Privacy Policy

Preamble & Background

The purpose of this policy is to articulate clearly the type of personal information collected by WAM, how the information is used and protected and to provide guidance on how such information may be accessed and corrected.

Privacy Principles

1 Collection

1.1 WAM must not collect personal information unless the information is necessary for one or more of its functions or activities.

1.2 WAM must collect personal information only by lawful and fair means and not in an unreasonably intrusive way.

1.3 WAM must take reasonable steps to ensure that the individual is aware of:

a) the identity of WAM and how to contact it; and

b) the fact that he or she is able to gain access to the information; and

c) the purpose for which the information is collected; and

d) the type of organisation to which WAM might find it necessary to disclose information; and

e) any law that requires that particular information to be collected; and

f) the main consequences (if any) for the individual if all or part of the information is not provided.

1.4 If it is reasonable and practicable to do so, WAM must collect personal information about an individual only from that individual.

1.5 If WAM collects personal information about an individual from someone else, it must take reasonable steps to ensure that the individual is or has been made aware of the matters except to the extent that making the individual aware of the matters would pose a serious threat to the life or health of any individual.

2 Use and Disclosure

2.1 WAM must not use or disclose personal information about an individual for a purpose (the secondary purpose) other than the primary purpose of collection unless:

a) Both of the following apply:

(i) The secondary purpose is related to the primary purpose of collection and, if the personal information is sensitive information, directly related to the primary purpose of collection;

(ii) The individual would reasonably expect WAM to use or disclose the information for the secondary purpose; or

b) The individual has consented to the use or disclosure; or

c) WAM reasonably believes that the use or disclosure is necessary to lessen or prevent:

(i) A serious and imminent threat to an individual’s life, health or safety; or

(ii) A serious threat to public health or public safety; or

d) WAM has reason to suspect that unlawful activity has been, is being or may be engaged in, and uses or discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities; or

e) The use of disclosure is required or authorised by or under law.

3 Data Quality

WAM must take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up-to-date.

4 Data Security

4.1 WAM must take reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure.

4.2 WAM must take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.

5 Openness

5.1 WAM must set out a document with clearly expressed policies on its management of personal information. WAM must make the document available to anyone who asks for it.

5.2 On the request by a person, WAM must take reasonable steps to let the person know, generally, what sort of personal information it holds, for what purpose, and how it collects, holds, uses and discloses that information.

6 Access and Correction

6.1 If WAM holds personal information about an individual, it must provide the individual with access to the information on request by the individual, except to the extent that:

a) In the case of personal information other than health information, providing access would pose a serious imminent threat to the life or health of an individual; or

b) The provision of access would have an unreasonable impact upon the privacy of other individuals.

7 Identifiers

7.1 WAM does not use identification or reference numbers to identify individuals nor does it disclose information to other organisations regarding an individual without their consent.

8 Anonymity

8.1 Whenever it is lawful and practicable, individuals must have the option of not identifying themselves when entering transactions with WAM.

8.2 Where an individual chooses to provide information to WAM anonymously WAM Ltd respects the person’s anonymity but may not be in a position to act on such information.

9 Trans – Border Data Flows

9.1 WAM will not transfer or send any personal information outside of Australia.

10 Sensitive Information

10.1 Where WAM collects sensitive information, it is done with the consent of the individual.