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), including the privacy Amendment (Notifiable Date Breaches) Act 2017.
2. Collection of your personal information
Cashel will only collect and store personal information for the purpose of providing, co-ordinating and marketing financial services to you. In providing, marketing or co-ordinating these financial services, we are subject to certain legislative and regulatory requirements which will necessitate us obtaining and holding personal information about you. This will assist us in our ability to provide you with the highest level of service we can provide. Failure to provide full and complete personal information to us may mean that we are unable to provide you with the appropriate level of service. The information we collect and store may include your name, address, date of birth, gender, marital status, dependents, occupation, contact details, and any financial information that assist us in providing a service. Once we have obtained your 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 You should let us know when your information becomes out-of-date or requires correction. Furthermore, identifying information is also required, a head and shoulders photograph from your passport, drivers license or other identity card will be required to open up accounts and provide clarification for money laundering and related laws.
You confirm that you are authorised to provide personal details and confirm that you consent to your information being checked with the document issuer or official record holder via third party systems for the purpose of confirming your identity.
3. How we collect your personal information
We collect information in numerous ways. The internet, email, Social Media, verbal and written communication are all used to gather the information that we require from you to provide you with the services that you require. Some collection will be on purpose, that is, a specific question and some may be incidental, that is, information that is obtained from an email or authorised third party such as your accountant.
4. Does Cashel collect sensitive information?
We believe all personal information is sensitive information. 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.
6. Use of your personal data
We will use your personal information for the main purpose of providing and co-ordinating financial services to you. If considered appropriate we may also use your personal information for internal communication purposes such as sending you notifications of new products and services that may be suitable to meet your financial needs and 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:
company share registries;
your margin lender, custodians and platform providers (such as Leveraged Equities, Linear& Netwealth;
issuers of securities and their agents;
trading and clearing agents (such as Pershing Securities Australia Pty Ltd);
our bank and your bank, or cash management account trustee;
giving you credit assistance;
preparing loan documents and applications for potential financiers;
BLSSA Pty Ltd;
debt collectors and/or credit reference agencies;
professional advisers, including our auditors;
third-party providers (such as insurance and mortgage brokers);
parties involved in dispute resolution (including for example, our insurers, lawyers and external complaints handling scheme);
independent contractors or other agents engaged to provide services to you;
We may also use the information for other purposes where you consent to this.
8. Disclosure to regulators, external dispute resolution schemes or as directed by law
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 Office of the Australian Information Commissioner (OAIC), Australian Securities & Investments Commission (ASIC), AUSTRAC, the Australian Securities Exchange Ltd (ASX), Chi-X Australia or other market operators, or by reason of a court order. We may also disclose information that relates to a compliance matter to the Financial Ombudsman Service (FOS) and/or Credit and Investment Ombudsman (CIO) who provide our external dispute resolution (EDR) schemes.
9. 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:
Issuing any client that requires on line access to any part of their relationship with us a unique log-in and password to relevant websites. Please remember that your password is personal to you and should not be disclosed to anyone;
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.
10. 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 of the request and the necessary supporting documentation to enable us to identify you correctly.
In certain circumstances we will be required to collect government related identifiers such as your tax file number or Medicare numbers. We will not disclose this information unless we are authorised by law. Each client account is allocated a unique client account number, which you should keep confidential.
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13. How do you make a 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 wish to complain to us about how we handled your personal information you should complain in writing to our Privacy Officer as outlined below.
The Privacy Officer Cashel House Level 38-55 Collins Street, Melbourne Vic 3000
If we receive a complaint from you about how we handled your personal information we will determine what (if any) action we should take to resolve the complaint.
We will advise you promptly that we have received your complaint and then respond to the complaint within 30 days. If we have been unable to resolve your compliant to your satisfaction, you may take matters further and refer your concerns to the Australian Information Commissioner: