Disclaimer

This website is operated by Industry Fund Services Limited - ABN 54 007 016 195, AFSL 232514 – (“IFS”). IFS is a wholly owned subsidiary of Industry Super Holdings Pty Ltd (ABN 71 119 748 060), which in turn is owned by a number of major industry superannuation funds.

The information provided on this website is of a general nature only. It has been prepared by IFS without taking into account your personal objectives, financial situation or needs. You should assess your own financial situation and obtain independent financial advice before making any investment decisions or taking any action based on the limited information available on this website.

IFS is responsible for the accuracy of the information it publishes.

IFS Privacy Policy

Introduction

Industry Fund Services Limited (referred to as IFS, we, our, us) is bound by the Privacy Act 1988 (‘the Privacy Act’), including the Australian Privacy Principles (‘APPs’), and recognises the importance of ensuring the confidentiality and security of your personal information.

All third parties (including clients, suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by IFS must abide by this Privacy Policy and Collection Statement (‘Privacy Policy’). IFS makes this Privacy Policy available free of charge and can be downloaded from its website.

In this privacy policy:

What kind of personal information do we collect and hold?

We may collect and hold a range of personal information about you to provide you with our services, including:

  • Name or nickname

  • Date of birth

  • Gender

  • Contact details including phone number, mobile number, home address, work address, PO box and email address

  • Relationship status

  • Family and living arrangements

  • Citizenship or nationality

  • Social security benefits

  • financial information, including details of:

  • your investments

  • your insurance policies

  • estate planning strategies

  • taxation information

  • health information

  • bank accounts

  • employment records

How do we collect personal information?

We generally collect personal information directly from you. For example, personal information will be collected through our application processes, forms and other interactions with you in the course of providing you with our products and services, including when you visit our website, participate in our surveys, competitions or promotions, call us, or correspond to us via email or postal letters.

We may also collect personal information about you from a third party, such a superannuation fund, an insurer, a parent or guardian, public sources, government organisations, regulatory bodies and enforcement agencies, market research organisations, service providers, and credit reporting bodies. For example, information about employment details may be obtained from a client superfund or an employer.

We will not collect sensitive information about you without your consent, unless an exemption in the APPs applies. These exceptions include if the collection is required or authorised by law, or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.

If the personal information we request is not provided by you, we may not be able to provide you with the benefit of our services or meet your needs appropriately.

We do not give you the option of dealing with us anonymously, or under a pseudonym. This is because it is impractical, and, in some circumstances, illegal for us to deal with individuals who are not identified.

Who do we collect personal information about?

The personal information we may collect, and hold includes (but is not limited to) personal information about:

  • members of our client funds

  • clients

  • potential clients

  • service providers or suppliers

  • prospective employees, employees and contractors

  • other third parties with whom we come into contact

Website collection

We collect personal when we receive completed online generated forms from our website https://www.ifs.net.au. We may also use third parties to analyse traffic at that website, which may involve the use of cookies. Information collected through such analysis is anonymous.

  • Cookies: Cookies are small text files that are transferred to a user’s computer hard drive by a website or application for the purpose of storing information about the user’s identity, browser type or website visiting patterns. Cookies do not contain personal information in themselves but can be used to identify a person when combined with other information. If you do not consent to our use of cookies, you may adjust your internet browser settings to disable cookies. However, disabling cookies may impact the functionality of the use of our website and we may not be able to provide all services available on our website.

  • E-mail: If we receive an e-mail from an individual, we will use the e-mail address, and any personal information contained in the e-mail to respond.

  • External Service Providers: We may use service providers to track usage on our websites, but personal information is not collected via this process.

  • Third Party Websites: Our website may contain links to external third parties however those parties’ websites are not covered by our privacy policy.

Why do we collect and hold personal information?

We may use and disclose the information we collect about you for the following purposes:

  • Establish the identity of clients or recipients of our services

  • Administer and manage the delivery of our products and services

  • Fulfil our obligations to client funds

  • Manage our risks and help to identify potentially illegal or fraudulent conduct

  • Assist with the design, development and improvement of our products and services

  • Appoint our directors, employees, Financial Advisers or other authorised representatives

  • Consider any concerns or complaints you may have

  • Comply with relevant laws, regulations and other legal obligations

We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act. For example, a secondary purpose of providing financial planning services is using the personal information to assist with a complaint.

Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise, or an exemption in the Privacy Act applies.

Who might we disclose personal information to?

We may disclose personal information to:

  • Superannuation funds

  • Employers contributing to superannuation

  • Investment product providers

  • Insurers, banks or Financial Advisers

  • Government organisations, regulatory bodies and enforcement agencies

  • Service providers that can act on our behalf

  • Parents, guardians or other family where authorised by law

  • Other financial services or product institutions to prevent, detect or investigate suspected fraudulent activity in connection with our products and services.

  • A related entity of Industry Funds Services Limited

  • An agent, contractor or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, debt collectors or other advisers

  • organisations involved in a transfer or sale of all or part of our assets or business

  • anyone else to whom you authorise us to disclose it or is required by law

If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues, and we will make third parties aware of this Privacy Policy.

Sending information overseas

We do not currently disclose personal information overseas.

Management of personal information

Whether personal information is gathered through face-to-face meetings or via phone, internet, mail or any other means, we take steps to store information we collect securely and protect it against misuse, loss, unauthorised access or disclosure.

We protect personal information by:

  • Restricting access to our office space to authorised persons. External guests must be accompanied by an employee or signed in at building reception.

  • Restricting access to our information technology (IT) systems to authorised users through:

  • User authentication: Each authorised user is required to have a password-protected individual account. Remote access to our systems is subject to a two-factor authentication.

  • Firewalls: Block unauthorised access by an external source.

  • Data Encryption: Ensures information is unusable to an external party.

  • Restricting access to personal information saved on our IT systems only to those persons who need to use the information. If someone does not need to use or see the personal information to perform their work, they do not have access to the information.

  • Requiring use of electronic records instead of paper records. Wherever possible, the collection and storage of personal information should be electronic and accessible only by authorised persons where the personal information is necessary for the performance of work. We do not keep paper records if information is stored electronically.

  • Requiring storage of paper records in a secured container, drawer, cupboard or room. Personal information is not left unattended and on display in our office.

  • Requiring encryption, password protection or secure file transfer protocols for transmission of any files containing Personal Information.

  • Requiring emails to contain as little personal information as possible. We only include what is necessary. In our emails, we require that email titles and bodies not contain any Sensitive Information. Sensitive Information is required to be in password protected attachments.

  • Informing all callers that their phone call may be monitored and recorded and allowing persons to request their phone call not be recorded. Where a person says that they do not want their phone call to be recorded, we stop recording or call the person from a phone that doesn’t record phone calls.

  • Regularly training our people to understand the importance of protecting the confidentiality of personal information. This includes our employees, Financial Advisers, contractors, representatives and third party service providers.

  • Restricting the collection and use of Tax File Numbers.

  • Destroying or de-identifying personal information when it is no longer needed for the purpose for which it was obtained or when we are no longer required to retain it by law (whichever is later).

Data Breach Response Plan

We have a data breach response plan that sets out procedures and responsibilities of IFS advisers and employees in the event IFS experiences a data breach or suspects a data breach has occurred.

The response plan is intended to enable IFS to contain and respond to data breaches in a timely manner and to help mitigate potential harm, and to comply with The Notifiable Data Breaches (NBD) scheme in Part IIIC of the Privacy Act. In the event of a data breach involving personal information, we will notify affected users and authorities as required by law.

Direct Marketing

We may use personal information (not including sensitive information) to communicate directly with an individual about our products and services. However, we can only use personal information (that is not sensitive information) for direct marketing where:

  • The personal information has been collected directly from an individual;

  • The individual would reasonably expect their personal information to be used for the purpose of direct marketing;

  • We provide a simple way for the individual to request not to receive direct marketing from us and draw their attention to the fact that they may make such a request;

  • The information is not spam as described in the Spam Act 2003; and

  • The individual has not previously made a request to not receive direct marketing from us, and is not listed on a Do Not Call Register.

Where an individual would not reasonably expect their information to be used or disclosed for the purpose of direct marketing, we must obtain consent from the individual.

To use sensitive information for direct marketing we must obtain the individual’s consent to the use or disclosure for the purpose of direct marketing.

A person can opt-out of receiving marketing communications by contacting IFS or by using the facilities provided in the specific marketing communication.

An individual can also tell us at any time if they do not wish to disclose their personal information to third parties by contacting our privacy officer.

IFS keep records of persons who have opted out of receiving marking communications from IFS.

Identifiers

We do not adopt identifiers assigned by the Government (such as drivers’ licence numbers) for our own file recording purposes, unless one of the exemptions in the Privacy Act applies.

Tax File Numbers

We will only ask you for your tax file number (TFN) where use is permitted by taxation, superannuation or personal assistance law. Before asking you for your TFN, we will tell you why we are collecting it, the law that permits us, that it is not an offence if you don’t provide us with your TFN and what will happen if you do not provide us with your TFN.

How do we keep personal information accurate and up-to-date?

We are committed to ensuring that the personal information we collect, use and disclose is relevant, accurate, complete and up-to-date.

We encourage you to contact us to update any personal information we hold about you. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge you for correcting the information.

Accessing your personal information

Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information that we hold about you by contacting the IFS’ Privacy Officer. We will provide access within 30 days of the individual’s request. If we refuse to provide the information, we will provide reasons for the refusal.

We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged for providing access.

Updates to this Privacy Policy

This Privacy Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.

Responsibilities

It is the responsibility of management to inform employees and other relevant third parties about this Privacy Policy. Management must ensure that employees and other relevant third parties are advised of any changes to this Privacy Policy. All new employees are to be provided with timely and appropriate access to this Privacy Policy, and all employees are provided with training in relation to appropriate handling of personal information. Employees or other relevant third parties that do not comply with this Privacy Policy may be subject to disciplinary action.

Non-compliance and disciplinary actions

Privacy breaches must be reported to management by employees and relevant third parties. Ignorance of this Privacy Policy will not be an acceptable excuse for non-compliance. Employees or other relevant third parties that do not comply with this Privacy Policy may be subject to disciplinary action.

Making a complaint

All complaints are managed in accordance with IFS’ Complaints Handling Policy.
You can make a complaint to us about the treatment or handling of your personal information by lodging a complaint with the Privacy Officer.
If you have any questions about this Privacy Policy, or wish to make a complaint about how we have handled your personal information, you can lodge a complaint with us by:

If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner by:

  • Telephoning – 1300 363 992

  • Writing – Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001

  • Online submission – https://www.oaic.gov.au/