This document outlines Infocus’ policy with respect to handling the personal information we collect.
‘Infocus’, ‘we’, ‘us’ or ‘our’ refers to the Infocus Wealth Management Group (the ‘Group’) entities, as outlined on page 2. Infocus has been providing financial advice for Australians from all walks of life since 1994. Starting out as a small financial advice team in Queensland, Infocus has grown to become one of Australia’s leading wealth managers. With an expanding national footprint of expertly trained Financial Advisers and support staff, we are dedicated to keeping personal information confidential.
Personal information is information or opinion that allows others to identify you. It includes, but is not limited to, the following: your name, age, gender, contact details, and financial information; information on your health, sexual orientation, philosophical or religious beliefs, race or ethnic origin political opinions, details of membership of professional associations or trade unions, and genetic or biometric information.
We collect personal information to provide you with the products and services you request as well as to provide information on other products and services offered by or through us. The law requires us to collect and retain personal information. Personal information may be used and disclosed within the Group to administer our products and services, and, unless you tell us otherwise, to provide you with related marketing information.
You can seek access to the personal information we hold about you. If the information we hold about you is inaccurate, incomplete, or outdated, please let us know so that we can correct it (refer to contact details on page 8).
The Infocus Group includes Infocus Wealth Management Limited ABN 28 103 551 015 and its related bodies corporate. It also includes corporate authorised representatives and authorised representatives of our wholly owned Australia Financial Services Licensees (AFSLs) and Australian Financial Services Credit Licensees (ACLs).
Members of the Group that have collected personal information are permitted by the Privacy Act 1988 (Cth) to disclose personal information to other members of the Group. This enables the Group to have an integrated view of its clients.
Members of our Group and a brief description of the services they provide are outlined below.
Infocus Securities Australia Pty Ltd (Licensee) has authorised a number of corporate entities and individuals to provide financial and credit services on its behalf. This list is updated continuously as individuals are licensed with us. Details of our current authorised representatives are available on the Infocus website at www.infocus.com.au.
Personal information is information or opinion that allows others to identify you. It includes your name, age, gender, and contact details. The kinds of personal information we collect and store will depend on what products and services you request from us. However, our ability to provide you with services and advice that meets your needs and objectives may entail us collecting information, including:
Sometimes we may collect sensitive information about you. This could include information on:
We will collect, maintain, use, and disclose personal information which is necessary for us to adequately provide the services you have requested including:
As well as providing us with information upon which to provide a customised solution to your needs and objectives, we are required under the Corporations Act 2001 (Cth) and the National Consumer Credit Protection Act 2009 (Cth) to collect and hold this information.
Generally, we will not collect personal information about you except when you have knowingly provided that information to us or have authorised a third party to provide that information to us. Sometimes we collect information about you from other sources. We may collect information about you that is publicly available (for example from public registers or social media). However, in most cases collection of your personal information will be via face to face interviews, over the telephone, email or by way of your completion of a financial fact find. From time to time, other service providers may provide us with your information for the purpose of our providing a service to you (referral). In this case we will contact you to determine if we can be of any assistance.
We may seek your express permission to collect information from other entities such as product providers, accountants, solicitors, etc where this information may not be currently available to you. If we were to obtain information that is not information that could have been provided or authorised for collection by you, we will de-identify and destroy this information unless it is unlawful to do so.
Identification documentation is required for collection by law under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), as we are required to know our clients. In some instances, we are required to verify this documentation against other records. For instance, identification for Australian companies, trusts or registered co-operatives may need to be verified by a search of records held by regulatory bodies such as Australian Securities and Investments Commission (ASIC) or the Australian Taxation Office (ATO) etc.
We will not use or disclose personal information collected by us for any purpose other than:
(a) the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
(b) where you have consented to such disclosure; or
(c) where the APP authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by, or on behalf of, an enforcement agency or regulatory body.
We are obliged to maintain records which include personal information and make those records available for inspection by [the] ASIC or other regulators under a relevant law. If we provide information for the purpose of law enforcement activities, we will make a record of that provision.
The effectiveness of our services is specifically dependent on information you provide and it being relevant, complete, accurate and up-to-date. Without this, our services may not meet your needs or may result in unforeseen financial consequences. If you elect not to provide us with your personal information, as and when requested, we may not be able to provide you with financial services. Similarly, we may not be able to provide other services such as credit assistance.
We may use personal information collected from you for the purpose of providing you with direct marketing material; however, if you do not wish to receive such information you can request not to receive it. Simply contact us by any of the methods detailed on page 8. There is no cost for this request, however, please allow two weeks for your request to be actioned.
Infocus adheres to the Spam Act 2003 (Cth), accordingly, we will:
In order to provide our services, we may disclose your personal information to external parties, including, but not limited to:
(a) other entities who refer your business to us;
(b) affiliated product and service providers as well as external service providers such as superannuation fund trustees, insurance providers, and product issuers for whom we act as agent (so that they may provide you with the product or service that you seek or in which you have an express interest);
(c) auditors we appoint to ensure the integrity of our operations;
(d) suppliers from whom we order goods and services on your behalf (so that those goods and services can be provided to you);
(e) other persons acting on your behalf including your accountant, solicitor, executor, administrator, trustee, guardian, or attorney;
(f) if required or authorised to do so under law, law enforcement agencies, regulatory bodies, and government organisations;
(g) medical assessment services where you have sought insurance for the purposes of underwriting an insurance policy;
(h) other organisations, who, in conjunction with us, provide their products and services (so that they may provide their products and services to you); and
(i) other AFSLs, authorised representatives or their agents for the purpose of due diligence on one of our associated entities were they to decide to sell all or part of their business. In the event that a sale of our business is affected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer and your information will not be exchanged if you object to the transfer.
If we have used an example to describe when we might exchange personal information, the exchange of personal information may not be limited to those examples or examples of a similar kind.
We disclose personal information when we outsource certain functions, including paraplanning, telemarketing, bulk mailing, market research, direct marketing, and information technology support; we may also seek expert help from time to time to help us improve our systems, products, and services.
In all circumstances where personal information may become known to our contractors, agents, AFSLs, authorised representatives or their agents and outsourced service providers, there are confidentiality arrangements in place. Contractors, agents, other AFSLs, authorised representatives or their agents and outsourced service providers are not able to use or disclose personal information for any purposes other than our own. The Group takes its obligations to protect client information very seriously and we make every effort to deal only with parties who share and demonstrate the same attitude.
We take reasonable steps to ensure that overseas recipients adhere to the APP. We may disclose your personal information to contractors overseas to provide services to you; however, when doing so you should be aware of the following:
We allow access to relevant personal information for external organisations that help us provide services. These organisations are bound by confidentiality arrangements. From time to time we may use service providers whose staff accesses our data outside of Australia to provide services. Where this is the case, these service providers have committed to adhere to the Australia Privacy Principles. These service providers may be located in a number of countries including the Philippines, India, Serbia, Vietnam and/or Sri Lanka.
We will not adopt as our own any identifiers that you may provide to us such as TFNs, Centrelink, Medicare numbers etc. If you have provided us signed consent, we may hold your identifiers on file so that we can provide ongoing services to you. If you chose not to provide this consent, we will not hold this information on file. The circumstances in which an organisation may use or disclose government related identifiers are narrower in scope than the circumstances in which an organisation may use or disclose other personal information. Government related identifiers will not be disclosed except in the following circumstances:
Our goal is to ensure that the personal information we hold about you is accurate, secure, complete and up-to-date. Please contact us if you believe that the information, we have about you is not complete, accurate or up-to-date. You can ask us to update or change information in your file at any time. Prior to providing this access we will require you to provide evidence of your identity. We may ask you to put your request in writing and any charge we make for providing access will be reasonable. We may take steps to update information, for example, an account balance from your account service provider where you have provided us with access rights or an address or contact number from publicly available information such as telephone directories or websites.
If you ask, we will tell you what personal information we hold about you within your client file and what we do with it. On receipt of your request we will, subject to the limitations outlined below, facilitate access to you by allowing an inspection of your client file in person, or by providing copies or an accurate summary of relevant documents, depending on what we believe is most appropriate in the circumstances. If for whatever reason we refuse to change information we hold on your file, we will arrange for a statement from you to be associated with the relevant information so that it can be included in any future use or disclose of that information should you wish to do so.
When we make reference to your client file we are referring to documents, including, but not limited to: data collection forms; written communications (such as letters and emails) from you to Infocus, and from Infocus to you (or our subsidiaries); Statements of Advice (SoAs), Records of Advice (RoAs); tax returns; credit guides; transaction letters; signed authorities; investment, superannuation and personal insurance applications or statements produced by the issuers of financial products, and fee invoices.
In accordance with the APP, we will not provide you with access to your personal information if:
In the event we refuse your request to access to your personal information; we will provide you with a written explanation for that refusal. We will endeavour to respond to any request for access within 14-30 days depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.
Your personal information is generally held in your client file and on our computer database. We will always seek to ensure that your personal information is protected from misuse, loss, unauthorised access, modification, or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential.
Our security measures include, but are not limited to:
In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in our secure storage facility for a period of 7 years in order to comply with legislative requirements. Where information we hold is identified as no longer needed for any purpose, we ensure it is effectively and securely destroyed.
Address: Level 2, Cnr Maroochydore Road & Evans
Street Maroochydore QLD 4558
Postal: PO Box 1856 Sunshine Plaza QLD 4558
Telephone: (07) 5406 5000
We recognise that even in the best run organisations things can go wrong. If you have a complaint about privacy please tell us, as we’d like the chance to fix the problem. We offer a free complaints resolution process for all our clients. Simply contact us.
So that we can help you, we ask you to follow the three-step process outlined below:
If, after having raised the issue with us, you are still dissatisfied with the outcome, you are entitled to escalate the complaint to an external dispute resolution scheme. Infocus is a member of the Australian Financial Complaints Authority (AFCA) who can be contacted by calling 1800 931 678 or by writing to GPO Box 3, Melbourne Vic 3001.