The purpose of this policy is to set out our approach to the handling of personal information about members of RetireSelect (the Funds).

The Privacy Act sets out 10 National Privacy Principles (NPPs) that define minimum standards on how a private organisation must handle personal information. As trustee of RetireSelect, MAP Funds Management Limited (ABN 85 011 061 831) (the Trustee) supports and adopts these principles. The distributors of the Funds facilitate the collection of your personal information and will have access to information about you and your investment/s in the Funds.

Each of the NPPs together with the Trustee's policy is set out below.

Privacy Officer
The Trustee's Chief Financial Officer (CFO) is the nominated Privacy Officer in respect of the Funds. Privacy issues, complaints or requests for private information should be referred to the CFO.

Staff Issues
All staff employed by the Trustee are required, as a condition of employment, to sign a confidentiality agreement.

Privacy Disclosure
Where individuals supply the Trustee with personal information, the Trustee will advise them that:

The Trustee is committed to protecting the privacy of information you provide in relation to your investment in the Fund. The information provided is only used to administer your investment, to communicate with you about your investment and to ensure that you receive the benefits relating to your investment.

The Trustee does not normally disclose information about you to outside parties, except those contracted to provide services to the Trustee. These include the distributor of the Fund and the Fund's auditors, lawyers, custodian, investment providers and platforms and insurers. If you, or anyone else on your behalf, makes a claim for a benefit, the insurer may give or receive information about you to or from medical practitioners, legal advisers, health service providers, past or present employers, other consultants, experts and companies in order to assess and process the claim.

With your written consent, we will disclose information about your investment in the Fund to your accountant, financial consultant or others you have nominated. Personal information may also be disclosed to the Australian Taxation Office or other government authorities or agencies as required by law.

Staff Training
Existing and new staff are made aware of the Trustee's policy on privacy of personal information through appropriate training.

NPP1 - Collection

An organisation must only collect personal information:
  • necessary for its function or activities;
  • fairly, lawfully and not in an unreasonably intrusive way;
  • wherever reasonable and practicable, directly from the relevant individual;
  • if reasonable steps are taken to notify the individual of:
    • the identity of the organisation and how to contact it;
    • the fact that the individual may gain access to the information collected;
    • the purposes for which the information is collected;
    • the organisation, or the types of organisations, to which the organisation usually discloses the information;
    • any law that requires the information to be collected; and
    • the main consequences for the individual if the information is not provided.

The Trustee collects personal information about you in order to issue interests in the Funds, process transaction and pay benefits from the Funds to you.

In addition, under the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) requirements, the Trustee must collect information about your identity in order for particular transactions to occur.

The Trustee only collects personal information under the following conditions:

  • The Trustee is identified as the collecting organisation and the Trustee's contact details are disclosed;
  • You are made aware of your right to gain access to the information collected;
  • The purposes for which the information is collected is clear;
  • You are informed of information which may be disclosed to another organisation, except where provisions of the AML/CTF Act prevent this;
  • You are informed of any law that requires the information to be collected; and
  • You are informed of the main consequences if the information is not provided.

The Trustee's information collection forms are designed to comply with these conditions.

NPP2 - Use and disclosure

An organisation must only use or disclose personal information:
  • in ways that the individual would expect;
  • in ways that the individual has consented to;
  • for direct marketing where:
    • the information is not sensitive (for example, information about political beliefs, sexual preferences and health information);
    • it is impractical to seek the individual's consent beforehand;
    • no charge will be made for a request not to receive direct marketing communications;
    • the individual has not made a request to the organisation not to receive direct marketing communications;
    • the organisation gives the individual the express opportunity not to receive direct marketing communications; and
  • in ways that are required by the public interest (for example, law enforcement and public health and safety).

At all times, personal information is treated as confidential and any sensitive information is treated as highly confidential.

The Trustee will only disclose your information to persons or organisations in the following circumstances:

  • To the ATO, APRA, AUSTRAC or other government authorities or agencies as required by law (e.g. superannuation contribution information);
  • To the distributor of the Funds;
  • To the Funds' auditors, lawyers, custodian, investment providers and insurers;
  • To your accountant, financial consultant, or other person nominated by you where your authority has been received;
  • To external contractors engaged by the Trustee, provided they adopt and adhere to appropriate privacy principles; and
  • If you, or anyone else on your behalf, makes a claim for a benefit, the insurer may give or receive information about you to or from medical practitioners, legal advisers, health service providers, past or present employers, other consultants, experts and companies in order to assess and process the claim.

The Trustee will only collect, maintain and use personal information if it is necessary to adequately provide to you the services which you have requested. These services include receiving contributions, processing transactions and paying benefits.

The Trustee will only use personal information for direct marketing under the following conditions:

  • The information is not sensitive;
  • It is impractical to seek your consent beforehand;
  • No charge will be made for a request from you not to receive direct marketing communications;
  • You have not made a request not to receive direct marketing communications;
  • The Trustee gives you the express opportunity not to receive direct marketing communications.

NPP3 - Data quality

An organisation must take reasonable steps to ensure the personal information it collects, uses or discloses is accurate, complete and up to date.

Individuals about whom the Trustee holds information are made aware of that information through regular communications.

The majority of all data held about you is communicated to you on your regular member benefits statements. Standard wording on the back of all statements invites you to contact the Trustee regarding any inaccuracies.

Where the Trustee is made aware of incorrect information about you, the information will be corrected after appropriate checks for accuracy.

NPP4 – Data Security

An organisation must take reasonable steps to:
  • ensure the personal information it holds is kept secure and protected from misuse, and unauthorised access, modification or disclosure; and
  • destroy, or permanently de-identify, personal information which is no longer required.

Electronic data is stored on the Trustee's file server which is password protected and installed in a secure room. In some cases, data is stored on third party computer systems. In such cases, the Trustee obtains appropriate assurances from the owners of those systems regarding data security and confidentiality.

In the event that you cease to be a member of the Fund, any personal information that the Trustee holds will be maintained for a period of at least 7 years in order to comply with legislative requirements. When your personal information is no longer needed, the Trustee will ensure that it is securely destroyed or de-identified.

NPP5 - Openness

An organisation must have a policy outlining its information handling practices and make this available upon request.

The Trustee's policy is that:

  • All member information is treated as confidential;
  • All member information (copies of applications, correspondence, notes of telephone calls, etc) which are filed in paper files are stored in a filing room or office which is locked nightly;
  • All member information which is stored electronically is done so in a secure manner; and
  • Member information is not released except in circumstances as set out in this policy.

NPP6 - Access and correction

An organisation must, subject to certain restrictions, provide individuals with access to personal information held about them upon request, and take reasonable steps to correct that information if it is shown that it is inaccurate, incomplete, or out of date.

The Trustee's policy is that individuals about whom it holds information are entitled to access any personal information held. The Privacy Act specifies certain exemptions. Information that is inaccurate, incomplete or out of date will be corrected where appropriate. In the event that members become aware, or believe, that any personal information that the Trustee holds about them is inaccurate, incomplete or out of date, they may contact the Trustee to seek correction.

NPP7 - Identifiers

An organisation must not use, or disclose, identifiers that government agencies have assigned to individuals, such as tax file numbers, except in limited circumstances.

The only personal government identifiers held by the Trustee are Tax File Numbers (TFNs). Access to TFNs is limited to specific staff members who require access in order to undertake their role. The Trustee will only use your TFN as a personal identifier where it is permitted to do so.

TFNs will not be released externally by the Trustee except where authorised by the individual in writing or required by law.

NPP8 - Anonymity

An organisation must wherever it is lawful and practicable, give individuals the option of not identifying themselves.

It is not possible for the Trustee to do business with individuals who are unwilling to identify themselves.

NPP9 - Transborder dataflow

An organisation must only transfer personal information to a recipient in a foreign country, if:
  • the recipient is subject to a law, binding scheme or contract substantially similar to the NPPs;
  • the individual has consented to the transfer;
  • the transfer is necessary for the performance of a contract between the individual and the organisation;
  • the transfer is necessary for the conclusion, or performance, of a contract in the interest of the individual;
  • the transfer is for the benefit of the individual, whose consent is impracticable to obtain, but likely to be given; or
  • the organisation has taken reasonable steps to ensure that the information transferred will not be used inconsistently with the NPPs.

The Trustee is very rarely involved in international dataflow where a member transfers funds to/from an overseas institution. In such cases, the Trustee will ensure the transaction complies with NPP 2 (i.e. you have consented to the transfer).

There are no other instances where the Trustee transfers personal information internationally.

NPP10 - Sensitive information

An organisation must not collect information, or an opinion, about an individual's:
  • racial or ethnic origin;
  • political opinions;
  • religious, or philosophical beliefs;
  • political, or religious affiliations;
  • membership of a trade union, or professional association;
  • sexual preferences, or practices;
  • criminal record;
  • health;
unless:
  • the individual has consented;
  • the collection is required by law, or for other public interest purposes (such as law enforcement and public health and safety); or other specified circumstances apply.

The Trustee will not collect sensitive information, or an opinion, about you unless

  • You have consented;
  • The collection is required by law, or for other public interest purposes.

Where sensitive information is collected, the Trustee will store this information securely to guard against improper use or disclosure.

Privacy Complaints

Complaints and Complaints Resolution

The Trustee has a complaints handling process in place with both internal and external resolution components. These procedures are designed to meet the Australian Standard (AS ISO 10002) guidelines on complaint handling. When a complaint is received, the complainants are first taken through the internal resolution procedures, and only if then it is not resolved, is the external resolution process required.

If you have a complaint about your privacy please contact the Trustee's Chief Financial Officer on:

  • Phone:
    1800 640 055
  • Write to:
    PO Box 1282, Albury NSW 2640

We will endeavour to resolve privacy complaints within 30 days of receipt.

External Complaints Resolution Procedures

When a privacy complaint is not resolved within 30 days or to your satisfaction, you can then refer your complaint to the Office of the Australian Information Commissioner (OAIC).

The OAIC can be contacted on 1300 363 992 or at www.oaic.gov.au.