Privacy Policy

How we use personal information

At KLM Strategic Solutions Pty Ltd (“KLMSS”) your and your clients’ privacy is important to us. Privacy laws apply to how we collect, maintain, use and disclose personal information. This applies to not only your personal information but also the personal information of your clients. This Statement explains how the laws affect KLMSS, you, your practice and your clients, including:

• The types of information that we keep on record and how we may use that information.
• Your privacy rights along with our general rights and obligations.
• Our policies in relation to how we collect, maintain, use and disclose your personal information.

Other Privacy Statements

When you use the services offered by KLMSS, the relevant documents will include notices about privacy and requests for consent. Those privacy notices (called Privacy Statements) will specify in more detail how any information about you or your clients may be used or disclosed in relation to the particular service requested. When you request one of our services you consent to us collecting, maintaining, using and disclosing personal information about you and your clients (provided by you or by another person) in accordance with the Privacy Statements in any Agreement you sign and this Privacy Policy.

 

What information does KLMSS hold?

The types of information we ask for will depend on the type of service requested by you. Generally, we keep a record of one or more of the following types of information about you and your clients:

• Information that identifies you or your client, such as names and addresses and other identification information provided by people nominated by you.
• If the advice you are providing is in relation to insurance, information about what is being insured, including health information relating to your client, income and occupation, information about beneficiaries, and information about your client’s claims history.
• If the advice you are providing is in relation to a superannuation or investment products or services, information about your client’s employment, beneficiaries, bank accounts for funds to be transferred to or from and, in some cases, the clients’ health information.
• Transaction information relating to the product or service acquired by your client, such as details of contributions and distributions for investment products.

All information sought is required for our business purposes, which are detailed generally in this Policy and in any other agreement. We do not actively seek to collect sensitive information (for example health information or information about any criminal record), unless it is necessary for our business purposes. If we do have to collect sensitive information, we will only collect, use and disclose it in accordance with privacy laws.

How do we collect personal information?

Generally, we only collect personal information about your clients from you (the adviser and members of your practice), unless it is not reasonable or practical for us to do so or if your clients do not provide their consent. For example, we may collect information from a third party, like your client’s accountant or your client’s superannuation or investment provider for the purpose of preparing the relevant advice documentation. We may also collect information about your clients from a publicly available source.

How do we collect information from our website?

KLMSS collect and hold information about you via our website when you:

• Complete an online request or other type of form.
• Access our website.

We also collect some statistical information about visitors, via our website (for example, the number of visitors, pages viewed, types of transactions conducted, time online and documents downloaded). Some of this statistical information is collected by using cookies. We use this information only for the purposes of evaluating our website performance (including identifying potential performance problems) and continually improving our services. None of the statistical information we prepare from information collected using cookies identifies individual visitors to our website. Other than statistical information, we do not collect any information about you or your clients via our website unless you or your clients provide the information to us.

How may KLMSS use your client’s personal information?

Generally, we use your and your clients’ personal information to:

• Help us process your request for products or services and subsequent investment directions.
• Effectively manage and administer these products and services (including keeping records required under superannuation laws and the Corporations Act).
• Ensure our internal business operations are running smoothly, which may include fulfilling legal requirements, conducting confidential systems maintenance and testing and conducting confidential telephone call monitoring to ensure any staff are properly trained and their service to you continually improved.

If information about you is provided to us but not for the purposes of, or in relation to, the provision of the services provided by KLMSS then, other than for the purposes indicated, we will not use your information for any purpose without your consent. Any form used to collect your information may give more specific details about the way we use your information.

 

 

What rights do we have to disclose personal information?

Generally, we must obtain your consent before we tell anyone about you, your clients or any specific products or services used in your business. You can give us your consent expressly (by telephone or writing to us) or it may be implied by your conduct. Sometimes the law requires or allows us to give out information about you. For example, we must provide your client’s personal details to a court if we are ordered to do so under a subpoena. Depending on the service we provide to you, if it is necessary we may also disclose your personal information to:

• External service providers that provide services to KLMSS or to your business. This is on a confidential basis and includes organisations that provide financial, advisory, administrative or other services, such as investment managers of products you select, financial institutions you nominate, your paraplanning software provider and other relevant industry bodies.
• Anyone acting on your behalf, including your support staff and 3rd party service providers.
• To any party acquiring an interest in our business.
• To a complaints body to whom a complaint relating to a product or service is referred.
• Where the law requires or permits us to do so.
• If you consent.

We may at other times give you more details about our disclosure practices in relation to specific services for example on the disclosure documents and data collection forms we use to collect personal information about you and your clients.

How we protect the security of your information

We take all reasonable steps to protect your and your clients’ personal information from misuse, loss, unauthorised access, modification or disclosure. We have physical, electronic and procedural safeguards to protect your information held by us. For example, your personal information is stored in secured premises, in encrypted electronic databases requiring logins and passwords for access and/or at a secured warehouse. We require all staff to maintain the confidentiality of customer information. We use secure methods to destroy or de-identify any personal information as soon as the law permits, provided the information is no longer needed by us for any purpose.

Changes to our privacy policies

We may amend this Privacy Policy from time to time. Not all changes to our privacy policies will require your consent, for example where office security procedures are changed. We will notify you of any change to our policies that require your consent before being implemented.

 

 

What are your rights?

Unless required by law (for example to comply with a legal duty of disclosure when applying for an insurance product) you need not give us any of the personal information about you, your clients or any other person which may be requested in our communications with you. However, without that information, we may not be able to fulfil your request or provide you with an appropriate level of service. Where we collect information from you about another individual please make that individual aware of that fact and the contents of this Privacy Policy.

Access to your information

You may request access at any time to personal information held by us about you or your clients. We will process your request within a reasonable time, usually 14 days for a straightforward request. More time may be needed, depending on the nature of the request. There is no fee for requesting access to your information, however we may charge you the reasonable costs of processing your request. Sometimes we are not required to provide you with access. If we refuse you access to your personal information, we will tell you the reason why. If we are not required to provide you with access to the information requested, we will consider, if reasonable, whether the use of a mutually agreed intermediary would allow sufficient access to meet your needs and ours.

Correction of information

We try to ensure that all information held by us about you or your clients which we collect, use or disclose is accurate, complete and up-to-date. However, you must promptly notify us if there are any changes to any personal information. You may ask us at any time to correct personal information held by us about you or your clients which you believe is incorrect or out-of-date. We will deal with your request within a reasonable time.

If we disagree as to the accuracy of the information, you may request that we make an appropriate notation in relation to that information noting you consider it is not accurate, complete or up-to date.

Who is KLMSS?

KLMSS is a privately owned company. If there is anything you would like to discuss, please contact us. If you have any questions or concerns about our privacy policy or practices, contact:

KLM Strategic Solutions Pty Ltd
4 Mallee Ridge Drive
Irymple, VIC, 3498

We will try to answer any questions you may have, correct any error on our part or resolve any complaint that you may have about our information handling practices. If we do not resolve a complaint to your satisfaction, you also have the right to complain to the Privacy Commissioner.