Privacy Policy

Current as at 1 October 2004

This Privacy Policy applies to BWA Managed Investments Ltd ("BWA Managed Investments"). The terms "we", "us" or "our" mean BWA Managed Investments.

We are bound by the National Privacy Principles of the Privacy Act, 1988 and are committed to safeguarding personal information we may hold at any time in respect of any individual, in accordance with the requirements of those Principles. "Personal information" for the purposes of this Policy is information about and which identifies individuals. It includes information obtained from the individual or about an individual obtained from a third party.

In general, we will not use or disclose personal information collected about you otherwise than for a purpose set out in the Privacy Policy, a purpose you would reasonably expect, a purpose required or permitted by law, or a purpose otherwise disclosed to, or authorised by, you.

We may, in connection with particular services we offer or provide to you, make other privacy disclosures to you or seek your authority to use your personal information in ways which are different from or more specific than those stated in this Privacy Policy. In the event of any inconsistency between the provisions of this Privacy Policy and those other disclosures, the other disclosures will prevail.

Collection of personal information

We will not ordinarily collect any information about you except where you provide it to us or it is provided to us with your authority.

The types of personal information we collect generally includes your name, address, telephone number, email address, tax file number, date of birth, employment, income details and other financial details.

In certain circumstances, we may also collect personal information which is sensitive. Sensitive information includes information about your health, religious or philosophical beliefs, membership of professional or trade associations or a criminal record. Unless the collection of sensitive information is required or permitted by or under law, we will obtain your consent to its collection. If the sensitive information relates directly to our ability to arrange for the issue of a financial product to you, you consent to our collection of it.

We will collect personal information directly from you when providing financial services to you whether you deal with us over the telephone, in person, send us a letter, via an agent or visit our website. We may, for purposes of security, training, or information or transaction verification, listen to and/or record telephone calls to which you are a party with us.

On occasions, we may need to collect personal information about you from third parties, such as our business alliance partners, your agents, and where you are introduced to us, the organisation introducing you. If required by law, we will obtain your consent to collect information from third party sources.

We only collect personal information about you that is necessary for our functions and activities and, ordinarily, you will be told the purposes for which we collect that information when it is collected.

As a general rule the collection of your personal information will be necessary for us to provide a service to you or to maintain our relationship with you.

Additionally, the purposes for which we will generally collect and use your personal information will include:

• complying with legislative and regulatory requirements;
• providing advice to you;
• considering an application you make to us;
• managing our rights and obligations in relation to external payment systems;
• performing our administrative operations, including accounting, risk management, record keeping, archiving, systems development and testing, and staff training;
• conducting market or customer satisfaction research;
• developing and identifying products and services that may interest you;
• arranging for the provision to you of financial products available from other organisations; and
• (unless you ask us not to) telling you about products and services.

We also advise that each time our website is visited, we use cookies to record the date and time of access to the site and any information read or downloaded but this information does not identify the user and therefore is not personal information. A cookie is a small text file placed on your computer hard drive by a web page server, which can then be accessed by our web servers. You may configure your web browser not to accept cookies, however this may mean that you are not able to make full use of our website.

Personal information about third parties

If at any time you supply us with personal information about another person (for example, a spouse or partner, or a person you may wish a payment to be directed to), you should ensure that you are authorised to do so and you agree to inform that person who we are, that we will use and disclose their personal information and that they may gain access to it should we hold that information.

Use and disclosure of personal information

We will not use or disclose information collected about you other than for a purpose made known to you, a purpose you would reasonably expect, a purpose required or permitted by or under any law or a purpose otherwise authorised by you.

You authorise us to disclose relevant information to our related companies, agents or contractors, who provide services to us in connection with the provision of financial products or services you have sought from us. These parties are prohibited from using your personal information except for the specific purpose for which we supply it to them.

Subject to what is permitted by law, other types of third parties we may disclose your personal information to include, where relevant:

• credit reporting agencies;
• our agents, contractors and external advisors whom we engage from time to time to carry out, or advise on, our functions and activities;
• investment providers, fund managers, superannuation fund administrators, stockbrokers;
• your agents and contractors, including your accountant, current financial planner, finance broker and your legal advisor;
• your executor, administrator, trutsee, guardian or attorney;
• external payment system operators;
• regulatory bodies, government agencies, law enforcement bodies and courts;
• any person or organisation who introduces you to us;
• debt collecting agencies;
• your and our insurers or prospective insurers and their underwriters; or
• any person to the extent necessary, in our view in order to carry out any instruction you give to us.

Your access to your personal information

If at any time you wish to know what personal information we are holding about you, you are welcome to apply for your details by telephoning our office on 1300 663 117.

Under certain circumstances, we may not be able to tell you what personal information we hold about you. This includes where:

• it would have an unreasonable impact on the privacy of other individuals;
• the information relates to legal proceedings with you;
• the information would reveal our commercially sensitive decision-making process; or
• we are prevented by law from disclosing the information, or providing access would prejudice certain investigations.

We may charge a fee for accessing your personal information.

We will take reasonable steps to ensure that your personal information is accurate, complete and up-to-date. If at any time you believe that personal information that we hold about you is inaccurate, incomplete or out of date, please advise us by telephoning our office on 1300 663 117 and we will take all reasonable steps to correct the information.

Security of your personal information

We maintain strict procedures and standards and take all reasonable care to prevent unauthorised access to, and modification and disclosure of, your personal information. We will take all reasonable steps to protect your personal information from misuse and loss.

We also protect the security of your personal information when transmitted over the internet. We use a Secure Socket Layer (SSL) to transfer personal information between you and our web servers, and DSS encryption when we transfer data to third parties. However no data transmission over the internet can be guaranteed as fully secure and accordingly, we cannot guarantee or warrant the security of any information you send to us using our on-line forms or products. You submit information over the internet at your own risk.

If we no longer need your information, we will destroy or de-identify it.

Direct marketing

We adhere to the Direct Marketing Code of Conduct produced by ADMA.

We will use your personal details, including any electronic addresses you provide to us, to provide you with information and tell you about product and services, including third party products and services which we consider may be of interest to you. We also provide you details to other organisations (including our related companies) but only for specific marketing purposes.

If at any time you do not wish to receive further marketing information, you have the option to ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this by telephoning our office on 1300 663 117, or in the case of email marketing material, you may use an unsubscribe facility included with a commercial electronic message to withdraw your consent.

Government identifiers

We do not use your tax file number, Medicare number, pension number or any other government identifier as your account, policy or application number. We will only use and disclose these numbers for the purposes required by law.

Complaints about breaches of privacy

If you believe that the privacy of your personal information has been compromised or is not being adequately protected, you should contact us by telephoning our office on 1300 663 117. We will make every effort to resolve your complaint internally.

If we do not resolve your complaint to your satisfaction, you may apply to the Federal Privacy Commissioner to have your complaint investigated. For more information about how you may lodge a complaint with the Federal Privacy Commissioner, please contact the Commissioner's hotline service on 1300 663 117.

Changes to this Privacy Policy

This statement sets out our current Privacy Policy. Please note that this Privacy Policy may change from time to time. Our current Privacy Policy is available from our office. For a current copy please call 1300 663 117.

We encourage you to periodically review our Privacy Policy for any changes.

Our Internet Website

This Privacy Policy applies to any website operated by us under the domain name www.bwami.com.au, and to the following domain names:

• secureforms.bankwest.com.au;
• bob.bankwest.com.au;
• bwamanagedinvestments.com.au;
• advisor.bwami.com.au; and
• advisor.bwamanagedinvestments.com.au.

When you use a link from the our website to the websites of third parties, those websites are not subject to our privacy standards. Those third parties are responsible for informing you of their own privacy policies.

If personal information about you is collected by third parties on any websites you have accessed through our website, we may also collect or have access to that information as part of our arrangement with those third parties.

Contacting Us

If you have any questions regarding this Privacy Policy or would like more information about the way we manage your personal information, telephone our office on 1300 663 117.