Christopher Cachia, Dennis Jones, Christopher Cachia & Associates Pty Ltd atf Cachia Trading Trust (t/a CCA Financial Planners)
The privacy of your personal information has always been important to us at Christopher Cachia & Associates Pty Ltd as trustee for the Cachia Trading Trust, trading as CCA Financial Planners ABN 60 947 356 801. In addition to complying with existing laws that govern confidential information that you provide to us, we are also required to comply with the Australian Privacy Principles. We will always seek to comply with the Australian Privacy Principles as well as other applicable laws affecting your personal information.
Collecting Your Personal Information
Your personal information will be collected and held by Christopher Cachia & Dennis Jones, who are authorised representatives of GWM Adviser Services Limited (t/a Garvan FP) ABN 96 002 071 749, an Australian Financial Services Licensee, for the purposes of:
- providing you with the advisory services that you have requested;
- managing our relationship with you; or
- contacting you about products and services in which you may be interested.
To enable your financial adviser to provide you with financial advice you request that is suitable for your investment objectives, financial situation and particular needs we need to obtain and hold personal information about you. This includes:
- your name, contact details and date of birth;
- employment details and history;
- financial details including information about your financial needs and objectives, your current financial circumstances including your assets and liabilities, income, expenditure, insurance cover and superannuation;
- details of your investment preferences and risk tolerance;
- family circumstances and social security eligibility; and
- any other information that we consider necessary.
The personal information collected may include sensitive information such as health information and memberships of professional or trade associations.
If it is reasonable and practicable we will only collect your personal information from you. Generally your personal information will be collected when you meet with your adviser in person, provide your adviser with information over the telephone or with written material. We may need to collect personal information from third parties, such as your accountant.
How Your Personal Information is Held
Your personal information is generally held in client files or a computer database. Your personal information may also be held in a secure archiving facility.
We will seek to ensure that we take reasonable steps to ensure that the personal information that we hold is protected from misuse and loss and from unauthorised access, modification and disclosure. Some of the measures that we have adopted are having facilities for the secure storage of personal information, having secure offices and access controls for our computer systems.
We will also take reasonable steps to destroy or permanently de-identify personal information that we no longer need for any purpose for which may be used or disclosed under the Australian Privacy Principles.
Using and Disclosing Your Personal Information
Your personal information may be disclosed for purposes related to the provision of the financial advice you have requested. The types of service providers that may be provided with your personal information are:
- other financial advisers and organisations involved in providing the financial advice you have requested (which may include ongoing service) such as fund managers who assist us in providing financial advice and paraplanners;
- insurance providers, superannuation trustees and product issuers in connection with the provision to you of the financial advice you have requested;
- organisations that assist in operating a financial planning business such as those that provide administrative, financial, accounting, insurance, research, legal, computer or other business services;
- your representatives or service providers such as your accountant, solicitor, tax agent, stockbroker or bank;
- organisations involved in a business restructure or a transfer of all or part of the assets of our business or the due diligence procedures prior to any such sale or transfer;
- government authorities and other organisations when required by law; and
- organisations that you have consented to your personal information being disclosed to.
Your personal information may also be used in connection with such purposes.
We will seek to ensure that your personal information is not used or disclosed for any purpose other than:
- the primary purpose for which it was collected or a related secondary purpose;
- where you have consented to the use or disclosure; or
- in other circumstances where the Australian Privacy Principles authorise the use or disclosure such as when it is required by or authorised under law.
We may disclose your personal information to third parties who provide services to us, in which case we will seek to ensure that the personal information is held, used or disclosed consistently with the Australian Privacy Principles.
Organisations outside Australia.
Currently, we do not share your information with organisations outside Australia.
We may store your information in the cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed. Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
Accessing your Personal Information
You can gain access to your personal information that we hold. This is subject to exceptions allowed by law such as where providing you with access would have an unreasonable impact upon the privacy of others. If we deny a request for access we will provide you with the reasons for this decision. To request access please contact us (see “Contacting Us and Privacy Issues” below).
Correcting Your Personal Information
We endeavour to take reasonable steps to ensure that the personal information that we collect, use or disclose is accurate, complete and up-to-date. If you believe that any of the personal information that we hold is not accurate, complete or up-to-date please contact us (see “Contacting Us and Privacy Issues” below) and provide us with evidence that it is not accurate, complete and up-to-date.
If we agree that the personal information requires correcting we will take reasonable steps to do so. If we do not correct your personal information we will provide you with the reasons for not correcting your personal information. If you request that we associate with the information a statement claiming that the information is not accurate, complete and up-to-date we will take reasonable steps to comply with this request.
Contacting Us and Privacy Issues
You can obtain further information on request about the way in which we manage the personal information that we hold or you can raise any privacy issues with us, including a complaint about privacy, by contacting us on [03 8651 6555]. We are committed to resolving your complaint.
Respecting your privacy
This Policy also includes our credit reporting policy, that is, it covers additional information on how we manage your personal information collected in connection with a credit application, or a credit facility. We refer to this credit-related information below as credit information.
What personal information do we collect and hold?
The types of information that we collect and hold about you could include:
· ID information such as your name, postal or email address, telephone numbers, and date of birth;
· other contact details such as social media handles;
· financial details such as your tax file number; and
· other information we think is necessary.
We may collect information about you because we are required or authorised by law to collect it. There are laws which require us to collect personal information. For example, we require personal information to verify your identity under Australian Anti-Money Laundering law.
What do we collect via your website activity?
If you’re an internet customer of ours, we monitor your use of internet services to ensure we can verify you and can receive information from us, and to identify ways we can improve our services for you.
If you start but don’t submit an on-line application, we can contact you using any of the contact details you’ve supplied to offer help completing it. The information in applications will be kept temporarily then destroyed if the application is not completed.
We also know that some customers like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However, for all confidential matters, we’ll ensure we interact with you via a secure forum.
To improve our services and products, we sometimes collect de-identified information from web users. That information could include IP addresses or geographical information to ensure your use of our web applications is secure.
How do we collect your personal information?
How we collect and hold your information
Unless it’s unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s important that you help us to do this and keep your contact details up-to-date.
There are a number of ways in which we may seek information from you. We might collect your information when you fill out a form with us, when you’ve given us a call or used our website. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details.
How we collect your information from other sources
Sometimes, we will collect information about you from other sources as the Privacy Act 1988 permits. We will do this only if it’s reasonably necessary to do so, for example, where:
· we collect information from third parties about the loan or lease made available to you arising out of the services we provide you;
· we can’t get hold of you and we rely on public information to update your contact details; or
· we exchange information with your legal or financial advisers or other representatives.
If you don’t provide your information to us, it may not be possible:
· for us to give you the credit assistance you seek from us;
· to assist in finding a loan or lease relevant to your circumstances;
· verify your identity or protect against fraud; or
· to let you know about other products or services that might be suitable for your financial needs.
How we collect and hold your credit information
We will collect your credit information in the course of you answering the enquiries we make of you relating to the credit assistance you seek from us. In addition to what we say above about collecting information from other sources, other main sources for collecting credit information are:
· your co-loan applicants or co-borrowers;
· your guarantors/proposed guarantors;
· your employer, accountant, real estate agent or other referees;
· your agents and other representatives like the person who referred your business to us, your solicitors, conveyancers and settlement agents;
· organisations that help us to process credit applications;
· organisations that check the security you are offering such as valuers;
· bodies that issue identification documents to help us check your identity; and
· our service providers involved in helping us to process any application you make for credit through us.
What do we do when we get information we didn’t ask for?
Sometimes, people share information with us we haven’t sought out (referred to as ‘unsolicited information’). Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.
When will we notify you that we have received your information?
When we receive personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.
Sometimes we collect your personal information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.
How do we take care of your personal information?
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:
- document storage security policies;
- security measures for access to our systems; and
- only giving access to personal information to a person who is verified to be able to receive that information
We may store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.
What happens when we no longer need your information?
We’ll only keep your information for as long as we require it for our purposes. We may be required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
How we use your personal information
What are the main reasons we collect, hold and use your information?
Collecting your personal information allows us to provide you with the products and services you’ve asked for. This means we can use your information to:
- give you credit assistance;
- give you information about loan products or related services;
- consider whether you are eligible for a loan or lease or any related service you requested;
- assist you to prepare an application for a lease or a loan;
- administer services we provide, for example, to answer requests or deal with complaints; and
- administer payments we receive, or any payments we make, relating to your loan or lease.
Can we use your information for marketing our products and services?
We may use or disclose your personal information to let you know about other products or services we or a third party make available and that may be of interest to you.
We will always let you know that you can opt out from receiving marketing offers.
With your consent, we may disclose your personal information to third parties for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We won’t sell your personal information to any organisation.
Yes, You Can Opt-Out
You can let us know at any time if you no longer wish to receive direct marketing offers from us. We will process your request as soon as practicable.
What are the other ways we use your information?
We’ve just told you some of the main reasons why we collect your information, so here’s some more insight into the ways we use your personal information including:
· identifying you;
· telling you about other products or services we make available and that may be of interest to you, unless you tell us not to;
· allowing us to run our business efficiently and perform general administrative tasks;
· preventing any fraud or crime or any suspected fraud or crime;
· as required by law, regulation or codes binding us; and
· any purpose to which you have consented.
To make sure we can meet your specific needs and for the purposes described in ‘How we use your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations for any purposes for which we use your information.
Sharing Your Information
We may use and share your information with other organisations for any purpose described above.
We may share your information with:
· your representative or any person acting on your behalf (for example, lawyers, settlement agents, accountants or real estate agents); and
· your referees, like your employer, to confirm details about you.
Sharing with third parties
We may share your information with third parties in relation to services we provide to you. Those third parties may include:
· the mortgage aggregator through whom we may submit loan or lease applications to lenders or lessors on the mortgage aggregator’s panel;
· the Australian Credit Licence holder that authorises us to engage in credit activities;
· referrers that referred your business to us;
· lenders, lessors, lender’s mortgage insurers and other loan or lease intermediaries;
· organisations, like fraud reporting agencies, that may identify, investigate and/or prevent fraud, suspected fraud, crimes, suspected crimes, or other misconduct;
· government or regulatory bodies (including ASIC and the Australian Taxation Office) as required or authorised by law. In some instances, these bodies may share the information with relevant foreign authorities;
· guarantors and prospective guarantors of your loan or lease;
· service providers, agents, contractors and advisers that assist us to conduct our business;
· any organisation that wishes to take an interest in our business or assets; and
· any third party to which you consent to us sharing your information.
Sharing outside of Australia
We are not likely to disclose your information to organisations overseas. However, we may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held.
How you can generally access your information
We‘ll always give you access to your personal information unless there are certain legal reasons why we can’t. You can ask us in writing to access your personal information that we hold. In some cases we may be able to deal with your request over the phone.
We will give you access to your information in the form you want it where it’s reasonable and practical.We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first.
We’re not always required to give you access to your personal information. Some of the situations where we don’t have to give you access include when:
- we believe there is a threat to life or public safety;
- there is an unreasonable impact on other individuals;
- the request is frivolous;
- the information wouldn’t be ordinarily accessible because of legal proceedings;
- it would prejudice negotiations with you;
- it would be unlawful;
- it would jeopardise taking action against serious misconduct by you;
- it would be likely to harm the activities of an enforcement body (e.g. the police); or
- it would harm the confidentiality of our commercial information.
If we can’t provide your information in the way you’ve requested, we will tell you why in writing. If you have concerns, you can complain. See ‘Contact Us’.
How do you correct your personal information?
How we correct your information
Contact us if you think there is something wrong with the information we hold about you and we’ll try to correct it if it’s:
- irrelevant; or
If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can – if we can’t, then we’ll let you know in writing.
What additional things do we have to do to correct your credit information?
If you ask us to correct credit information, we will help you with this in the following way.
Helping you manage corrections
Whether we made the mistake or someone else made it, we are required to help you ask for the information to be corrected. So we can do this, we might need to talk to others. However, the most efficient way for you to make a correction request is to send it to the organisation which made the mistake.
Where we correct information
If we’re able to correct the information, we’ll let you know within five business days of deciding to do this. We’ll also let the relevant third parties know as well as any others you tell us about. If there are any instances where we can’t do this, then we’ll let you know in writing.
Where we can’t correct information
If we’re unable to correct your information, we’ll explain why in writing within five business days of making this decision. If you have any concerns, you can access our external disputeresolution scheme or make a complaint to the Office of the Australian Information Commissioner.
Time frame for correcting information
If we agree to correct your information, we’ll do so within 30 days from when you asked us, or a longer period that’s been agreed by you.
If we can’t make corrections within a 30 day time frame or the agreed time frame, we must:
- let you know about the delay, the reasons for it and when we expect to resolve the matter;
- ask you to agree in writing to give us more time; and
- let you know you can complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
How do you make a complaint?
How do you generally make a complaint?
If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us.
You can contact us by using the details below:
Address: Suite 19 Level 15 401 Docklands Drive, Docklands VIC 3008
Tel: 03 8651 6555
Fax: 03 8651 6550
Email address: firstname.lastname@example.org
We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within five business days.
Need more help?
If you still feel your issue hasn’t been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner:
· Phone: 1300 363 992
· Email: email@example.com
· Fax: +61 2 9284 9666
· Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601
What additional things do we have to do to manage your complaints about credit information?
If your complaint relates to how we handled your access and correction requests
You may take your complaint directly to our external dispute resolution scheme or the Office of the Australian Information Commissioner. You are not required to let us try to fix it first.
For all other complaints relating to credit information
If you make a complaint about things (other than an access request or correction request) in relation to your credit information, we will let you know how we will deal with it within seven days.
Ask for more time if we can’t fix things in 30 days
If we can’t fix things within 30 days, we’ll let you know why and how long we think it will take. We will also ask you for an extension of time to fix the matter. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
Letting you know about our decision
We’ll let you know about our decision within 30 days or any longer agreed time frame. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
We care about your privacy. Please contact us if you have any questions or comments about our privacy policies and procedures. We welcome your feedback.
You can contact us by using the details below:
Address: Suite 19 Level 15 401 Docklands Drive, Docklands VIC 3008
Tel: 03 8651 6555
Fax: 03 8651 6550
Email address: firstname.lastname@example.org
If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. We might not always be able to interact with you this way, however, as we are often governed by regulations that require us to know who we’re dealing with. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:
· it is impracticable; or
· we are required or authorised by law or a court/tribunal order to deal with you personally.
What do we do with government-related identifiers?
In certain circumstances we may be required to collect government-related identifiers such as your tax file number. We will not use or disclose this information unless we are authorised by law.
This Policy may change. We will let you know of any changes to this Policy by posting a notification on our website, correspondence via post or e-mail or you may contact us for a copy of the most up to date policy at any time.
 However we’ll never ask you for your security details in this way – if you are ever unsure, just contact us