We recognise that your privacy is important to you, and we are committed to protecting your privacy and handling your personal information in an open and transparent way.
- we provide services to you or our clients;
- you use our website; or
- we perform any other activities that form part of the operation of our business.
3. What laws apply to us?
When handling personal information we will comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act) and other applicable legislation (such as Australian State and Territory health privacy legislation), as well as the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).
The APPs are legally binding principles that are designed to ensure that individuals’ personal information is protected throughout the information lifecycle, i.e. from the time the information is collected through to its destruction. The APPs also give individuals the right to access their personal information and have it corrected if it is incorrect.
Additional information about privacy is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.
4. Personal information we collect
Generally, we only collect personal information that is reasonably necessary for, or directly related to, one of more of the functions and activities of our business. For example, we may request that you provide your personal information when you instruct us to provide services, acquire products, invest with us or interact with us, e.g., via our website. There may be other occasions when we collect personal information about you or from other sources, such as from our related entities, a publicly maintained record or from an information services provider. We may also share personal information about you with our related entities.
The types of personal information we collect or be provided with include, but are not limited to:
- Name, occupation, contact and address details.
- Date of birth and gender.
- Details about your spouse, children and other family members, e.g., to provide estate planning, family continuity or wealth transition services.
- Employment records.
- Financial records, including bank account details, financial statements, tax returns, valuations; and asset / investment related information.
- Information about shareholders, beneficiaries and beneficial owners.
We may also collect sensitive personal information (also called ‘special category information’). For example, where we are provided with such information directly by our clients to provide services, or where we collect information directly from individuals with their consent. This may include:
- Government identifiers, such as drivers’ licence, passport and Medicare numbers.
- Tax file numbers.
- Health records or status.
We do not collect or hold sensitive information, such as racial or ethnic origins, religious affiliation or political opinions.
We also collect personal information (such as contact details and account details) from suppliers, contractors and third party service providers that we engage to help us operate our business.
We may also collect your personal contact details when you use our website or when you attend a Keystone event, or an event sponsored by Keystone. For example, if you sign up to receive communications about services provided by us.
5. Collection and use of personal information
5.1 How we collect personal information
Generally, we will collect your personal information directly from you, e.g., when we deal with you in person or over the phone, when you send us correspondence (including via email), when you complete a form, questionnaire or survey, when you attend a Keystone event (or Keystone sponsored event) or when you use our website or our social media.
We may also collect your personal information when you invest in a financial product that we are associated with, e.g., where we arrange the issue of the financial product to you.
Your personal information may also be collected as part of the identification and verification activities we conduct on a person, e.g., where you are listed as a beneficial owner of a person.
Sometimes it may be necessary for us to collect your personal information from a third party. For example, we may collect your personal information from a publicly available record (such as an company search), information provider or your personal representative.
5.2 Providing personal information about someone else
5.3 Holding personal information
In the event you cease to be a client of Keystone, personal information we hold about you will be maintained for at least as long as we are required to comply with any legislative document retention requirement. After that time, we may destroy your personal information or put it beyond use, e.g., de-identify the personal information so it cannot be used to identify you.
5.4 Purpose for collecting, holding, using and disclosing personal information
Keystone collects, holds and uses personal information for a number of purposes including:
- To provide products and services.
- To respond to requests or queries.
- To provide you with information about our products or services, such as marketing material.
- To operate our business and any company, managed investment scheme, trust or syndicate, including entering details on a register of members and performing compliance reviews or audits.
- To maintain contact and keep you informed of our services, updates, industry developments and events.
- To verify your identity, including under anti-money laundering laws.
- For administrative purposes, including processing applications, distributions and payment transactions.
- For recruitment purposes and matters relating to the employment of our personnel, providing internal services or benefits to our staff.
- When engaging service providers, contractors or suppliers relating to the operation of our business.
- To manage any complaint or conflict of interest.
- For seeking your feedback on our services or to conduct surveys.
- To meet any legal or regulatory obligations, e.g., providing the Australian Taxation Office with tax file numbers.
- As part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including Keystone’s business) or entering into an alliance, joint venture or referral arrangement.
- For market or other research purposes.
- To perform internal statistical analysis, including of our databases and website.
- To manage and improve our website.
- For any other business related purposes.
If you do not provide us with the personal information we have requested, we may not be able to complete or fulfil the purpose for which such information was requested or collected, including providing you with the services or products we were engaged to perform.
The types of third parties to whom we may disclose your personal information include:
- Your financial advisers or other professional advisers.
- Third parties we engage to assist us in providing services to our clients or in the operation of our business (i.e. subcontractors, advisors and suppliers).
- Third parties we engage to provide due diligence, compliance, custody, administration, technology, auditing, mailing, printing or other services.
- Third parties we engage to verify the identity of customers.
- Law enforcement, regulatory or government agencies (including the Australian Taxation Office or the Australian Securities and Investments Commission).
- Our professional advisers, including experts, legal and accounting firms, auditors, consultants and other advisers.
- As part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including Keystone’s business) or to enter into an alliance, joint venture or referral arrangement.
- Our related bodies corporate or any other company within the Keystone group.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you.
6. Information storage and security
We hold personal information in hard copy and electronic formats. We use a range of physical, operational and technological security measures to protect this information. These measures include:
- Administrative and technical controls to restrict access to personal information to only those people who need access.
- Technological security measures, including passwords, fire walls, encryption and anti-virus software.
- Physical security measures, such as restricted access our premises, locked cabinets and offices.
We generally store personal information in our computer databases. We do not utilise third party storage providers and do not store data or personal information outside of Australia.
7. Privacy on our website
7.1 Automatic collection of personal information
Cookies and other technologies may be used by us on our website and through email to automatically collect certain types of information. The collection of this information allows us to customise your online experience, market products and services to you, improve the performance, usability and effectiveness of our online presence and to measure the effectiveness of our marketing activities.
7.2 IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It is not linked to personally identifiable information. We may use IP addresses to analyse trends, administer the website, track user’s movement, and gather broad demographic information.
A ‘cookie’ is a small text file that is placed on your computer or internet-enabled device whenever you visit our website. This allows the website to remember your computer or device and serves a number of purposes.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our website and geographic origin of visitor trends, and not to identify individual visitors.
7.4 Location-based tools
We may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services (if applicable).
7.5 Social media features
Our website may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any Keystone social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.
7.6 Links to third party websites
7.7 Your choice
You have several choices regarding your use of our website. In general, you are not required to provide personal information when you visit our website. However, if you apply to receive information about our services, events, newsletters and updates, wish to acquire products or services or apply for a job, provision of certain personal information will generally be required.
We understand the importance of protecting children’s privacy, especially in an online environment. In particular, our website is not intentionally designed for or directed at children under the age of 18. It is our policy to never knowingly collect or maintain information about anyone under the age of 18, except as part of a specific engagement to provide services or products that necessitates such personal information being collected, such as to provide estate planning, family continuity or wealth transition services.
9. Accessing your personal information
You can request access to your personal information, subject to some limited exceptions permitted or required by law. Such requests must be made in writing to our Privacy Officer. If we decline your request for access, we will provide a written explanation to you for the refusal.
Upon confirmation of your identity, we may provide you with access to information by either providing you with copies of the information requested or allowing you to inspect the information. We may charge reasonable costs for providing you access to, or copies of, your personal information.
We will not provide you with access to information which would reveal any confidential formulae or the detail of any in-house evaluative decision making process, but may instead provide you with the result of the formulae or process or an explanation of that result (if applicable).
10. Correcting your personal information
If you believe that any personal information we have collected about you is inaccurate, not up-to-date, incomplete, irrelevant or misleading, you may request the information to be corrected. To do so, please contact our Privacy Officer and we will take reasonable steps to correct the information in accordance with the requirements of the Privacy Act.
If you wish to make a complaint about our handling of your personal information, you can contact our Privacy Officer. You may be asked to set out the details of your complaint in writing.
We will endeavour to reply to you within 30 days of receipt of the complaint and, where appropriate, will advise you of the general reasons for the outcome of the complaint. In some circumstances, our Privacy Officer may decline to investigate the complaint, e.g., if the complaint relates to an act or practice that is not an interference of the privacy of the person making the complaint. If you are not satisfied with the outcome of your complaint, you can refer your complaint to the Office of the Australian Information Commissioner (telephone 1300 363 992).
13. Our contact details
PO Box 7120, Riverside Centre, Brisbane, Queensland 4001
T: +61 7 3229 7955
F: +61 7 3211 7446