Download Privacy Policy - Cummings Flavel McCormack

Cummings Flavel McCormack
Privacy Policy
In this Privacy Policy, Cummings Flavel McCormack (CFMC), ‘we’, ‘us’ and ‘our’ refers to the
partnership carrying on business under that name and includes any entity owned by CFMC.
At CFMC, we are committed to the protection and maintenance of your personal information
and are bound by the Australian Privacy Principles established under the Privacy Act 1988
(as amended by the Privacy Amendment (Enhancing Privacy Protection Act 2012).
The information below provides an outline of how we will protect your privacy.
Collection of your personal information
In the course of our activities we may collect your personal information that is reasonably
necessary for, or directly related to, the purpose of carrying out services that you have
engaged us to provide.
Most of your personal information will be collected directly from you. In some situations
where it is reasonable and practical to do so, we will collect personal information from a third
party, the Australian Taxation Office, your financial institution, financial planner or solicitor. In
these situations we will inform you of the information received from that third party.
We will also inform you if CFMC is likely to disclose personal information to overseas
recipients where it is reasonable and necessary for the provision of services to you, or by
law. We are required to take reasonable steps to ensure overseas recipients do not breach
Australian Privacy Principles or similar applicable law.
Typical personal information that we may collect would be your name, contact details,
gender, date of birth, tax file number, ACN, ABN, ARBN, employment details, income,
expenditure, investments, insurances, superannuation, bank account details, business
records and assets and liabilities.
Under Australian Privacy Principles you have the option of not identifying yourself or using a
pseudonym. This, however, may not be practicable for the provision of, and may limit the
extent of, services to you.
Some personal information is considered by the Privacy Principles to be sensitive
information e.g. tax file numbers and professional memberships, which will only be collected
with your consent if it is necessary to provide our services to you.
Use and disclosure of your personal information
The personal information that CFMC collects about you will only be used or disclosed for the
following purposes:
• To assist us to provide you with the primary services that you have requested;
• To help us with a secondary purpose that is related to the primary services requested but
only if you would reasonably expect us to use or disclose your information for this secondary
purpose; or
• To send you information that you have not specifically requested, such as our regular
newsletter or other information we consider relevant to your affairs. If you receive informative
material from us that you do not want to continue receiving, we ask that you please let us
know by email at [email protected] or write to us at Level 15, 390 St. Kilda Road,
Melbourne VIC 3004.
Other than in the above circumstances, CFMC will only use or disclose your personal
information if your consent has been obtained (expressly or implied); or as required for the
enforcement of the law at which time we would notify you.
Dealing with unsolicited personal information
If CFMC receives unsolicited personal information that we know could have been collected
from you, this information will be treated the same as if we had requested this personal
information. If the information is not reasonably necessary for the provision of our services to
you we will destroy or de-indentify the information as soon as practicable, unless it is
unlawful or unreasonable to do so.
Keeping your personal information up to date and correct
We aim to ensure that all personal information we collect, hold, use or disclose is up to date,
accurate and complete. You are able to gain access to personal information that we hold
about you and update this information by contacting your relationship director or manager, or
alternatively, you can contact our Privacy Officer, whose contact details are at the conclusion
of this policy. Upon such contact we undertake to respond within 30 days.
Keeping your personal information secure
We will take all reasonable steps to protect your personal information held by us from
misuse, loss, interference and from unauthorized access, modification or disclosure.
Our security measures include:
• Physical security- Restricted access to our premises and physical records;
• Computer & network security- Password protection, firewalls and virus checks to help
prevent access to electronic information by unauthorized persons;
• Personnel security-Clauses in employee agreements requiring confidentiality and the
provision of training in security awareness, practices and procedures;
• Information no longer required to be held by us to provide services, or for compliance, is
destroyed, permanently de-indentified or returned to you.
Adoption, use or disclosure of government identifiers
CFMC will not adopt, use or disclose government agency identifiers, for example tax file
numbers, as our primary means of identifying you, unless it is required or authorised by law.
Website
When visiting our website we collect statistical data which is not personally identifiable in
order to make our sites more navigable and user friendly.
Where Cummings Flavel McCormack facilitates event registration, the use or disclosure of
information provided is subject to this policy.
Would you like more information on our privacy policy?
The CFMC Privacy Policy is available on our website or may be obtained by contacting the
Privacy Officer. If you have any queries or complaints about our compliance with the
Australian Privacy Principles, or if you would like more information about the way we
manage personal information, please contact our Privacy Officer on (03) 9252 0800 during
normal business hours or in writing using the contact details below.
We undertake to respond to you within 30 days. If not satisfied with our response, you may
take your complaint in writing to the Office of the Australian Information Commissioner,
whose details are also below.
Contact details
Privacy Officer
Cummings Flavel McCormack
Level 15, 390 St. Kilda Road
Melbourne VIC 3004
Ph (03) 9252 0800
Fx (03) 9252 0801
Email: [email protected]
Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Ph 1300 363 992
Fx (02) 9284 9666
Email: [email protected]