Cooper Investors Pty Limited (“CI”) generally collects personal information in its capacity as a fund manager. Such information may include clients’ names, addresses, contact details, date of birth, country of residence, investment details, tax file numbers, bank account details and other accounting, audit and financial services related information. The primary purpose for our collection, holding and use of that personal information is generally to provide, assist in and expedite the management of client investment portfolios and provide our fund management services including (but not limited to) making distribution payments and CI corporate communications such as issuing our clients’ performance reports. Depending on our dealings or interactions with you, we may collect personal information for other purposes from time to time.
Collection, maintenance and disclosure of certain personal information is governed by legislation including (but not limited to) the Privacy Act 1988 (Cth), the Australian Privacy Principles under the Privacy Act 1988 (Cth), the Corporations Act 2001, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007, Income Tax Assessment Act 1997 / Tax administration Act 1953, and the Superannuation Industry (supervision) Act 1993.
CI may collect personal information in various ways such as via telephone, email, hardcopy and/or online forms. In most situations we collect personal information directly from you. We may however also collect information via third parties such as our custodian. We hold personal information by storing it in our systems, on our servers, and the servers of any third parties we may engage to store data for us. We may also hold physical records containing personal information at our premises or at any offsite records storage facility maintained by us.
If CI receives personal information that was not requested (i.e. unsolicited personal information), CI will, unless otherwise required or permitted by law, delete or destroy the information as soon as possible after receiving it.
You do not have to provide us with your personal information, but if you do not provide us with the required personal information, we may not be able to provide our services or assistance to you.
Disclosure of personal information by CI
Clients’ personal information may be disclosed to other entities for the purpose of CI providing our funds management or other similar services or undertaking the other relevant purpose for which the information was collected. Personal information may also be disclosed to other entities for any secondary purposes that CI is permitted to use or disclose your information for (which will generally be secondary purposes within your reasonable expectations or that you have consented to). Such entities include the trustees who hold the investments which we manage, third party service providers such as our back office support providers and the National Australia Bank Limited, and certain government and regulatory bodies. We may disclose personal information to other types of organisations for the above purposes such as CI’s accountants, financiers, auditors, legal advisers, and other professionals. CI may also disclose personal information to entities for which you have given your consent.
To seek to ensure the integrity and safety of our clients’ personal information, CI will only disclose any information if our internal procedures are satisfied. CI takes reasonable steps to protect any personal information that we hold from misuse, interference and loss and from unauthorised access, alteration and disclosure. This includes the following security protocols that have been implemented:
- Security procedures for access to our business premises;
- IT security protocols including security around access of data, firewalls, password protection, and strict rules around VPN access;
- Mandatory confidentiality guidelines for all staff (as outlined in employment contracts).
However, data protections measures are never completely secure and, despite the measures we’ve put in place, CI cannot guarantee the complete security of your personal information.
Updating your personal information
CI takes reasonable steps to ensure the personal information we hold about you is accurate, up-to-date, and complete. You have the right to access, correct and update the personal information that we hold about you by contacting us using any of the details set out below. Please contact the Compliance Manager at the address set out below as soon as possible if there are any changes to your personal information or if you believe the personal information we hold about you is not accurate, complete or up-to-date for CI to update your file accordingly.
Cooper Investors Pty Limited
Level 1, 60 Collins St
Melbourne VIC 3000
Phone: (03) 9660 2600
Fax: (03) 9660 2699