What is personal information and how do we collect it?
Personal information is information or an opinion about an individual from which they can be reasonably identified. Depending on the circumstances, we may collect personal information from the individual in their capacity as an investor, including potential investors, employees, job applicants or any third parties we engage. .
In the course of providing products and services we may collect and hold personal Information including names, addresses and other contact details, dates of birth and financial information and sensitive Information including government identifiers (such as TFN), nationality, country of birth, professional memberships, family court orders and criminal records.
As part of our recruitment processes for employees and contractors, we may collect and hold personal information including names, addresses and other contact details, dates of birth, financial information, citizenship, employment references, regulatory accreditation, media, directorships, property ownership and driver’s licence information. We may also collect sensitive information including government identifiers (such as TFN), nationality, country of birth, professional memberships, family court orders and criminal records.
Generally, we will seek consent from the individual in writing before we collect their sensitive information (including health information).
Collection of personal information
The collection of personal information depends on the circumstances in which Monash Investors is collecting it. If it is reasonable and practical to do so, we collect personal information directly from the individual.
We have, where possible, attempted to standardise the collection of personal information by using specifically designed forms (e.g. our Application Forms). However, given the nature of our operations we often also receive personal information by email, letters, notes, via our website, over the telephone, in face-to-face meetings and through financial transactions.
We may also collect personal information from other people (e.g. a third-party administrator, referees for prospective employees) or independent sources. However, we will only do so where it is not reasonable and practical to collect the personal information from the individual directly.
We may collect information based on how individuals use our website. We use ‘’cookies’’ and other data collection methods to collect information on website activity such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to our website. This information is collected to analyse and improve our website, marketing campaigns and to record statistics on web traffic. We do not use this information to personally identify individuals.
We may be provided with personal information without having sought it through our normal means of collection. This is known as “unsolicited information” and is often collected by misdirected postal and electronic mail, employment applications sent to us that are not in response to an advertised vacancy and additional information provided to us which was not requested. Unsolicited information obtained by us will only be held, used and or disclosed if it is considered as personal information that could have been collected by normal means. If that unsolicited information could not have been collected by normal means then we will destroy, permanently delete or de-identify the personal information as appropriate.
We only collect sensitive information if it is reasonably necessary for one or more of these functions or activities, and we have the individuals consent necessary to lessen or prevent a serious threat to life, health or safety another permitted general situation. We may share sensitive information to other entities in our company group, but only if necessary for us to provide our products or services.
How do we use and store personal information
We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by the individual, or for an activity or purpose which the individual has consented.
Our uses of personal information include but are not limited to providing one or more of our financial services or products; assessing an application for a financial product or service and/or communicating with the individual about the products and services that we offer. With regard to shareholders in the LIC, information such as your bank account details and tax file number (TFN) are collected by the share registry (Boardroom Pty Limited).
We may also need to collect personal information to comply with our legal obligations, such as under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act and AML/CTF Rules). This personal information is collected for investors in the Fund by the Fund’s unit registry (Link Fund Solutions Pty Limited).
It may be necessary for us to disclose personal information to certain third parties in order to assist us with one or more of our functions or activities. This may include organisations providing fund administration, unit and share registry, audit and tax, marketing and fund-raising, recruitment, payroll, superannuation, insurance, management consulting, financial and legal advisory, banking and technology services.
We may share personal information with other bodies corporate within our company group, but only if necessary for us to provide our products or services.
Storage and security of personal information
We store personal information in a variety of formats including on databases, in hard copy files and on personal devices, including laptop computers, third party storage providers such as cloud storage facilities and paper based files.
We take all reasonable steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.
These steps include, but are not limited to:
- Restricting access and user privilege of information by staff depending on their role and responsibilities.
- Ensuring staff do not share personal passwords.
- Ensuring hard copy files are stored in lockable filing cabinets in lockable rooms. Staff access is subject to user privilege.
- Ensuring access to our premises is secured at all times.
- Ensuring our IT and cyber security systems, policies and procedures are implemented and up to date.
- Ensuring staff comply with internal policies and procedures when handling the information.
- Undertaking due diligence with respect to third party service providers who may have access to personal information, including customer identification providers and cloud service providers, to ensure as far as practicable that they are compliant with the Australian Privacy Principles or a similar privacy regime.
The destruction, deletion or de-identification of personal information we hold that is no longer needed, or required to be retained by any other laws.
Our public website may contain links to other third-party websites outside of Monash Investors. We are not responsible for the information stored, accessed, used or disclosed on such websites and we cannot comment on their privacy policies.
Disclosure of personal information
Personal information is used for the purposes for which it was given to us, or for purposes which are directly related to one or more of our functions or activities. Personal information may be disclosed to government agencies, related entities and other recipients from time to time, if the individual has given consent, or would reasonably expect the personal information to be disclosed in that manner.
We may disclose personal information without consent or in a manner which an individual would reasonably expect if we are required to do so by law, the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety, another permitted general situation applies and disclosure is reasonably necessary for a law enforcement related activity.
The quality of personal information
We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up-to-date, including at the time of using or disclosing the information. If we become aware that the personal information is incorrect or out of date, we will take reasonable steps to rectify the incorrect or out of date information.
Access and correction of personal information
Individuals may submit a request to us to access the personal information we hold, or request that we change the personal information. Upon receiving such a request, we will take steps to verify the individual’s identity before granting access or correcting the information.
If we reject the request, you will be notified accordingly. Where appropriate, we will provide the reason/s for our decision. If the rejection relates to a request to change personal information, an individual may make a statement about the requested change and we will attach this to their record.
An individual can make a complaint about how we manage personal information by notifying us in writing as soon as possible. We will respond to the complaint within a reasonable time (usually no longer than 30 days) and we make seek further information in order to provide a full and complete response.We do not charge a fee for the handling of complaints.
If the individual is not satisfied with our response, they may refer the complaint to the OAIC. A complaint can be made using the OAIC online Privacy Complaint form or by mail, fax or email. A referral to OAIC should be a last resort once all other avenues of resolution have been exhausted.
How to contact us
- emailing firstname.lastname@example.org
- calling +61 29237 8862
- writing to our Privacy Officer at Level 5, 139 Macquarie Street, Sydney NSW 2000.
If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so.
Changes to our privacy and information handling practices