Midwinter Advice Solutions Pty Ltd (“MAS”) develop and distribute the AdviserTECH service - an online technical manual that helps advisers answer complex questions about superannuation, retirement, estate planning and other tax issues.
Typically MAS will only store client information incidental to the lease of this service. However, there may be instances where we are exposed to client information.
Privacy Principle 1 – Collection
MAS will not collect Personal Information unless requested a by a client and where the information is necessary for one or more of its functions or activities. MAS will collect Personal Information only by lawful and fair means and not in an unreasonably intrusive way.
Privacy Principle 2 - Use and Disclosure
MAS will not use or disclose Personal Information about an individual for a purpose other than the primary purpose of collection.
Privacy Principle 3 - Data Quality
MAS will take reasonable steps to make sure that the Personal Information it collects, uses or discloses is accurate, complete and up to date.
Privacy Principle 4 - Data Security
MAS will take reasonable steps to protect the Personal Information it holds from misuse, loss and from unauthorised access, modification or disclosure. MAS will take reasonable steps to destroy or permanently de-identify Personal Information if it is no longer needed for any purpose for which the information may be used or disclosed under Privacy Principle 2.
Privacy Principle 5 – Openness
MAS has set out in a document clearly expressed policies on its management of Personal Information. This document is available to anyone who asks for it. On request by any MAS client, MAS must take reasonable steps to let the requestor know, generally, what sort of Personal Information it holds, for what purposes, and how it collects, holds, uses and discloses that information.
Privacy Principle 6 - Access and Correction
If MAS holds Personal Information about an individual, it will provide the individual with access to the information on request by the individual, irrespective of the individual's nationality or place of residence, except to the extent that MAS must provide reasons for denial of access or a refusal to correct personal information.
Privacy Principle 7 – Identifiers
MAS will not adopt as its own identifier of an individual an identifier of the individual that has been assigned by: an agency; or an agent of an agency acting in its capacity as agent; or a contracted service provider for a Commonwealth contract acting in its capacity as contracted service provider for that contract.
Privacy Principle 8 – Anonymity
Wherever it is lawful and practicable, individuals will have the option of not identifying themselves when entering transactions with MAS.
Privacy Principle 9 - Transborder Data Flows
MAS will not transfer Personal Information about an individual to someone who is in a foreign country.
Privacy Principle 10 - Sensitive Information
MAS will not collect sensitive information about an individual unless
- the individual has consented, or, in the case of Personal Information from or about a child, the relevant child's legal guardian has consented, or
- the collection is required by law.
If you have privacy concerns, please contact the Midwinter Compliance Officer on 1300 882 938 or by emailing firstname.lastname@example.org . You can also obtain further information from the Privacy Commissioner's website.