In order to provide investment management and superannuation services to our clients, we need to request and retain some personal information. This allows us to process applications, administer your accounts and provide you with information. We may also use your personal details to communicate with you about products and services and comply with relevant laws. We consider all information about our clients to be private and confidential.
These laws regulate the way organisations:
- collect;
- use;
- disclose;
- keep secure; and
- give people access to their personal information, i.e. information about an individual that identifies them.
1. Collection
Who do we collect information from?Wherever practicable, Vanguard will collect information about you from you. However, it may be necessary at times to collect information about you from other external sources, such as:
- your employer;
- your financial adviser or broker;
- your authorised representatives, such as executors or administrators;
- identification verification service providers; and
- in the case of our superannuation products in order to assess a claim, it may also be necessary to collect information from medical practitioners and from beneficiaries.
In order to establish and administer your account, and to comply with relevant legislation, we may collect all or some of the following:
- your full name, date of birth, gender and contact details including telephone, address, e-mail and fax;
- copy of your driver's licence and /or passport for the purpose of verifying your identity and to ensure compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act;
- your tax file number and bank account details for the purpose of administering your accounts;
- employment details which may include annual salary as advised by your employer;
- your contribution details and investment choice;
- your preferred beneficiaries;
- details about authorised signatories;
- copies of any relevant trust deeds, partnership agreements, constitutions or articles of association, which may be relevant to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act;
- details of services you are interested in and about your investment needs, for the purpose of gathering demographic information;
- health information, for example, if you apply for insurance cover or make a claim for benefits in connection with your superannuation account, such as disablement, salary continuance or other benefits;
- personal information about you, your dependants, relatives and potential beneficiaries may be required in order to determine whether and to whom a superannuation benefit should be paid. This may include health information, financial information, education and experience, work prospects, injuries, disablement, medical conditions, family and personal relationships.
2. Use and disclosure
How is your personal information used?Generally, we only use and disclose information about you for the purpose for which it was disclosed to us or related purposes which would reasonably be expected. Those purposes include:
- to establish and administer your investment and/or superannuation accounts and your relationship with us:
- to communicate with you;
- to enable us to inform you about new and existing products and services that will enhance our relationship with you. However, we do respect your right to ask us not to do this;
- to comply with our reporting and tax obligations;
- to handle any relevant enquiries or complaints;
- in the case of our superannuation products, to determine whether and to whom death, disablement and salary continuance benefits are payable.
Required by law
We may be required by law to disclose your personal information. For instance, we may be required to provide details to:
- Australian Government regulators such as the Australian Securities and Investments Commission (ASIC), Australian Prudential Regulatory Authority (APRA), Australian Tax Office (ATO), Australian Transaction Reports and Analysis Centre (AUSTRAC) and to other regulatory or government entities;
- Financial Ombudsman Service (FOS);
- Superannuation Complaints Tribunal (SCT);
- as required by a court order; and
- your Spouse in accordance with the Family Law Act requirements.
In order to meet your needs and provide some investor services, such as administering your accounts and mailing your distribution statements to you, it may be necessary to release information or provide access to external service providers, for instance:
- any organisations involved in providing, managing or administering our products or services such as administrators, mail houses and software providers;
- auditors, consultants and other professional advisers;
- your financial adviser;
- any fund (administrator or trustee) to which your investment balance is to be transferred or rolled over;
- your Legal Personal Representative, attorney or any other person who may be entitled to receive your account balance following your death and any person contacted to assist us in that process;
- other financial institutions who hold an account in your name, for example, where amounts have been transferred to or from that account;
- authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to your account.
If you make a claim in relation to your superannuation benefits, for example, in a claim for death, disablement, salary continuance or other benefits, it may be necessary to disclose your personal and health information to third parties in order to assess the claim. For example, your details may be disclosed:
- to your employer (relates only to employer sponsored superannuation arrangements);
- to our nominated medical practitioners and other relevant experts;
- to our insurer and to its medical practitioners and other experts nominated by the insurer;
- in the event of a dispute regarding your entitlement it may be necessary to disclose your personal information to legal advisers and other relevant parties to bring the matter to a resolution.
Market research
We may also provide some information to market research companies for the purpose of analysing our client base. We may provide our clients' or prospective clients' contact details to market research companies to undertake research on behalf of Vanguard. For example, we may run client satisfaction surveys, or run focus groups on proposed products. These agencies must return all records of this information to Vanguard. Vanguard retains ownership of this information and will ask you if you do not wish to receive further information.
Competitions
Vanguard may use an agency to run competitions or promotions on the Vanguard website and may request your name, address, telephone number and email address where it is necessary to ensure your eligibility, and comply with Lottery and Gaming regulations. In compliance with the relevant regulations it may also be necessary to publish details of the winners of competitions in an appropriate newspaper.
3. Information quality & security
Vanguard relies on the accuracy of the personal information provided by its clients. We aim to ensure that it is accurate, up to date and complete. If any of your details change or you have any concerns regarding its accuracy you should contact us.All client information is protected from unauthorised access through the use of secure passwords, user log ons or other security procedures. Developments in security and encryption technology will be reviewed regularly.
Where necessary, we will remind our clients that the Internet is an insecure medium.
4. Access to & correction of information
You may request access to any personal information we hold about you. Generally, if it is incorrect, we will correct it at your request. However, this is subject to some exceptions allowed by law, for example:- if access to information would pose a serious threat to the life or health of an individual;
- if access to information would have an unreasonable impact on the privacy of others;
- if the request is frivolous or vexatious;
- if the information relates to a commercially sensitive decision making process;
- if providing access would be unlawful;
- if access would prejudice enforcement activities relating to criminal activities and other breaches of revenue, or a security function;
- if providing access would reveal the intentions of Vanguard in relation to negotiations with you in such a way to prejudice those negotiations;
- if there are legal dispute resolution proceedings;
- where a third party has given us health information about you in confidence;
- denying access is required or authorised by or under law.
If access is denied we will provide you with the reason why.
Contact Us
If you have any further questions relating to this privacy statement, or concerns about the way in which we have handled your personal information, please do not hesitate to contact us.
