The information contained on this website has been provided as general advice only. The contents have been prepared without taking into account your personal objectives, financial situation or needs. You should, before you make any decision regarding any information, strategies or products mentioned on this website, consult your own financial advisor to consider whether that is appropriate having regard to your own objectives, financial situation and needs.
Prime Advisory Pty Ltd and its associated entities (us, our, we or the company) understands the importance of the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and we recognise the importance of protecting and maintaining the privacy of your personal information.
What personal information do we collect?
The type of personal information that we collect about you will depend on the nature of our engagement and dealings with you. The extent of the information requested, how we use it, and its disclosure are determined by our obligations, the obligations of entities that provide services to us and product issuers under financial services laws, taxation laws, superannuation laws and the Anti-Money Laundering and Counter-Terrorism Financing Act.
Some laws require us to collect information and verify your identity before we are able provide services to you. We may be required to request your Tax File Number. You are not required to provide your Tax File Number to us, however there may be consequences for not doing so.
If you do not allow us to collect all your personal information that we request, we may not be able to deliver any services to you.
It may be necessary in some circumstances for us to collect sensitive information about you to provide specific services to you. Sensitive information includes information about a person’s race, gender diversity, sexual orientation, disability, ethnic origin, political opinions, heath, religious or philosophical beliefs and criminal history. We will only collect and use sensitive information with your consent, in accordance with applicable laws or in a de-identified aggregated manner.
As a professional financial services provider our ability to provide you with a comprehensive and appropriate advisory service is dependent on us collecting personal information about you. The law, in particular the FASEA Code of Ethics, requires that we act with integrity and in the best interests of our clients (Standard 2), that all advice and product recommendations must be in the best interests of our clients (Standard 5) and that we must take into account the broad effects arising from the client acting on our advice and actively consider the clients broader, long-term interests and likely circumstances (Standard 6). Therefore, we collect personal information for the purposes of:
• Providing you with the advisory services that you have requested.
• Managing our relationship with you.
The information we collect includes:
• Your name, address, and contact details
• your date of birth
• your financial needs and objectives (including your retirement plans)
• your employment details and employment history
• details of your current financial circumstances, including your assets and liabilities, income, expenditure, insurance cover and superannuation
• details of your investment preferences and aversion to, or tolerance to risk
• information about your family commitments and social security eligibility, and
• other details of your personal circumstances that may affect the advice.
We collect most personal information about you, directly from you or (if that is unreasonable or impractical) from a third party who you have authorised to provide such information to us. Generally, your personal information will be collected by either meeting with our advisers or completing a data collection form. We may also collect information from you via the telephone, mail, or e-mail. From time to time additional and/or updated personal information may be collected through one or more of these methods.
We hold this information in a combination of electronic formats and in paper form.
Your financial advisers are authorised representatives of Paragem Pty Ltd (AFSL 297276).
Accounting & Taxation
To enable us to provide taxation, accounting, and lending services to you, we collect your 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
The information we collect includes:
• Your name, contact details and date of birth
• Tax File Number
• Employment details and history
• Bank Account Details
• 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 66694005), PrimeAccounting 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 that 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.
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 if required 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 directly from you. We may need to collect personal information from third parties, such as your accountant or previous 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?
We store your personal information in a variety of ways, which include both electronic and paper form. 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 always seek to take reasonable steps to ensure that the personal information that we hold is protected from misuse, loss, 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 kept in this way, 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 require 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 it was collected. We may also use your personal information for related purposes which you would reasonably expect. We will take reasonable steps to ensure the information that we use is accurate, up-to-date, complete, and relevant, having regard to the reasons why it is being used. Sensitive information will only be used and disclosed for the purpose for which it was collected. It may also be disclosed for 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 PrimeAdvisory. If you do not wish to receive direct marketing materials from us, you can opt-out by contacting us. Our contact details are included with all direct marketing materials.
Who do we disclose personal information to?
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 that you have requested (which may include ongoing service) such as fund managers and paraplanners; brokers, insurance providers, superannuation trustees, financial institutions; organisations that assist us in operating our business such as those that provide administrative, financial, accounting, insurance, research, legal, computer or other business services. We may also disclose information to your representatives or service providers such as your accountant; solicitor; tax agent; stockbroker; or bank; government authorities; professional organisations; auditors; insurers, and other organisations where required by law. In addition to this we may also provide or disclose information to 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 the 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 and/or software providers who store data in the cloud. This means your personal information may be located overseas. We normally make those disclosures based on a reasonable belief that entities in other 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. We will take reasonable steps to ensure the personal information that we disclose to authorised parties is accurate, up-to-date, complete, and relevant, having regard to the reasons why it is being disclosed. We will only disclose your information to others where we have your consent.
Visiting our Website and Online automatic collection of personal information
We also use analytical tools, such as Google Analytics, to gather information about the number of visitors coming to our site. No identifying information is collected during this process.
Our website may include functionality that enables information sharing via third party social media applications, such as the Facebook Like button and LinkedIn. These social media applications may collect and use information regarding your use of our website. Any personal information that you provide via such social media applications may be collected and used by members of that social media application separate to us and are subject to the privacy policies of the relevant companies that provide the applications. We do not have control over, or responsibility for, those companies or their use of your information.
Any personal information that you provide on any PrimeAdvisory social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.
Employees and potential employees
When recruiting and employing staff, we collect personal information such as your name, address, personal details, telephone numbers, email address and other information specific to recruiting employment activities. This can include, but is not limited, to previous work experience, education, references, tax file number and superannuation details.
Destroying personal information
Any personal information we hold will be maintained to comply with legislative and professional requirements, after which time the information will be securely destroyed. Where the information is paper based, it will be shredded and if held electronically will be deleted from our onsite and offsite storage systems.
How can you access personal information we have about you?
You can obtain your personal information that we hold by either writing or emailing us by using our details below. We may charge an administration fee for the provision of this information, and you may also need to verify your identity before we provide any personal information.
We will try to provide your personal information within 14 days of receipt of your written request or 30 days were responding to a request which is more complicated. If we deny your request for information, we will provide you with the reasons for this decision.
What if your personal information is not correct?
At PrimeAdvisory, we 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 and provide evidence that the information is not accurate, complete, or 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 it. 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.
Notifiable Data Breaches
From February 2018, the Privacy Act includes a new Notifiable Data Breaches (NDB) scheme which requires us to notify you and the Office of the Australian Information Commissioner (OAIC) of certain data breaches and recommend steps you can take to limit the impacts of a breach (for example, a password change).
The NDB scheme requires that we notify OAIC about any breach that is likely to result in serious harm to affected individuals. There are exceptions where notification is not required. For example, where we have already taken appropriate remedial action that removes the risk of serious harm to any individuals.
If we believe there has been a data breach that impacts your personal information and creates a likely risk of serious harm, we will notify you and the OAIC as soon as practicable and contact you about the nature of the breach, the steps we are taking and what you can do to reduce the impacts to your privacy.
If you believe that any personal information, we hold about you has been impacted by a data breach, you can contact us using the contact details below.
How do you complain about interferences with your privacy?
If you have a question or complaint about how your personal information is being handled by us, or are concerned about an interference with your privacy, please contact us first by using the contact details below.
We will acknowledge your complaint as soon as we can after receipt of your complaint. We will let you know if we need any further information from you to resolve your complaint.
We aim to resolve complaints as quickly as possible. We strive to resolve complaints within ten (10) business days, but some complaints may take longer to resolve. If your complaint is taking longer, we will let you know what is happening and a date by which you can expect a response.
We will seek to resolve the complaint with you.
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:
Is there anyone else you can complain to?
We expect our procedures will deal fairly and promptly with your complaint. But if you are still not satisfied you can make a written complaint to the Office of the Australian Information Commissioner.
‘Liability limited by a scheme approved under Professional Standards Legislation’.