Privacy Policy

First Approach Pty Ltd as trustee for The Graymann Enterprise Trust and related entities (Approach Super) understand the importance of, and are committed to protecting your personal information during the operation of its business.

Purpose of the policy

This document sets out the policy of Approach Super in relation to protecting the privacy of personal information, and is made in compliance with Approach Super’s obligations under the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

This Privacy Policy applies in addition to the Terms and Conditions of our Website.

Application of the policy

This policy applies to any individuals about whom Approach Super currently holds, or may collect in the future, personal information.

The purpose of this policy is to inform such individuals about:

  • What type of personal information we collect; and
  • What we do with this personal information.

Collection of personal information

What is personal information?

‘Personal information’ is information or an opinion, whether true or not, about an individual whose identity is apparent or can be reasonably identifiable. Information may or may not be recorded in material form in order to be classified as personal information. An individual’s name, address and telephone numbers are all examples of ‘personal information’.

What is sensitive information?

This policy also refers to ‘sensitive information’. Sensitive information is a category of personal information and is information about a person’s:

  • Racial or ethnic origin, political opinions, memberships of a professional or trade organisation;
  • Religious or philosophical beliefs;
  • Sexual preferences or practices;
  • Health, genetic or biometric information; and
  • Criminal records.

Information that is not personal information

Information is not personal information where Approach Super has removed any reference to an individual so that the person cannot be reasonably identifiable from the information. Approach Super can use this information for its own purposes and for commercial gain.

How and when we collect personal information

Approach Super will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect personal information through some of the following means:

  • From any person nominated by you, including solicitors, accountants and financial planners;
  • In the course of providing any of our services, including when you provide us with information verbally, or complete and submit written forms;
  • When you subscribe to our email service, or access and use our Website, or social media;
  • When you communicate with us via telephone, email, or otherwise correspond with us (whether in writing or electronically);
  • When you provide us with information in response to direct marketing or customer satisfaction and market research surveys and questionnaires;
  • From credit reporting bodies;
  • When you apply for employment with us; and
  • As otherwise required to manage our business.

In some circumstances we will collect personal information from publicly available sources and third parties.

Personal information we collect and hold

The types of personal information we collect and hold about you will depend on a range of circumstances, however, will generally include, but is not limited to:

  • Names, date and place of birth, age, gender, postcode and other demographic information;
  • Tax file number;
  • Information about employer contributions to your Super Fund;
  • Contact details, such as your work and personal email, postal addresses and phone numbers;
  • Proof of identification documentation such as drivers licences and passports;
  • Banking, credit and other finance related information;
  • Financial information, relevant to the provision of accounting and taxation services;
  • Business circumstances;
  • Information about assets, investments and liabilities;
  • Australian Taxation Office related correspondence and correspondence from other parties;
  • If you are applying for employment with us, employment information, such as job application information and the results of criminal history checks;
  • Any information which is publicly available, including on a third party social media service; and
  • Any other information you provide us from time to time, including your preferences or opinions relating to our products and services, and information relating to surveys, competitions, enquiries or complaints.

How we hold personal information

We hold personal information we collect in a number of formats including hard copy, on our computer systems and on other electronic systems.

If Approach Super received personal information it did not request, and Approach Super determines that it would not be permitted to collect this information under the APPs, Approach Super will destroy and de-identify the information as soon as practicable.

Why do we collect and hold personal information?

We collect personal information for purposes including to enable us to provide our services to clients, to contact and communicate with clients, employees, suppliers and other third parties, for internal record keeping and for marketing. We may also use personal information we collect for associated secondary purposes where the person to whom it relates could reasonably expect its use or disclosure.

Collection of sensitive information

Unless required or authorised by law, Approach Super will not collect sensitive information about an individual unless:

  • It has the consent of the person to whom it relates; and
  • The information is reasonably necessary to one or more of Approach Super’s functions or activities.

Employee records

Approach Super is not required to comply with the Privacy Act when handling the personal information of its employees if the personal information is directly related to:

  • A current or former employment relationship; and/or
  • An employee record relating to the employee.

This means that the APPs do not apply to Approach Super when it handles current or past employee records for something that is directly related to the employment relationship. Approach Super is also not required to grant its employees access to their personal information held by Approach Super under the Privacy Act, although it may have an obligation to disclose certain employee records under other legislation.

Use and disclosure of personal information

We may use or disclose personal information that we collect for its primary purpose (for example, providing our services to clients and related activities ancillary to the provision of accounting services) or for related secondary purposes that a person would reasonably expect us to use or disclose that information (for example, where we provide your details to a third party to assist us in the provision of our services to you).

Otherwise, Approach Super will not use or disclose personal information to third parties without the consent of the individual to whom it relates unless the disclosure is:

  • Required or authorised under law; or
  • It is permitted under an exception to the Privacy Act.

Overseas disclosures

Personal information that we collect may be disclosed to entities located overseas or be stored on a server overseas. If we disclose or transfer personal information to countries outside Australia, we will do so in compliance with Australian data protection and privacy laws. The countries to which Approach Super discloses or transfers personal information to, include within Australia and the United States, where some of our data is stored.

Security of personal information

Approach Super will take all reasonable steps to ensure that personal information is stored in a manner that reasonably protects it from misuse, unauthorised access, modification or disclosure. Approach Super does not guarantee that personal information cannot be accessed by unauthorised third parties. Where personal information is no longer required for the purpose for which it was obtained, we will take reasonable steps to destroy or de-identify this information.

Your rights and choices

Accessing and correcting personal information

You may request access to personal information we hold about you. On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover reasonable costs incurred for providing you with access to any of the personal information about you held by us.

You may also request that information about you be corrected if you do not think that it is accurate. We are not obliged to correct any of your personal information if we do not agree that it requires correction, and we may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.

Requests to access or correct personal information should be made in writing, either by post or email, to:

Attention: Office Manager

hello@approachsuper.com.au

1300 290 595

PO Box 108

NERANG QLD 4211

Complaints

Complaints that Approach Super, its employees, its agents or third parties have breached this policy should be made in writing by post or email to Approach Super, to the above address.

Approach Super deals with all complaints through an internal process. We will assess your complaint and respond to you within a reasonable period. Any subsequent action in relation to a complaint will depend on individual circumstances.

Status of the policy

This policy is not intended to create contractually binding obligations upon Approach Super.

This policy may be varied or withdrawn from time to time by Approach Super in its sole discretion.