Privacy Policy
Version: 5
Issue Date: 30th May 2011
PLUM GROVE’S COMMITMENT
Plum Grove Pty Ltd (henceforth, "Plum Grove" or "Plum Grove Pty Ltd" refers to Plum Grove Pty Ltd and its subsidiaries) 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). Our aim is to both support and ensure that we comply with these principles. Further information on privacy in Australia may be obtained by visiting the website of the Office of the Federal Privacy Commissioner at http://www.privacy.gov.au.
Plum Grove’s Privacy Policy discloses how the personal information you provide to us, and our representatives, is collected, used, held, disclosed and disseminated.
Plum Grove collects information about you to meet particular legislative and regulatory requirements including for the purpose of reporting to AUSTRAC under the Anti Money Laundering and Counter Terrorism Financing Act 2006. In order to provide a comprehensive financial product advice to you, we are required to collect certain personal information from you.
We encourage you to check our website regularly for any updates to our Privacy Policy.
YOUR PERSONAL INFORMATION
Personal information held by Plum Grove 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.
• your financial needs and objectives;
• your assets and liabilities (current and future), income, expenses;
• 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.
HOW WE COLLECT PERSONAL INFORMATION
Plum Grove collects personal information directly from you or from third parties once authorisation has been provided by you. You have a right to refuse us authorisation to collect information from a third party.
HOW WE USE YOUR PERSONAL INFORMATION
Primarily, your personal information is used in order to provide financial product advice (grain derivatives and foreign exchange) to you. We may also use the information that is related to the primary purpose and it is reasonable for you to expect the information to be disclosed.
Although in certain circumstances we are required to collect government identifiers such as your tax file number or drivers licence number, we do not use of disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.
From time to time, we may provide you with direct marketing material. This will include articles and newsletters that may be of interest to you. We maintain a register for those individuals not wanting direct marketing material. 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 WE DISCLOSE YOUR PERSONAL INFORMATION
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 Plum Grove. The organisations to which we disclose information may include:
• compliance consultants to ensure that our representatives are meeting our compliance standards;
• paraplanning contractors or temporary staff to handle workloads during peak periods;
mailing houses;
• your professional advisers, including your solicitor or accountant 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 representative of Plum Grove if necessary;
• a potential purchaser/organisation involved in the proposed sale of our business for the purpose of due diligence. Disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them; 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 Plum Grove.
Plum Grove takes its obligations to protect your information seriously, this includes when we operate throughout Australia and overseas, as part of our operations some uses and disclosures of your information may occur outside your State of Territory and/or outside of Australia. In some circumstances we may need to obtain your consent before this occurs.
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 and subject to confidentiality requirements.
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 Plum Grove, 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.
Personal information will be treated as confidential information and sensitive information will be treated highly confidential.
ENSURE YOUR PERSONAL INFORMATION IS CORRECT
Plum Grove 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) 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.
If charges are applicable in providing access to you, we will dislose these charges to you prior to providing you with the information.
Access to your information may be denied if:
• providing access would pose a serious threat to the life or health of a person;
• providing access would have an unreasonable impact on the privacy of others;
• the request for access is frivolous or vexatious;
• the information is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
• providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
• providing access would be unlawful;
• denying access is required or authorised by or under law;
• providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.
Should we refuse you access to your personal information, we will provide you with an explanation for that refusal.
DEALING WITH US ANONYMOUSLY
You can deal with us anonymously where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.
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 10 days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Privacy Commissioner.
OUR WEBSITE
Plum Grove’s website provides links to third party websites. The use of your information by these third party sites is not within the control of Plum Grove and we cannot accept responsibility for the conduct of these organisations. Other websites are not subject to our privacy standards. You will need to contact or review those websites directly to ascertain their privacy policies.
You may register with us to receive newsletters and other information. By doing so, your name and email address will be collected and stored on our database.
If you do not wish to receive any further information from us, or you wish to update your registration details, please email your request to us. We will endeavour to meet your request within 2 weeks.
Our website utilises cookies to provide you with a better user experience. Cookies also allow us to identify your browser while you are using our site – they do not identify you. If you do not wish to receive cookies, you can instruct your web browser to refuse them.
HOW TO CONTACT US
If you have any questions in relation to privacy, please contact us between 9.00 am and 5.00 pm, Monday to Friday. Alternatively, you can:
Use the contact us page on the website to send your questions and comments via email.
Click here contact us.