Joseph Palmer & Sons respect the privacy of all our customers and business contacts, and are committed to safeguarding the personal information that you provide to us.
Joseph Palmer & Sons is subject to the National Privacy Principles (NPPs), which are contained in the Privacy Act 1988 (Privacy Act). The NPPs govern how organisations must handle personal information.
Personal information is information about, and which identifies an individual (such as your name and contact details). Your personal information includes information about who you are and your interactions with us such as transactions on your account. It may also include information about you that is publicly available, for example from public registers or made available through social media. When you give us personal information about another person, you represent that you are authorised to do so and agree to inform that person of the contents of this Statement as it relates to them.
Purpose for which we collect and use personal information
Joseph Palmer & Sons does not sell, rent or trade personal information about you to or with third parties.
We do not ordinarily collect any information about you except where you provide it to us, or it is provided to us with your consent.
In general, we do not use or disclose personal information collected about you other than for:
- disclosures required or permitted by law or otherwise permitted under the Privacy Act;
- a purpose otherwise disclosed to you or for which you have consented;
- as directed by you, such as to your accountant;
We may collect and use personal information that you or others give us in connection with an account to:
- process an application for an account to be opened;
- establish, provide and administer the account and execute your instructions;
- comply with legislative or regulatory requirements;
- open other accounts at your request;
- develop and identify products or services that may interest you, and advise you of them, unless you ‘opt out’ of marketing (see below);
We prohibit our Service Providers from using your personal information except for the specific purpose for which we supply it.
We collect your information because we are required to identify you in accordance with the Anti-Money Laundering and Counter-Terrorism Financing Act before we can open an account for you.
You are not required to provide your Tax File Number. However, if we do not collect your Tax File Number as permitted by the Taxation Administration Act 1953 and the Income Tax Assessment Act 1936, you may have TFN withholding tax deducted from the income on your investments at the highest marginal tax rate, plus the Medicare Levy.
Joseph Palmer & Sons may collect contact information from people with whom it does business (e.g. contact people in regulatory bodies, external service providers and the investment industry).
If you are a ‘business contact’ of Joseph Palmer & Sons, we may collect business contact information about you including your name, your position and the organisation you work for, your business telephone, your fax number and your email address.
We use your personal details, including any email address you give us, to provide you with information, and to tell you about products and services (including third party products and services) which we consider may be of interest to you. We may do this only while you hold any account with us, and even if your telephone number is registered on the Do Not Call Register.
Marketing ’Opt Out’
If at any time you do not wish to receive further marketing information, you may ask us not to send you any further information about products and services. You may do this by calling 02 9233 2433, or in the case of email marketing material, you may reply back to the email to ask us not to send further marketing emails.
Exchange of Personal Information
We may exchange personal information about you with our related bodies corporate, assignees, agents, contractors, organisations for verifying your identity, your agents, advisers, referees, executors, administrators, trustees, beneficiaries (if you are a trustee), guardians, attorneys, law enforcement, regulatory and government bodies, payment system operators, any person we consider necessary to execute your instructions, other organisations for the supply of services, other persons where this is permitted by law, persons with whom you make a joint application for a product or service with us and any financial institution to or from which a payment is made in relation to any account you have or operate.
In some cases, these persons or organisations may disclose your personal information for the purposes of any relationship they have with you or performing functions in relation to you.
Transfer of Personal Information Overseas
Sometimes it may be necessary to send your information overseas – for example where we outsource functions overseas, where we need to complete a transaction on your behalf or where this is required by laws and regulations in Australia or in another country.
We do not use or disclose your tax file number, Medicare number, pension number or any other government identifier except for opening an account and as required by law.
Access to your Personal Information, contacting us and contacting you
If you are a client of ours, you have rights to access your personal information from us, to request us to correct the information, and to make a complaint to us about a breach of your privacy rights in relation to the 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 calling 02 9233 2433.
We will give you access to that information unless the National Privacy Principles allow us to refuse access.
Generally, this will only happen where:
- disclosing the information would have an unreasonable effect on the privacy of other individuals;
- the information relates to legal proceedings with you;
- providing access would be unlawful;
- denying access is required or authorised by or under law or providing access would be likely to prejudice an investigation of possible unlawful activity;
- providing access would be likely to prejudice the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law or the enforcement of laws relating to the confiscation of the proceeds of crime or an enforcement body performing a lawful security function asks us not to provide access to the information on the basis that providing access would be likely to cause damage to the security of Australia;
To provide you with access to your personal information, Joseph Palmer & Sons will ordinarily provide you with a copy of the relevant personal information (a print-out from a database or a photocopy of personal information recorded only in paper form). If personal information about you (for example, your name and address) is duplicated across difference databases or paper files, we will generally only provide you with one printout of this information, rather than multiple printouts.
Joseph Palmer & Sons do not charge a fee for giving you access to your personal information and will try to deal with your request within a reasonable time. Generally, Joseph Palmer & Sons will endeavour to grant access within 14 days, or if giving it is more complicated, within 30 days.
We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date. If you believe that personal information that we hold about you is inaccurate, incomplete or out of date, please call us on 02 9233 2433, email firstname.lastname@example.org or come into our office 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 steps to prevent unauthorised access to, or unauthorised modification or disclosure of, your personal information and to protect it from misuse or loss.
All information transmitted to the Joseph Palmer & Sons website is stored securely (to the extent possible using existing technology). If you are trading online with us, your security is protected through your use of a User ID and a secure site Log-on Password. A Trading Password must also be entered each time you place an order to buy or sell Financial Products. When accessing or initiating your transactions over the internet, all communications with Joseph Palmer & Sons are secured through user authentication and 128-bit enabled data encryption. To ensure ongoing security, we encourage clients to change their password regularly.
Joseph Palmer & Sons may collect non-personal information from you by your use of our website. For example, we might track information about the date and time you access our site, the type of web browser you use, and the website from which you connected to our site. Generally, we do not collect information which personally identifies you. Rather, this information is collected in an aggregate form, e.g. the number of users using different types of web browsers. Joseph Palmer & Sons does not match any personal information we have collected about you with the anonymous navigation and other non-personal information which we collect when you visit our website.
Personal information provided to us in ‘hard copy’ is stored in locked filing cabinets or in areas of our office restricted to authorised personnel. We take steps to ensure that our staff understands that they must protect your privacy.
If we no longer need your information, we destroy or de-identify it.
Links to Other Websites
Sometimes our website contains links to third party websites for your convenience and information. When you access a non-Joseph Palmer & Sons website, please understand that Joseph Palmer & Sons is not responsible for the privacy practices of that site. We suggest that you review the privacy policies of each site you visit.
Complaints about Breaches of Privacy
If you believe that the privacy of your personal information has been compromised or is not being adequately protected, in the first instance you should contact us by calling 02 9233 2433. We will make every effort to resolve your complaint immediately but if it is not resolved to your satisfaction, you can contact:
The Privacy Officer
Joseph Palmer & Sons
GPO BOX 895 SYDNEY NSW 2001
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 to do this, please contact the Commissioner's Hotline service on 1300 363 992.