Privacy is important to us
We respect the confidentiality of information and the privacy of individuals. We are bound by the Commonwealth Privacy Act and the National Privacy Principles.
This Policy Statement will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment.
Why do we collect personal information?
Our business is to administer investment portfolios for our clients. To do this effectively, we need to collect a certain amount of personal and financial information.
We also keep our clients informed of our business activities and of the products and services we provide. Collecting personal information also allows us to meet legal obligations we might have.
What kind of personal information do we ask for?
The type of personal information we may collect can include (but is not limited to) name, address, date of birth, contact details, income, assets and liabilities, investment and cash account balances, tax and financial statements and employment details.
We obtain most of the information directly from our customers through application or other forms, but we may also obtain information from other sources.
We may ask for other information voluntarily from time to time (for example, through market research, surveys or special offers) to enable us to improve our service or to consider the wider needs of our customers or potential customers.
How do we use the information we collect?
The personal information we hold is used for establishing and managing the services we provide, enhancing customer service and providing ongoing information or opportunities that we believe may be relevant and of interest to our clients.
Who may we disclose information to?
Personal information may be disclosed to:
- companies in the Praemium group (ASX:PPS), who provide and host the software we use to provide our service.
- employees or contractors of Shoebox, external service providers and advisers who have been contracted to provide us with administrative, financial, research or other services,
- credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law
- credit reporting or reference agencies or insurance investigators
- any person or company which has expressed an interest in a joint venture with, acquisition of or a merger with the business of Shoebox, and who:
- is undertaking due diligence investigations,
- has signed a non-disclosure agreement with us, and
- with regard to the information held on any particular person, anyone authorised by that person.
Generally, we require that organisations and people both inside or outside of Shoebox who have access to personal information acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and agree to comply with the National Privacy Principles and this policy.
Management of personal information
Shoebox trains its employees in the legal and ethical bases of the requirements to respect the confidentiality of customer information and the privacy of individuals. Shoebox regards breaches of privacy very seriously and will impose appropriate penalties if breaches occur, including dismissal and legal action.
Shoebox has appointed a Privacy Officer who has clear accountability for Shoebox’s compliance with this statement, the Privacy Act and our confidentiality obligations.
How do we store personal information?
Safeguarding the privacy of information is important to us, whether such information is acquired and transmitted personally, by phone, by mail, over the internet, via other electronic media, or in any other way. We hold personal information in a combination of computer storage facilities and paper-based files and records, and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.
We may need to maintain records for long periods of time. However, when we consider information is no longer needed, we will securely destroy the relevant records.
Clients can check what personal information we hold
Under the Commonwealth Privacy Act, clients have the right to obtain a copy of any personal information which we hold about them and to advise of any inaccuracies. The Act does set out some exceptions to this.
An application form specifying the information required will be available from Shoebox offices. We will acknowledge a request for information within 14 days. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested. We will advise the likely cost in advance.
If Shoebox’s proposed resolution of a complaint is not considered satisfactory to the complainant, it can be escalated to the Commonwealth Privacy Commissioner by calling the hotline on 1300 363 992.