We take steps to ensure that appropriate standards of privacy practice and security are applied whenever we handle personal information.
What personal information does Eley Griffiths Group collect?
Eley Griffiths Group only collects personal information that is necessary to assist us in providing our services to our clients. Eley Griffiths Group generally collects personal information such as name, phone numbers, address, email address, banking details, date of birth, country of residence, investment details, payroll details, taxation details (including Tax File Number) and other accounting, audit and financial services related information.
We also collect personal information from you if you apply for a job with the Eley Griffiths Group.
If you provide us with personal information that we have not requested (unsolicited personal information) we will, unless otherwise required or permitted by law, delete or destroy it as soon as possible after receiving it.
Generally, we do not collect sensitive information but we may be required or permitted by law or Court or Tribunal order to collect certain personal information about you. Sensitive information includes information relating to: race, political or religious beliefs, sexual orientation and sexual life, criminal convictions, membership of a trade association and/or trade union, health information and details published in Politically Exposed Person (PEP) lists, criminal watch lists, United Nations Sanctions lists and the Australian Department of Foreign Affairs and Trade lists or EU lists of a similar nature (for Anti-Money Laundering Counter-Terrorism Financing and Autonomous Sanctions purposes).
How do we collect your personal information?
Eley Griffiths Group collect personal information from you directly or your authorised representative when you or they interact with us. This can be in person, in documents you give us, from telephone calls, emails, your access to our website or from transactions you make. We may also collect personal information from third parties including public sources, your adviser(s), employer (or its affiliates), agents, introducers, referrers, brokers, our related companies and service providers.
Why do we collect your personal information?
Eley Griffiths Group collect personal information from you which is reasonably necessary to:
• provide you with quality service
• send you communications (on your request or if we have a legitimate interest to keep you informed)
• maintain your contact details
• consider applications you make to us
• answer your enquiries and provide information or advice about existing and new services
• fulfil our legal obligations and to comply with any other law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or where a government authority makes recommendations that are not mandatory but which we elect to follow.
Should you not provide us with the personal or sensitive information mentioned above, we may not be able to process your application or provide you with the appropriate level of service.
How do we store your personal information?
Eley Griffiths Group keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include processing or storage in the cloud. Eley Griffiths Group will take reasonable steps to protect your information from misuse, loss and unauthorised access, modification or disclosure in accordance with statutory requirements through security measures and controls in place to protect personal information including limiting access, cryptography, physical and environmental security and audit monitoring.
How do we use your personal information?
Eley Griffiths Group use your personal information for the purpose for which it was provided to us, including to:
• provide you with efficient quality services
• process any applications made
• administer and manage our products and services
• carry out any analysis about out services and how we might improve them
• prevent and detect fraud and/or money laundering
• communicate with you and deal with any enquiries or complaints.
We do not sell information for marketing purposes to other organisations or allow such companies to do this.
Who do we share your personal information with?
Personal information held by Eley Griffiths Group will only be used for purposes directly related to one or more legitimate functions or activities of Eley Griffiths Group in the provision of its services or as otherwise permitted by law.
Eley Griffiths Group may disclose your personal information within the Eley Griffiths Group, and may disclose personal information outside the Eley Griffiths Group:
• as required by law or regulations, such as those relating to anti-money laundering and counter-terrorism financing or as required by a regulator
• to our service providers, who provide services in connection with our products and services (including archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, delivery, data processing, data analysis, information broking, mailing, marketing, research, investigation, insurance, identity verification, brokerage, maintenance, trustee, securitisation, website and technology services)
• to our affiliates
• to your nominated financial adviser with your permission
• as contained in the terms and conditions of any specific product or service.
In some circumstances the parties to whom we disclose personal information may operate outside of Australia or, in the case of data collected within the European Union, outside the European Union — this includes locations in the countries listed in the Appendix. Where this occurs, we take steps to protect personal information against misuse or loss and to comply with local law in respect of the transfer of your data from one jurisdiction to another. Those parties, in turn, may make such information available to the governments of such other countries in accordance with local law requirements.
How do we keep information accurate and up to date
Eley Griffiths Group take reasonable steps to ensure that all information we hold is as accurate as possible. Please contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.
How do we keep your information secure?
Eley Griffiths Group will take all reasonable steps to ensure your personal information is protected from misuse, loss and unauthorised access, modification or disclosure in accordance with statutory requirements. This includes having security measures and controls in place to protect personal information including internal policies, limiting access, cryptography, physical and environmental security and auditing, training and monitoring staff.
We require our external service providers to take appropriate technical and organisational measures to secure the privacy of any information provided to them.
• we have your consent (which may be implied);
• we are satisfied that the overseas recipient is compliant with the Australian Privacy Principles, or a similar privacy regime;
• we form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety; or
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