Walker and Miller FS- PRIVACY POLICY

Walker and Miller FS would like to provide the best possible service to our members and clients by making the most efficient use of your personal information. It is of utmost importance to us that you are confident that any personal information provided to us is treated with an appropriate degree of privacy.

Definitions:

Personal Information:
Personal Information is information or an opinion (including information or an opinion forming part of a database) whether true or not, and whether recorded in a material form or not about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Sensitive Information:
Sensitive information is a subset of personal information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences, criminal record or health information about an individual.

Collection of Personal Information

It is essential for Walker and Miller FS to collect personal information to complete its standard business activities of providing education and training services to our members and clients.

When collecting information we:

• Establish and maintain a database to ensure prompt and efficient service from us
• Establish and maintain a database for tracking education and training stages to ensure prompt and efficient service from our contractors
• Establish and maintain a database for follow-up and notification of any potential event or training that may be of interest to you and your staff.

Collection and usage of personal information is essential for us to complete our business with clients. Where reasonable and practicable, Walker and Miller FS will collect personal information directly from clients. This may occur for example when completing an application form for a product or request a product or service over the telephone or Internet.

Where not reasonable or practicable to collect personal information directly, Walker and Miller FS relies on third parties. Below are examples of situations where we may receive personal information from another source, and why this would happen.

• Application for a service through a Walker and Miller FS business alliance
• Processing of online enquiries for service provision
• Another business or entity who provides Walker and Miller FS the information to meet legislative requirements

Consent

In the majority of circumstances Walker and Miller FS will require your specific consent before we collect, use or disclose personal information. Consent will be obtained in writing; however, there may be some situations where your verbal consent is accepted.

Disclosure

Walker and Miller FS does not generally disclose personal information to any other party, unless required or authorised by law, consent is given, or is required to complete a business transaction.

There are times when Walker and Miller FS is required or authorised by law to disclose personal information. Personal information may be required in accordance with taxation law to be provided to the taxation office, or under subpoena to a Court of Law.

Personal information may also be disclosed where consent has been obtained. Consent may be received directly from a client, as set out above, or may be implied from a client’s conduct.

Personal information is only disclosed to parties outside Walker and Miller FS where it is required to complete business activities. Some examples where this may occur are: –

• Contractors for the provision of sub-contracted services

Accuracy

It is essential to Walker and Miller FS that personal information is complete and up-to-date at all times to effectively conduct standard business activities.

When using personal information we will contact a client to determine if any personal details have changed. Walker and Miller FS can also contacted at any time to update personal information, or to advise that information held is inaccurate or incomplete.

Access

Individuals can request access to their personal information by contacting Walker and Miller FS. A summary of personal information (E.g. name, address, phone number) is freely accessible.

In some situations, where the information requested goes beyond a basic summary, a fee may be charged for access. This fee is used to cover the cost to Walker and Miller FS for retrieving and supplying the information.

Walker and Miller FS will endeavour to handle all requests for personal information within 30 days of having received the request. Some requests may take longer than 30 days, depending on the information sought, in which case the individual will be notified of the expected time frame as soon as is practicable.

There are some circumstances where requests for access to information may be denied by Walker and Miller FS , such as where the information may relate to existing or anticipated legal proceedings, where denying access is required or authorised by law, or where the request for access is regarded as frivolous and vexatious.

If a request to access or change personal information is denied, we will offer a formal explanation for our actions.

Security

It is of utmost importance to Walker and Miller FS that personal information is protected from unauthorised access, loss, modification, misuse or disclosure.

When information is no longer required we ensure that it is deleted from our systems, destroyed in a secure manner, or permanently de-identified.

In common with other service providers we use agents and other third parties to provide some services to Walker and Miller FS and for this purpose we sometimes need to provide them with relevant parts of the information which we have obtained from clients under their contracts. These third parties are required to keep your information confidential and use it only for the purposes for which we are permitted.

We may offer through our website products or services that are supplied by or through other organisations. If a client enquires about the service we will need to pass to them relevant details about the client and their enquiry, to complete the transaction.

Information Security

Walker and Miller FS takes all reasonable steps to protect clients’ security when using our web site but they you should be aware that no transmission of information to and from web sites is ever totally secure.

Identifiers

In some circumstances certain Commonwealth identifies (e.g. Tax File Numbers) may be collected as proof of identity when carrying out standard business activities. These identifiers are securely destroyed, and are not used by Walker and Miller FS in any way to identify an individual.

Wherever it is lawful and practicable to do so Walker and Miller FS will endeavour to deal with clients anonymously. For example, when a client requests information regarding the services offered by Walker and Miller FS.

Sensitive Information

Sensitive information (as defined above) is only collected by Walker and Miller FS where consent has been obtained, it is allowed by law, or the collection is necessary for the establishment, exercise or defence of a legal claim.

Trans Border Data Flows

Walker and Miller FS does not send any personal information outside of Australia unless we are authorised to, or required to by law.

Complaints

Any complaints with regard to the handling of your personal information in breach of this Privacy Policy can be directed to:

Privacy Officer
Walker and Miller Financial Services

PO Box 6478
North Sydney NSW 2060

Tel: 1300 136 947

Any complaints that have not been handled satisfactorily by Walker and Miller FS can be referred to the Federal Privacy Commissioner:

Telephone:	1300 363 992, or
Address:	Director of Complaints Office of the Federal Privacy Commissioner GPO Box 5218 Sydney NSW 1042