To safeguard your personal information, we’ve implemented a number of practices, procedures and systems to protect your privacy whenever we collect, hold, use or disclose your personal information.
Why we collect and use personal information
We collect, hold, use and disclose personal information so that we can consider your requirements and provide you with products, advice and services relevant to your media and communication needs.
We may also deal with your personal information for related purposes such as:
- complying with our legal obligations;
- assisting with your questions and complaints;
- arranging for services to be provided by third parties;
- internal operations, such as record keeping, data analytics, auditing or training; and
- promotion of other products or services that may be relevant to you.
We may also collect, use, hold and sometimes disclose personal information about your users in order to administer and manage our business operations. This information is afforded the same standard of care as that of our clients.
What personal information we collect
We may ask you to provide a range of personal information to provide you with our services. The types of personal information we collect include (but are not limited to) your name, date of birth, contact details, employment details, residency and financial details.
It’s your choice whether to provide personal and sensitive information. You have the right not to disclose this information. However, this may affect the quality and accuracy of the advice or services provided. In some circumstances, your adviser may decline to provide advice if they believe there is insufficient information to adequately meet your needs.
We will not collect sensitive information about you unless we have your consent and it is reasonably necessary for the performance of one or more of the entity’s functions or activities or where the collection of sensitive information is permitted by law.
In most instances, we collect your information directly from you via application forms, over the phone, in person or by email. In some instances, we may collect personal information about your users.
How we protect your personal information
We are committed to ensuring that any personal information we hold is stored safely and securely. We have taken a number of precautions to protect against misuse, interference and loss from any unauthorised access, modification or disclosure.
The policies and practices we have in place to protect the personal information that we hold, include:
- storing electronic data on password-protected software;
- requiring our staff and representatives to use passwords when accessing our systems;
- where appropriate, using strict confidentiality arrangements restricting third parties’ use or disclose of personal information for any unauthorised purposes;
- storing carbon copies in locked facilities with physical access restrictions;
- employing firewalls, intrusion prevention systems and virus scanning tools to protect against unauthorised persons, malware and viruses from entering our systems; and
- continued training and education for our staff and representatives about how to protect your personal information and providing regular updates regarding cybersecurity.
We will also take steps to securely de-identify or destroy personal information that is no longer required.
Who we share personal information with
There may be instances where we share your personal information with other entities both within and outside Red Herring Digital. This will vary according to the product or service involved, but could include:
- any person acting on your behalf, including any advisor, solicitor, accountant, etc
- other organisations within Red Herring Digital including related bodies corporate (see the list of companies at the end of this Policy)
- social media companies and other entities through which we provide services to you
- our solicitors, our insurers, courts, tribunals and dispute resolution organisations
- anyone to whom we, or our service providers, are required or authorised by law to disclose your personal information to (for example, law enforcement agencies, Australian and international government and regulatory authorities).
We may also disclose your information to third parties where you have given your consent or where you would reasonably expect us to disclose your information. This may include sharing your personal information with professional organisations, companies and consultants that we work with.
The only circumstances in which we would collect, use or disclose your government related identifiers is where we are required or authorised by law to do so. For example, in certain cases we may be required to disclose your Tax File Number to the Australian Taxation Office.
Personal information may also be used for direct marketing purposes to promote other products, services or events that may be of interest to you. If you do not want to be contacted for marketing purposes, please call or email us.
Disclosure of personal information – overseas recipients
When collecting your personal information, we’ll generally notify you of any overseas recipients that we may disclose your personal information to. We may need to disclose personal information to an overseas recipient in instances, for example, where we outsource a function involved with the financial planning business.
At the current time, Red Herring Digital does not disclose personal information to overseas recipients.
Should this change in future, before disclosing your personal information to an overseas recipient we’ll take all reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to that information. If we cannot ensure this, we will not disclose your personal information without your consent.
Accessing personal information
Subject to certain exemptions permitted by law, you have a right to access any personal information that we hold about you.
You may request access to your personal information by contacting us.
In dealing with your request, we aim to provide a response within 30 days. Where access to personal information is provided, a fee may be involved with locating, copying or sending you the requested information. If there is a fee, we’ll give you an estimate up front and confirm that you’d like us to proceed.
In some circumstances, we may not be able to provide you with access to your personal information, for example when the requested information is commercially sensitive. In these situations, we will inform you and provide an explanation as to why.
Updating and correcting personal information
We take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, up-to-date, complete, relevant and not misleading.
You may request that we change any personal information we hold about you by contacting us (see details below). We’ll generally rely on you to assist us by informing us if the information we hold about you is incomplete or inaccurate.
If you want to remain anonymous or use a pseudonym when dealing with us, we may only be able to provide you with limited information or services. In many cases it will not be possible for us to assist you with your specific request if you do not provide your full details.
When we correct personal information about you that has previously been disclosed to a third party, upon your request, we will take all reasonable steps to notify that third party of the correction where it is not impracticable or unlawful to do so.
Contacting us and providing feedback
If you’re not satisfied with how we have dealt with your personal information and wish to make a complaint, please contact our Privacy Officer on the information below:
Mail: 38/91 Moreland St, Footscray VIC 3011
Phone: 1300 646 118
We will acknowledge receipt of your complaint within 48 hours and provide a response within 45 days.
If you’re unsatisfied with the response, you can refer your complaint to the Office of the Australian Information Commissioner (OAIC). The contact details for the OAIC are:
Mail: GPO Box 5218 Sydney NSW 2001
Phone: 1300 363 992
About this Policy
Red Herring Digital has a number of business partners and affiliates that have their own privacy policies. Please refer to their policies for how those organisations deal with privacy.