The Cashel House of companies including; Cashel Financial Services Pty Ltd, Cashel Corporate Finance Pty Ltd, Cashel Private Wealth Pty Ltd, Cashel Capital Partners Fund 1 Pte Ltd (together Cashel House) believe that the privacy of your Personal Information is important.
1. Our Commitment
At Cashel we recognise that your privacy is very important to you. We are committed to providing you with high quality financial services within a secure and confidential environment. This privacy statement details for your information:
• What personal information we may collect from you and store.
• How your personal information may be used or disclosed.
• The security of any personal information you provide to us.
• How you may access and correct or update your personal information.
• How you can contact us if you have any concerns.
Cashel abides by the Australian Privacy Principles established under the Privacy Act 1988 (Cth) (Privacy Act).
2. Information we may collect from you
Cashel will only collect and store personal information for the purpose of providing financial services and information to you. In providing these financial services we are subject to certain legislative and regulatory requirements which will necessitate us obtaining and holding personal information about your individual objectives, financial situation and needs. This will also assist us in our ability to provide you with appropriate advice and service given your objectives, situation and needs. Failure to provide full and complete personal information to us may mean that we are unable to provide you with an appropriate level of service. The sorts of information we collect and store includes your name, address, date of birth, gender, marital status, dependents, occupation, contact details, and any financial information such as assets and liabilities. Once we hold personal information we will take reasonable steps to keep it accurate, complete and up-to-date. You should let us know when your information becomes out-of-date or requires correction.
3. Does Cashel collect sensitive information?
We sometimes need to collect, store and use sensitive information, such as when we consider applications you have filled out for some insurance and banking products. We may also collect and store information from you which you have provided to us over the telephone or internet. We may also collect and store sensitive information about you from a third party, such as your accountant, tax adviser or your employer.
Sensitive information includes information or an opinion relating to a person’s racial or ethnic origin, political views or memberships, religious beliefs or affiliations, membership of a professional or trade association or trade union, sexual orientation or practices and criminal record. It also includes information about a person’s health and medical history. The Australian Privacy Principles set out restrictions about the way sensitive information can be used.
Unless you give us your consent, or if we are required or permitted by law, we will only use or disclose sensitive information for the purposes for which it was provided.
Given the nature of the financial services that we provide, you will not generally be able to deal on an anonymous basis with us.
5. Use and Disclosure
We will use your personal information for the main purpose of providing financial services to you. If considered appropriate we may also use your personal information for internal communication purposes such as sending you research, newsletters and notifying you of new products and services that may be suitable to meet your financial objectives, unless you have notified us that you do not wish to receive such communications.
We will only disclose personal information to third parties carrying out functions on behalf of Cashel on a confidential basis, including for example:
• registrars of securities;
• fund managers;
• issuers of securities and their agents;
• clearing houses;
• trading and clearing agents;
• our bank and your bank;
• your cash management account trustee;
• your margin lender and/or the custodian of your securities;
• Financial Services Protection Limited;
• Potential financiers;
• debt collectors and/or credit reference agencies;
• professional advisers, including our auditors;
• third-party brokers (such as insurance and mortgage brokers);
• parties involved in dispute resolution (including for example, our insurers, lawyers and external complaints handling scheme);
• independent contractors engaged to provide services to you on our behalf;
• other agents who may assist us in providing services to you (including, for example, external mail houses to enable us to forward information to you).
We may also use the information for other purposes where you consent to this.
You should note that information we collect from you may also be disclosed to third parties if that disclosure is required or authorised by law, including regulators such as the Australian Securities & Investments Commission (ASIC), AUSTRAC, the Australian Securities Exchange Ltd (ASX) or other market operators, or by reason of a court order.
6. How we secure your information
We will protect your personal information from misuse and loss, and destroy or permanently de-identify (where possible) personal information we no longer need.
Even though constant changes to technology mean that we cannot guarantee that data transmission will be 100% secure or safe from attack by unauthorised intruders, we have a range of practices and policies in place to provide a robust security environment, including:
• educating employees as to their obligations with regard to your personal information;
• requiring employees to use passwords when accessing our systems to prevent unauthorised access;
• employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems;
• maintaining our servers in a controlled, secured environment in an Australian location;
• using dedicated secure networks or encryption when we transmit electronic data;
• providing secure storage for physical records; and
• employing physical and electronic means such as alarms to protect against unauthorised access to premises.
7. How you can access and update your information?
You are able to access and update the personal information that we hold about you at any time. To access or amend the personal information that Cashel holds about you, you should contact your advisor, or you can email: firstname.lastname@example.org. We will endeavour to address your request promptly but in any event within 14 days of receipt.
We will not adopt as our own identifiers that you may provide to us such as TFN’s and Medicare numbers. Each client account is allocated a unique client account number, which you should keep confidential.
9. Our website cookies
10. Privacy Complaints
We are committed to providing our clients and other parties whose personal information we hold a fair and responsible system for handling privacy issues. If you have any concerns with regard to your privacy, please contact our Privacy Officer as outlined below. We will seek to address any concerns that you may have through our complaints handling processes, but if you wish to take matters further you may refer your concerns to the Australian Information Commissioner (OAIC) (website www.oaic.gov.au or telephone 1300 363 992).
11. How to contact Cashel
If you have any questions or feedback about this Policy or you have any privacy issues concerning Cashel, please contact the Privacy Officer in writing to:
The Privacy Officer Cashel House Level 38-55 Collins Street, Melbourne Vic 3000
If you wish to access and update your personal information please contact your Adviser or the Privacy Officer at the address above.