What is ‘Personal Information’?
Personal Information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information is recorded in a material form or not.
Types of information collected
We may collect and hold personal information about you, that is, information that can identify you, and is relevant to providing you with the services you are seeking. The kinds of information we typically collect includes name, address, date of birth, phone number, email address, bank account details, electronic information from your use of our website (see further below), and any other information relevant to providing you with the services you are, or someone else you know is, seeking. We are required to take any steps required to ensure that the information we have collected is accurate, up-to-date, complete and relevant.
Method of collection
Personal information will generally be collected directly from you through the use of any of our standard forms, over the internet, via email, or through a telephone conversation with you.
There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect personal information directly from you. For example, we may also collect personal information about you from third parties acting on your behalf (for instance an Enduring Power of Attorney).
We will usually notify you about these instances as soon as reasonably practicable after the information has been collected.
Unsolicited person information
Where we receive personal information which we did not solicit, and is not required to solicited by us, we will take steps to de-identify the information and ensure its confidential destruction as soon as practicable.
Purpose of collection
The personal information that we collect and hold about you depends on your interaction with us. Generally, we collect, use and hold your personal information for the purposes of:
- providing services to you or someone else you know;
- monitoring, auditing and evaluating our services;
- providing you with marketing information (including newsletters and emails) about other services that we, our related entities and other organisations that we have affiliations with, offer that may be of interest to you;
- facilitating our business operations;
- providing you with the opportunity to attend our seminars and events;
- complying with any legal or regulatory requirements;
- analysing our services and customer needs with a view to improving those services; and
- dealing with any complaints or enquiries.
With your consent, we may also send you marketing information via commercial electronic message (including SMS or text message) about other services and investment opportunities that we offer that may be of interest to you.
Anonymous information or individuals using pseudonyms
In order to comply with the requirements of the Anti-Money Laundering and Counter-Terrorism Financing Act and the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2001 (No 1), we are required to identify unitholders who invest in our managed investment schemes. We are therefore unable to deal with an anonymous person / entity or a person / entity who seeks to deal with us using a pseudonym.
Failure to provide information
If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, are seeking.
If you access our website, we may collect additional personal information about you in the form of your IP address and domain name.
Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.
Use and disclosure
Generally, we only use or disclose personal information about you for the purposes for which it was collected (set out above). We may disclose personal information about you:
- Internally to our staff;
- to our related bodies corporate;
- to any person where necessary or desirable in connection with the provision of our products or services;
- to our professional advisers such as auditors, accountants, lawyers and insurance companies consistent with normal business practices;
- to third parties we may engage from time to time to assist us in the promotion of our product and services, and who may receive limited personal information for that purpose;
- to external service providers in Europe, Asia, Africa and the Americas (on a confidential basis) so that they can provide us services related to our business – for example, IT services;
- Where required or authorised by law; and
- Where you consent to the disclosure.
We may rely on employee and related bodies corporate exemptions that are available to us under the Privacy Act when using or disclosing personal information, where applicable.
Government related identifiers
We will not adopt a government related identifier of an individual as our own identifier of any individual. We will not disclose a government related identifier of an individual unless
- it is necessary for us to verify an individual’s identity;
- it is reasonably necessary for us to fulfil our obligations to an agency or a State or Territory authority;
- it is required or authorised under an Australian law or a court / tribunal order;
- a permitted general situation exists;
- we reasonably believe that the use or disclosure of the identifier is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
- is prescribed by the regulations.
Access and correction
You may request access to personal information we hold about you, by making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making a request for access). We may refuse a request for access to personal information in circumstances prescribed by the Privacy Act. If we refuse to give you access, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons).
If upon receiving access to your personal information, or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please let us know immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.
If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint.
We are committed to keeping secure the information we collect from you. We store your personal information about you in different ways, including in paper and in electronic form. We take reasonable measures to ensure that your personal information is stored safely to protect it from loss, misuse, unauthorised access, alteration or disclosure, including electronic and physical security measures. We have implemented a Data Breach Response Plan (Response Plan) which sets out procedures and clear lines of authority for Sentinel employees in the event that Sentinel experiences a data breach (or suspects that a data breach may occur).
Complaints and feedback
If you wish to make a complaint about a breach of the Privacy Act, Australian Privacy Principles or a privacy code that applies to us, please contact us as set out below and we will take reasonable steps to investigate the complaint and respond to you.
Street address: Level 25, 240 Queen Street, Brisbane, Queensland 4000
Email address: firstname.lastname@example.org
Telephone: 07 3733 1660
Fax: 07 3733 1669
Australian Privacy Commissioner
If you are not satisfied with our response, you may contact the Australian Privacy Commissioner:
Telephone: 1300 363 992
For more information about privacy in general, you can visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.