RJ Sanderson & Associates Pty Ltd Privacy Statement
ABN 71 060 299 783
Respecting your privacy and the law
The privacy of your personal information has always been important to us at RJ Sanderson & Associates Pty Ltd (‘RJS’) and our associated and related companies referred to below (‘the Group’). We are committed to respecting your right to privacy and protecting your personal information. We adhere to the Australian Privacy Principles and any applicable laws and codes affecting your personal information. Our staff are trained to respect your privacy in accordance with the law and our standards, policies and procedures.
We may also need to share your information with third parties. It is RJS’s policy to use the information within the Group’s companies to identify and make available to you a range of the Group’s services. This enables RJS to have an integrated view of you, our client.
You have the right to request us in writing that your personal information not be provided to other parties, however, that may mean that it is not possible to provide you with the products and services that you have requested. Where this is the case we will inform you in writing.
Members of the Group and a brief description of the services they provide, include:
- RJS Sanderson & Associates Pty Ltd ABN 71 060 299 783 (accounting services)
- RJS Wealth Management Pty Ltd ABN 24 156 207 126 (financial advising services)
- RJS Super Solutions Pty Ltd ABN 46 612 965 063 (SMSF advising services)
- RJS Loan Solutions Pty Ltd ABN 25 123 033 116, Australian Credit Licence Number 393942 (credit services)
- Modoras Pty Ltd ABN 86 068 034 908, Australian Financial Service License and Australian Credit Licence Number 233209 (Licensee)
Collecting your personal information
The Group collects and holds your personal information for the purposes of:
- Providing you with the relevant service (including assessing your application and identifying you);
- Managing and administering the service we provide to you; and
- Protecting against fraud where it is a banking, finance, or insurance product or service.
Group companies may also collect your personal information for the purpose of promoting and marketing products or services that might be of interest to you;
We collect your personal information when you fill out product or service documentation, an administrative form, or when you give us personal information over the telephone, or through a Group organisation’s website.
We may collect your personal information from third parties such as your employer, or a representative such as a legal adviser or accountant or publicly available sources of information.
The type of personal information we collect and hold
Personal information held by the Group may include identification information such as your name, address, phone numbers, email addresses, tax file number etc. Depending on the type of service or product you require or choose, we may also ask you for other personal information including:
- Employment information;
- Marital status, and family information or circumstances;
- Financial information such as your superannuation and other investment details;
- Business interests and trust structures;
- Your insurance, credit, financial and bankruptcy history;
- Date of birth, Gender, Past times, hobbies, family history;
- Details regarding any circumstances or assets you wish to insure; and
- Other personal information details which are needed depending on the type of financial product or service you require.
Your sensitive information
The collection of sensitive information is restricted by the national Privacy legislation. This includes information such as your racial or ethnic origin, political opinions, association memberships and details of health, disability etc.
This type of information is only collected with your consent and where required to provide you with the products, services or assistance you may require and the collection of this information is needed to provide these products, services and assistance.
How will we collect your personal information
We collect your personal information:
- Directly from you when you provide information by phone, in person or in documents;
- From third parties including related firms as listed as Members of the Group;
- From publicly available sources of information;
- When required to do so by Federal or State legislation;
- The organisations identified within this document;
Security of your information
We hold your personal information in:
- Our computer systems and electronic databases;
- Digital records and
- In hard copy or paper files.
We protect your personal information by:
- Stand by systems and system backups to deal with any business interruptions;
- Limiting physical access to our offices and premises;
- Limiting physical and electronic access to your personal information and our systems;
- Identifying whether third party providers with whom we deal have appropriate documented policies consistent with the Australian Privacy Principles;
- Maintaining technical security product to protect your personal data; and
- Destroying or de-identifying personal data and information, where required by law once such data is no longer required to be maintained by us.
- Staff training and through employment agreements and electronic user identifiers and passwords.
Using and disclosing your personal information
In order for the Group to meet your specific needs it may need to disclose your personal information to the type of firms and organisations described below. Where your personal information is disclosed we will seek to ensure that the information is held, used or disclosed consistently with the Australian Privacy Principles and any State Legislation and other applicable privacy laws and codes.
The relevant organisations are those:
- Involved in providing, managing or administering your product or service including
- Banking and finance organisations;
- Financial Planning service providers
- Trustee or custodial services
- Life or General insurance providers
- Group organisations who may wish to promote and market products or services that might be of interest to you;
- Who are external advisers and their service providers;
- Involved in maintaining, reviewing and developing our business systems, procedures and infrastructure;
- Involved in a transfer of all or part of the assets or business of a Group organisation;
- Involved in the payments system including financial institutions, merchants and payment organisations;
- Involved in a service or product planning and development;
- Which are your representatives including your legal advisers and accountants;
- As required or authorised by law;
- Where you have given your consent.
Other use and disclosure
If your personal information is subject to Australian Privacy Principles, we only will use and disclose your personal information for a secondary purpose if it is related to the primary purpose for which we collected it and where you would reasonably expect us to use or disclose your information for that secondary purpose. In the case of sensitive information, we will only use this information for the secondary purposes if it is directly related to the purpose of collection or where we are required or authorised by law to disclose your personal information and sensitive information. For example, to a Court in response to a subpoena or to the Australian Taxation Office, Centrelink or to the Australian Transaction Reports and Analysis Centre (AUSTRAC).
Use and disclosure of personal information for marketing
The Group is able to assist you in providing a large range of financial services, products and advice. An important part of our service to you is marketing, by being able to keep you up to date with new products and services which we think may be of benefit and interest to you.
In bringing this information to you, we use a large range of communication tools including mail, telephone, email and other internet based tools as well as direct and group presentations. Third party marketing service providers may combine the personal information we disclosed to them with information they already hold about you, to provide you with more relevant advertising about the products and services we can provide you.
Keeping your personal information accurate and up-to-date
We aim to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. We will take reasonable steps to make sure this is the case. This way we can provide you with better service. If you believe your personal information is not accurate, complete or up to date, please contact us.
Protecting your personal information
We store information in different ways including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, loss unauthorised access, modification or disclosure.
Your privacy on the Internet
We take care to ensure that the personal information you give us on our websites is protected.
For example, our websites have electronic security systems in place, including the use of firewalls and data encryption. Depending on the Group Company with which you deal, user identifiers, passwords or other access codes may also be used to control access to your personal information.
Please refer to the website of those Group companies with which you transact electronically for more information on our website specific privacy and security procedures.
Links to other sites
You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to ascertain their privacy standards, policies and procedures.
Overseas Service Providers and disclosure
Companies within our Group will, when necessary, disclose personal information to organisations and persons overseas. Instances when we will do this include:
- When we are authorised or required by an Australian law or a court/tribunal to do so;
- When we have engaged an overseas service provider to deliver services central to our financial service business operations.
Your personal information will only be disclosed to the extent it is necessary to perform our functions or activities.
These external service providers to whom your data may be provided are for our Group’s client service management system and the service providers for this are located in Indonesia and Sri Lanka. These external overseas service providers provide computer system, computer code support and service to the group. Also, our internal document management system is supported by a service provider located both within Australia and overseas in the Philippines.
In addition to the above our Group also utilises external service providers located in Sri Lanka and India, which provides Accounting administration service, and the Philippines, which provides project management, marketing support and database management
When you visit our website details may be recorded about your visit, such as time and date, your server address, pages accessed, time spent and type of browser. This information is used in an anonymous form for statistical purposes and as such cannot identify you individually.
Gaining access to your personal information
You can gain access to the underlying personal information and data the Group holds in relation to you. You can also ask for corrections to be made. If you would like to request access to your personal information we hold about you please contact us.
There are some circumstances where we are not required to give you access to your personal information. If we refuse your request we will give you written reasons if we deny access or confirmation.
Our response to your request could take up to 30 days from the receipt of your request. If we require further time we will write to you and advise you of the reason for the further time required. If such request incurs a fee, we will advise you of this.
Correction of personal information
You also have the right to request that we correct any inaccurate, out of date, incomplete, irrelevant or misleading personal information we may hold. We will take such steps that we regard as reasonable to make any correction required to ensure the information is accurate, up to date, complete, relevant and not likely to mislead. If we refuse to change or correct your personal information we will provide reasons for the refusal in writing to you. If we refuse to correct or change any personal information, you have a right to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will take any steps that are reasonable to associate that statement with all the records containing that relevant information.
Using Government identifiers
In certain circumstances we are required to collect government identifiers such as your TFN, Medicare Number or Pension Card number. We do not use or disclose this information other than when required or authorised by law or unless you have consented to disclose this information to athird party.
Dealing with us anonymously or through the use of pseudonyms
You have the option of not identifying yourself and dealing with us anonymously or through the use of a pseudonym, where it is lawful and practicable to do so.
Resolving your privacy issues
If you have any issues or a complaint that you wish to raise with the Group about the way in which we collect, use, hold or disclose your personal information or about a privacy related issue please use our complaint process so that we can help.
- You are always welcome to speak directly to our staff and they will do their best to resolve your issue. Alternatively, you can email your issue to firstname.lastname@example.org, write to us directly or contact us by phone. If investigation is required we will keep you advised of progress.
- If our staff are unable to resolve the matter it will be escalated to an appropriate Senior Manager of the Group.
- If we are unable to resolve your issue or complaint immediately, a response to that effect will usually be provided to you within 5 business days. We will endeavour to resolve client complaints within 45 days. However, this may not always be possible.
- Modoras will provide you with a written response to the issues in your complaint.
- If you are not satisfied with the outcome you may be able to access the services of an ASIC approved external dispute resolution scheme or other body, we have provided contact details of these below:
Office of the Australian Information Commissioner (OAIC)
Complaints must be in writing
Phone 1300 363 992
Director of Compliance
Office of the Australian
GPO Box 5218 Sydney NSW 2001
If you seek any further information from the Modoras Group about this policy, please contact our Privacy Officer reference point below:
Registered Address: Level 3, 50 – 56 Sanders Street, Upper Mt Gravatt QLD 4122
Postal Address: PO Box 6530, Upper Mt Gravatt QLD 4122
Telephone: (07) 3219 2066
Facsimile: (07) 3219 4432