• government and regulatory authorities and other organisations, as required or authorised by law;
• another authorised representative of White Robinson & Company Pty Ltd if necessary;
• a potential purchaser/organisation involved in the proposed sale of our business for the purpose of due diligence; and
• a new owner of our business that will require the transfer of your personal information.

In addition, our employees and the outsourcing companies/contractors are obliged to respect the confidentiality of any personal information held by White Robinson & Company Pty Ltd.

YOUR SENSITIVE INFORMATION

Without your consent we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or afflations, membership of professional or trade association, membership of trade union, details of health, disability, sexual orientation, or criminal record.

This is subject to some exceptions including:

• the collection is required by law; and
• when the information is necessary for the establishment, exercise or defence of a legal claim.

USING GOVERNMENT IDENTIFIERS

Although in certain circumstances we are required to collect government identifiers such as your tax file number, medicare number or pension card number, we do not disclose this information other than when required or authorised by law or unless you have consented to disclose this information to any third party.

HOW WE STORE AND SECURE YOUR PERSONAL INFORMATION

We keep your personal information in your client file. These files are accessible to authorised personnel only and are appropriately secured out of hours.

Your personal information may also be held on our computer database. All computer-based information is protected through the use of access passwords. Data is backed up regularly and stored securely off site.

It is a legislative requirement that we keep all personal information and records for a period of 7 years. Therefore, if you are no longer a client of White Robinson & Company Pty Ltd, we will maintain your personal information on or off site in a secure manner for 7 years. After this, we will ensure it is destroyed in a secure manner.

ENSURE YOUR PERSONAL INFORMATION IS CORRECT

White Robinson & Company Pty Ltd takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. To ensure we can maintain this level of accuracy and completeness, we recommend that you:

• inform us of any errors in your personal information as soon as possible; and
• update us with any changes to your personal information as soon as possible.

ACCESS TO YOUR PERSONAL INFORMATION

You have a right to access your personal information, subject to certain exceptions allowed by law. We ask that you provide your request for access in writing(for security reasons) to our Privacy Officer and we will (subject to certain exceptions) provide you with access to that personal information. Access to the requested personal information may include:

• providing you with copies;
• providing you with the opportunity for inspection; or
• providing you with a summary.

Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal.

COMPLAINTS RESOLUTIONS

Please contact our Privacy Officer if you wish to complain about any breach or potential breach of your privacy rights. Your complaint will be responded to within 3 days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Privacy Commissioner.

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