Smith Thornton Privacy Policy

Introduction


Smith Thornton understands the importance of the personal information that we hold about clients and the trust placed in us to protect the privacy of this information.


This Privacy Policy describes our current policies and practices in relation to the collection, handling, use and disclosure of personal information, in accordance with the requirements of the Australian Privacy Principles of the Privacy Act 1988 (Cth). It also deals with how you can complain about a breach of the privacy laws, how you can access the personal information we hold about you and how to have that information corrected.


Collection and Holding Personal Information


Smith Thornton collects and holds personal information necessary to deliver our services, products, business functions and activities.


Typically, we only collect information about you when you provide it to us, or it is provided to us with your authority.


The types of personal information we may collect generally include:


  • Names, addresses, telephone numbers, email addresses, other contact details;
  • Date and place of birth
  • Financial information;
  • Identification details;
  • Tax file numbers and other government-issued identification numbers, such as driver's licence, passport, Medicare card or other ID document numbers 
  • Biometric information, such as a facial image, to verify your identity 
  • Employment details;
  • Information necessary to make or receive payments to or from you;
  • Information about your spouse and dependants.
  • Any other information you choose to provide to us 


We will collect information directly from you whether you deal with us over the telephone or in person, send us a letter or visit our website, www.smiththornton.com.au. On occasions, we may collect personal information about you from third parties, for example, ASIC and the ATO, or that is otherwise available in the public domain, where this information will help us in providing services to clients.


If you do not provide us with some or all of the information that we ask for, we may not be permitted under law to provide services to you.


Use and Disclosure of Personal Information


Smith Thornton collects personal information in order to provide a service to you or maintain our relationship with you. Aside from this, we collect and use your personal information for:


  • Establish and verify your identity;
  • Perform our administrative procedures, such as accounting, archiving, compliance, invoicing and record keeping;
  • Meet our legal and regulatory obligations, including anti-money laundering and counter-terrorism financing (AML/CTF) requirements 
  • Detect and prevent fraud, and keep our systems secure 
  • To keep clients and other contacts informed of services that may interest you and ongoing developments within the industry;
  • Conducting market or customer satisfaction research;
  • Comply with legislative and regulatory requirements.


You authorise Smith Thornton to disclose necessary information to related companies, affiliates and agents who provide us with services in connection with the provision of services or products you have requested from us. These parties are prohibited from using your personal information except for the specific purpose for which we supply it to them.


We may disclose your personal information to third parties such as:


  • Regulatory bodies, government agencies, law enforcement bodies and courts;
  • Financial institutions;
  • External advisers, we engage from time to time to carry out, or advise on, our services;
  • Knight Financial Advisors, a financial planning firm that Smith Thornton is affiliated with, where you engage in their services;
  • Accredited identity verification providers, including APLYiD (APLYiD Pty Ltd, ABN 36 632 866 794)
  • Any person, to the extent necessary, in our view, in order to carry out the instructions you give to us.


In some situations, we may need to disclose your personal information to a third party outside Australia. If we believe that the overseas third party is not subject to, or has not agreed to comply with, privacy obligations equivalent to those which apply to us, we will seek your consent to transfer the information, except where the Australian Privacy Principles do not require us to do so.


Identity Verification and Government Data Matching (DVS) 


To verify your identity, we may use electronic identity verification services, including the Australian Government's Document Verification Service (DVS). 


Where you have consented, your name, date of birth and identity document details will be securely sent to the relevant Commonwealth or State authority that issued your document. This may include passport offices, driver licence authorities, the Department of Home Affairs, Births, Deaths and Marriages, or other authorised record holders. 

These authorities check whether the details you have provided match the records they hold. 


We do not receive a copy of your government records. The authority returns a match result only, confirming whether your details match (yes or no). 


This process may be carried out through accredited identity verification providers, including APLYiD (APLYiD Pty Ltd, ABN 36 632 866 794) and its sub-providers.

 

More information about the DVS is available at idmatch.gov.au. 


Biometric Information 


As part of identity verification, we may collect biometric information, such as a facial image or a short video of you holding your ID. 


Biometric information may be used to: 

  • Confirm that you are a real person and physically present 
  • Match your image to the photograph on your identification document 
  • Reduce the risk of fraud and identity theft 


Biometric information is treated as sensitive information under the Privacy Act. We only use it for identity verification and related compliance purposes, and only with your consent. 


Consent to Collection and Identity Verification 


By providing your personal information and completing the identity verification process, you consent to: 


  • The collection, use and disclosure of your personal information for identity verification, AML/CTF and related compliance purposes 
  • The collection and use of biometric information, such as a facial image or video, for identity verification 
  • Your information being checked against records held by Commonwealth and State authorities through the DVS 
  • Your information being shared with our authorised identity verification providers, including APLYiD 


Your consent is voluntary. You can withdraw your consent at any time by contacting our Privacy Officer.


If you do not consent or do not provide the information we need, we may not be able to verify your identity electronically. In that case, we may need to verify your identity in another way, or we may not be able to provide our services to you. 


Smith Thornton Website


For statistical purposes, we collect information on website activity, such as date and time of visits, number of pages viewed and the operating systems and browsers used to access the site. This information does not specifically identify an individual, but it does provide us with statistics that we can use to analyse and improve our website.


Access to your Personal Information


You can request any of your personal details we have on file by writing to us and identifying the nature of the personal information you request. We may charge a fee to respond to your request, which may also include any additional costs we incur in providing the information. You can contact us via:


Privacy Officer

Smith Thornton

PO Box 5445

ALBANY WA 6332

Email: mail@smiththornton.com.au


We will take practical measures to ensure that your personal information is accurate, complete and up to date. Please contact us immediately if at any time you find that your current personal information we hold about you is inaccurate, incomplete or out of date, and we will correct it or advise you of any additional information we require to make the change.


Security of your Personal Information


Smith Thornton will take practical measures to protect the personal information we hold from misuse, loss, and from unauthorised access, modification or disclosure. Our employees are required to follow the Australian Privacy Principles and respect the confidentiality of personal information and the privacy of individuals.


Smith Thornton takes practical measures to destroy or permanently de-identify records no longer needed.


Complaints


If you believe that the privacy of your personal information is not being sufficiently protected, please contact our Privacy Officer. We will endeavour to resolve your complaint internally.


If we do not resolve your complaint to your satisfaction, you may contact the Australian Information Commissioner to have your complaint investigated. For more information, please contact the Commissioner's hotline service on 1300 363 992.


More Information


We may update this Privacy Policy from time to time to reflect changes in our practices or in the law. The latest version will always be available on our website. 


If you would like more information regarding how your personal information is collected or used, or regarding our Privacy Policy, please contact our Privacy Officer at mail@smiththornton.com.au. Additional information may be found on the Australian Information Commissioner's website at www.oaic.gov.au.