Privacy Policy

Collins SBA is committed to ensuring your privacy is protected. We comply with the Australian Privacy Principles (APPs) as contained in the Privacy Act 1988.

This policy was last updated 6 August 2015.

The privacy of your personal information has always been important to us at Collins SBA. In addition to complying with existing laws that govern confidential information that you provide to us, we are also required to comply with the Privacy Act and the Australian Privacy Principles.

This policy explains how we comply with the Privacy Act when collecting, using, disclosing, storing and destroying your personal information. It also explains how you can access or correct personal information we hold about you and what you can do if you think your privacy has been interfered with.

In addition to this policy, we are required to comply with a range of laws and professional standards relating to confidentiality and privacy for our clients.

Who are we?

We are a group consisting of:

  • SBA Financial Group Pty Ltd (ABN 17 073 859 346), which provides accounting and taxation services;
  • SBA Wealth Management Pty Ltd as trustee for the Ashe Unit Trust (ABN 58 585 824 199), which provides wealth advisory services as an authorised representative of SBA Advice Pty Ltd; and
  • Collins SBA Nominees Pty Ltd (ABN 87 104 489 330), which provides business administration and support services to the other two entities.

Collectively and separately these entities are known as Collins SBA. We also refer to each entity as being a member of the Collins SBA Group. These entities are related to each other within the meaning of the Corporations Act 2001 (Cth).

Throughout this policy we are referred to as Collins SBA, we or us. We refer to an individual as you.

What information does this policy cover?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Personal information may include sensitive information about the individual such as racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health, genetic or biometric information.

Credit information is personal information about you which is also:

  • identification information (including name, address, date of birth, sex, current or last employer, driver licence number, previous names and two previous addresses) when used in a credit context;
  • information about your current and past consumer credit liabilities;
  • information about other credit you have sought or obtained;
  • information about your repayment of other credit;
  • information held by a credit reporting body about you;
  • information about your previous defaults, payments and payment arrangements relating to credit provided to you;
  • information about your insolvency; and
  • information about court proceedings involving you.

When might this policy not apply?

In some cases we may act in a way other than described in this policy, however we will only do that with your informed consent or if required by law.

This policy does not apply to employee records used for employment purposes.

What personal information do we collect?

Wealth advice and lending services

To enable us to provide you with financial advice that is suitable for your investment objectives, financial situation and particular needs we need to collect and hold personal information about you. We collect personal information for the purposes of:

  • providing you with the advisory and/or lending services that you have requested;
  • managing our relationship with you; and
  • contacting you about products and services in which you may be interested.

The information we collect includes:

  • your name, contact details and date of birth;
  • employment details and history;
  • financial details including information about your financial needs and objectives, your current financial circumstances including your assets and liabilities, income, expenditure, insurance cover and superannuation;
  • details of your investment preferences and risk tolerance;
  • family circumstances and social security eligibility; and
  • any other information that we consider necessary.

The personal information collected may include sensitive information such as health information and memberships of professional or trade associations.

If we do not collect the information we require then we may be unable to provide you with the services you have requested.

Your financial adviser is an authorised representative of SBA Advice Pty Ltd, an Australian Financial Services Licensee.

Accounting, taxation and lending services

To enable us to provide taxation, accounting and lending services to you, we collect your personal information. We collect personal information for the purposes of:     

  • providing you with the accountancy, taxation and/or lending services that you have requested;
  • managing our relationship with you; and
  • contacting you about products and services in which you may be interested.

The information we collect includes:

  • your name, contact details and date of birth;
  • employment details and history;
  • financial details including information about your assets and liabilities, income, expenditure, superannuation, business activities and investments;
  • family circumstances and social security eligibility; and
  • any other information that we consider necessary.

The personal information collected may include sensitive information such as health information and memberships of professional or trade associations.

If we do not collect the information we require then we may be unable to provide you with the services you have requested.

As a registered tax agent (number 6854 9007), SBA Financial Group Pty Ltd is authorised by the Tax Agent Services Act 2009 to request your tax file number (TFN). You do not have to provide us with your TFN. However, quoting your TFN reduces the risk of administrative errors and having extra tax withheld. Failing to quote your TFN may prevent us from providing you with all the services you have requested. If you provide us with your TFN we will only disclose it to the ATO and we will only do so when necessary to conduct your affairs.

Credit information

We collect, hold, use and disclose your credit information for the purpose of providing you with credit, managing that credit and recovering any debts you owe to us. We will only disclose your credit information to another entity when permitted by law. This will only be with your consent, or to an entity that is managing credit on our behalf or collecting a debt from you.

We do not obtain credit reports on our clients. We do not report our clients’ defaults to credit reporting bodies.

In addition, we may collect credit information from you for the purpose of providing you with mortgage broking and lending services. We may disclose that information to lending providers. This will only be done with your consent.

Other information

We only collect personal information that is necessary for our functions or activities. We will ensure you are aware when we collect your personal information and the primary purpose of its collection. We will only collect sensitive information with your consent or where permitted by the Privacy Act.

There may be consequences if you do not provide us with all information sought from you. We will let you know what those consequences are when requesting the information. If you provide us with more information than we have requested we will destroy it unless it is necessary for our functions or activities.

The type of information we collect will depend on the reason we are collecting your information but may include contact details, employment and educational history (for prospective employees) and financial details (for prospective contractors).

How do we collect personal information?

If it is reasonable and practicable we will only collect your personal information from you. Generally your personal information will be collected when you meet with your adviser in person, provide your adviser with information over the telephone or with written material. We may need to collect personal information from third parties, such as your accountant or publicly available sources where it is unreasonable or impractical to collect it from you directly, or where we have your consent. This consent could be implied, for example where we are providing services to a family group and information about the whole family is collected from one individual.

How do we store personal information?

Your personal information is generally held in client files or a computer database. Your personal information may also be held in a secure archiving facility.

Normally correspondence and documentation is scanned and stored in our computer system, with originals returned to you or destroyed. In some circumstances we will store hard copy originals or return them to you.

We will seek to ensure that we take reasonable steps to ensure that the personal information that we hold is protected from misuse and loss and from unauthorised access, modification and disclosure. Some of the measures that we have adopted are having facilities for the secure storage of personal information, having secure offices and access controls for our computer systems.

We may store your information in the cloud or other types of networked or electronic storage. If your information is stored in this way (for example, using Dropbox), disclosures may occur to other countries. Overseas organisations may be required to disclose information we share with them under a foreign law.

We will also take reasonable steps to destroy or permanently de-identify personal information that we no longer need for any purpose for which may be used or disclosed under the Australian Privacy Principles. In general information is retained for seven years from the date it was last used. Certain information (for example, information which may have a bearing on capital gains tax calculations) may be kept indefinitely.

Please be aware that sending personal information by email or through our website may not be secure. If you are concerned about the security of sending information this way you should arrange alternative delivery of information, for example by registered post.

How do we use your personal information?

We will use and disclose your personal information for the purpose for which we collected it. We may also use your personal information for related purposes which you would reasonably expect. We will take reasonable steps to ensure the information we use is accurate, up-to-date, complete and relevant, having regard to the reasons why it is being used.

Sensitive information will be used and disclosed only for the purpose for which it was collected, a directly related secondary purpose, with your consent or as required or allowed by law.

We may use your personal information for the purpose of direct marketing to you where you would reasonably expect this. We may provide you with information about relevant products and services offered by Collins SBA or SBA Advice Pty Ltd. If you do not wish to receive direct marketing materials from us or our clients you can opt-out by contacting us. Our contact details are included with all direct marketing materials.

Who do we disclose personal information to?

One member of the Collins SBA Group may share your personal information with the other members of the Collins SBA Group so we can provide our services. This privacy policy applies to each member of the Collins SBA Group.

Where reasonably necessary for an approved purpose, we may disclose your personal information to:

  • other financial advisers and organisations involved in providing the financial advice you have requested (which may include ongoing service) such as fund managers (including SBA Advice Pty Ltd) and paraplanners;
  • brokers, insurance providers, superannuation trustees and product issuers in connection with the provision to you of the financial advice you have requested;
  • financial institutions or lenders in connection with the provision of lending or broking services to you;
  • organisations that assist us in operating our business such as those that provide administrative, financial, accounting, insurance, research, legal, computer or other business services;
  • your representatives or service providers such as your accountant, solicitor, tax agent, stockbroker or bank;
  • government authorities, professional organisations, auditors, insurers and other organisations when required by law; and
  • organisations that you have consented to your personal information being disclosed to.

If we sell, finance or restructure all or part of our business we may disclose your personal information to other organisations for that purpose, including as part of due diligence, sale of assets or transfer of customers.

We will seek to ensure that your personal information is not used or disclosed for any purpose other than:

  • the primary purpose for which it was collected or a related secondary purpose;
  • where you have consented to the use or disclosure; or
  • in other circumstances where the Australian Privacy Principles authorise the use or disclosure (for example, where disclosure is required by or authorised under law).

In order to provide you with our services, we may share your information with IT service providers and subcontractors outside Australia. We regularly engage providers in the Philippines, Vietnam and the United States of America. We normally make those disclosures on the basis of a reasonable belief that entities in those countries are subject to a law or binding scheme which protect your personal information in a way that, overall, is substantially similar to the way the Australian Privacy Principles protect your information. You can access mechanisms to enforce those schemes in those countries.

We will take reasonable steps to ensure the personal information we disclose to others is accurate, up-to-date, complete and relevant, having regard to the reasons why it is being disclosed.

We may also disclose your information to others where we have your consent.

How can you access personal information we have about you?

You can gain access to your personal information that we hold. This is subject to exceptions allowed by law such as where providing you with access would have an unreasonable impact upon the privacy of others. If we deny a request for access we will provide you with the reasons for this decision. To request access please contact us (see our details below).

We may charge you a reasonable fee to access that information, for example to recover the costs of photocopying or if we have to spend a significant amount of time to provide you with access. We may need to verify your identity before providing access to your personal information.

If we refuse you access to your personal information, we will provide you with an explanation for that refusal. We will try to provide you with access to your personal information within 14 days of receipt of your written request for access or 30 days where responding to the request is more complicated.

What if your personal information is not correct?

We endeavour to take reasonable steps to ensure that the personal information that we collect, use or disclose is accurate, complete and up-to-date. If you believe that any of the personal information that we hold is not accurate, complete or up-to-date please contact us (see our details below) and provide us with evidence that it is not accurate, complete and up-to-date.

If we agree that the personal information requires correcting we will take reasonable steps to do so. If we do not correct your personal information we will provide you with the reasons for not correcting your personal information. If you request that we associate with the information a statement claiming that the information is not accurate, complete and up-to-date we will take reasonable steps to comply with this request.

If we refuse to correct your personal information, we will provide you with a written explanation for that refusal. We will try to resolve all requests within 14 days of receipt of your written request or 30 days where the matter is more complicated. We will not charge a fee to correct that information.

How do you complain about interferences with your privacy?

If you are concerned about an interference with your privacy, this policy or the APPs please submit a complaint in writing, marked to the attention of our Operations Manager. We will consider and respond to your complaint within 10 working days. We will seek to resolve the complaint with you. We prefer to address all matters in this manner prior to a complaint being taken further.

How do you contact us if you have a privacy issue?

You can obtain further information on request about the way in which we manage the personal information that we hold or you can raise any privacy issues with us, including a complaint about privacy, by:

Email:           reception@collinssba.com.au

Post:             GPO Box 1082, Hobart, Tasmania 7001

Phone:         1300 265 722

Web:            http://www.collinssba.com.au/

Is there anyone else you can complain to?

You can make a complaint about interferences with your privacy to the Office of the Australian Information Commissioner. Their contact details are:

Email:           enquiries@oaic.gov.au

Post:             GPO Box 5218, Sydney NSW 2001

Phone:         1300 363 992

Fax:              02 9284 9666

Web:            http://www.oaic.gov.au/