WESTERN ASSET PRIVACY STATEMENT
Western Asset Management Australia Pty Ltd (ABN 41 117 767 923, AFSL 303160) ("Western Asset") is subject to the Australian Privacy Principles under the Privacy Act 1988 (Cth) and the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth). Western Asset is committed to protecting and maintaining the privacy, accuracy and security of your personal information. This Privacy Statement outlines how we deliver the rights and protection you are entitled to under the Privacy Act and its amendments. Where there are differences between the Western Asset’s Privacy Statement and the Privacy Act and its amendments, the stronger protection applies.
Throughout this document we refer to “personal information”, which is defined as any “information or an opinion about an identified individual, or an individual who is reasonably identifiable”:
1) whether the information or opinion is true or not; and
2) whether the information or opinion is recorded in a material form or not.
The nature of the personal information collected and maintained by Western Asset generally comprises name, address, telephone number, other identifying information and certain personal financial details. We consider the personal information and the account information that we collect from you on application forms to be confidential. We will take steps to safeguard your information according to strict standards of security and confidentiality.
We only collect personal information that is relevant to our business relationship with you.
If you do not provide the personal information requested, we may not be able to provide a particular service or may be required by law to take particular actions, such as deducting tax at the top marginal rate.
We may store information about you in databases, which may be maintained inside or outside Australia by other companies in the Western Asset group or by other third-party providers to Western Asset subject to the terms of arms-length agreements designed to protect your privacy. Western Asset may also store information about you in databases maintained by third-party storage providers.Use and Disclosure of Personal Information
We will only collect and disclose personal information relevant to the product or service we provide to you. Such purposes may include:
- processing an application
- fulfilling our Know Your Client obligations under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), including the providing of certain customer information to AUSTRAC
- processing receipts and payments and servicing customer accounts
- responding to client enquiries about applications, accounts or services
- understanding client needs and offering products to meet those needs
- allowing our affiliates and selected third parties to promote their products and services to clients
- meeting legal and regulatory requirements.
We may use your information to offer you a wide range of financial services and products that may be of value to you. However, if you do not wish Western Asset or any of our related companies to communicate marketing offers to you, you can notify our Privacy Officer at any time and we will remove your details from our marketing database.
Western Asset Management Company
Attention: Privacy Officer
Level 48, 120 Collins Street
Melbourne VIC 3000
We may share your personal information with other Western Asset entities and related companies. In common with many organisations, we are able to keep our costs down by obtaining some routine services from external service providers. Unless you have instructed us otherwise, your information may be provided to third parties or related companies on a confidential basis for purposes related to the administration of your funds.
If you use the services of a financial adviser or a consultant to invest with Western Asset, your financial adviser or consultant will have access to the information we hold on you, unless you inform us that you no longer have a relationship with that adviser or consultant.Protecting and Maintaining your Personal Information
We will ensure that your personal information is kept secure and confidential.
Only employees of Western Asset, and those who perform services on our behalf who are authorised to handle your information, will have access to your personal information.
We will not retain your information any longer than is required to fulfil our legal obligations. As a guide, the law requires us to retain records for seven years.
We will, with your help, keep your personal information accurate, complete and up-to-date. To assist us with this, please notify your Relationship Manager about any changes to the information you have provided to us. Furthermore, if you believe the information that we have about you is not accurate, complete or up-to-date, please contact our Compliance Manager and we will use all reasonable efforts to correct the information.
We use a number of mechanisms to protect the security and integrity of your personal information. Once any personal information comes into our possession, we will take reasonable steps to protect that information from misuse and loss and from unauthorised access, modification or disclosure.Data Breach Events
In the event Western Asset has reasonable grounds to believe there has been an eligible data breach, Western Asset will follow its internal Incident Response Plan. If determined to be a valid data breach, and notification exceptions do not apply, notification of the event will be made to the Australian Information Commissioner and affected individual(s) and will include the following information:
- details of the entity breached (Western Asset);
- a description of the serious data breach;
- the type of information concerned, and;
- recommendations about the steps you should take in response to the serious data breach
You may request access to most of the personal information that we or an outsourced service provider holds in relation to your investments, by submitting your request in writing to our Privacy Officer. We will inform you beforehand if there is a cost associated with providing this information to you. We retain the right to request adequate proof of identification before authorising any requests for access to personal information. If we deny your request for access, we will let you know why.More Information
If you believe the information we hold about you is incorrect or if you believe we have breached our Privacy Statement, you have the right to have the information corrected or to lodge a complaint. We will investigate your complaint within five working days. If your complaint is justified, we will take all reasonable action to ensure that it does not happen again.
If your complaint is not resolved to your satisfaction, you may apply to the Office of the Australian Information Commissioner (OAIC), to have your complaint investigated. For further information about how you may lodge a complaint with OAIC please refer to their website, www.oaic.gov.au. You may also contact them on 1300 363 992 or in writing at GPO Box 5218, Sydney NSW 2001.
Western Asset may make changes to this Privacy Statement from time to time for any reason. We will publish those changes on our web site. This Privacy Statement was last amended on 20 September 2017.