Synergis Fund
Setting the standard for disability housing in Australia.

Privacy

 
 

Privacy policy

Updated: 30 October 2019

This Privacy Policy (policy) applies to information collected by Social Infrastructure Investment Partners Pty Ltd ACN 636 457 479 and its related bodies corporate (SIIP or we) in connection with its Australian operations. It outlines how we manage your personal information and safeguard your privacy. 

1. What personal information is collected?

SIIP collects personal information that is reasonably necessary for us to provide you with financial products and services and to administer them. The kind of personal information we collect and hold will depend upon the type of products and services that you request from us and may include:

  • information you give us when you request a product or service from us. This information may include your name, date of birth, address, contact details and relevant identification documents;

  • communications between us and your financial, legal or other adviser, or your broker or agent;

  • communications between us and associations that you are a member of and with which we have an affiliation;

  • transactional information about the use of a product if you have or had a product with us;

  • financial information about you such as your financial position and information obtained from credit checks if you have authorised us to carry out those checks;

  • in some cases sensitive information obtained with your consent (e.g. health information) or otherwise where required or permitted by law (e.g. in relation to anti-money laundering);

  • if you are a financial adviser or other authorised representative of a customer, your name, contact details and any other information you provide when communicating with us in relation to our products and services, or in connection with a mutual customer; and

  • information regarding your website interaction with us (i.e. the sections or features of our website that you have visited or used). See the 'Use of our website' section of this policy for further information. 

2. How is personal information collected?

SIIP usually collects your personal information in a number of ways including:

  • directly from you (including via your financial, legal, or other adviser, or your broker or agent), such as when you provide the information by phone, email or in an application form, or when you participate in a survey, promotion or competition;

  • from other SIIP group companies where permitted by law;

  • from third parties such as your financial adviser, lawyer or other agents or credit reporting agencies, credit providers, or identity verification service providers, if you authorise us to do so; and

  • from publicly or commercially available sources for the purpose of complying with customer due diligence obligations under relevant legislation (e.g. anti-money laundering laws).

3. What if you do not provide certain information?

If you provide us with an incomplete application, we may not be able to provide you with the product or service until the application is complete.

If you do not provide us with all relevant identity verification documents, or adequately satisfy electronic identity verification requirements, we may not be able to provide you, or continue to provide you with the product or service.

If you choose not to disclose your Tax File Number (TFN), TFN exemption or Australian Business Number (ABN), we may have to deduct tax at the highest marginal rate (plus the Medicare levy) from distributions or income payments made to you. If you are a foreign tax resident and you have not provided us with information we have requested about your tax residency (i.e. your Tax Identification Number or similar number issued by the relevant foreign tax authority), we may not be able to process your request, or we may be required to notify the Australian Taxation Office (ATO).

If you choose not to disclose your account details or correctly answer verification questions, we may not be able to process transactions requested.

4. How do we use and disclose your personal information?

SIIP may collect, use and disclose your personal information for the primary purpose of providing the products and/or services requested, as well as for related purposes such as:

  • to verify your identity or transactions which you may enter into with us (including the identities of third parties connected with your product/service application, such as beneficiaries and beneficial owners, where applicable);

  • to process your applications for our products and services;

  • to administer and manage the provision of our products and services;

  • to respond to queries, complaints or to provide you with our general customer services;

  • to provide your nominated financial adviser or other agent with details of your investment;

  • to confirm your membership of an association with which we have an affiliation;

  • to assess credit which you seek from SIIP loan programmes and to administer any credit a SIIP loan programme provides, including providing your nominated mortgage broker with details of your loan;

  • to provide you with offers of other SIIP products or services and to improve and personalise our products and services;

  • to provide you with offers from organisations with whom we have an alliance;

  • to comply with laws and regulatory requirements, including anti-money laundering, financial services and taxation laws, or complying with any request made by a governmental authority in connection with legal proceedings or the prevention or detection of fraud and crime;

  • to comply with SIIP's risk management policies and procedures;

  • to conduct product and market research;

  • to train our staff;

  • if applying for employment with SIIP, to complete appropriate background checks; or

  • if attending our offices in person, to assist SIIP in providing a safe and secure environment for employees and visitors.

We may disclose your personal information to:

  • your financial, legal or other adviser, or your broker or agent;

  • professional service firms that provide services to us, such as, legal, and audit, or data/information services;

  • electronic identity verification service providers, in order for identity information (about you or related persons connected with your investment) to be verified against relevant government and other databases, for the purpose of complying with anti-money laundering laws;

  • our related companies; or

  • organisations with which we have an association and you are a member, and otherwise in accordance with this policy and the APPs.

5. Overseas transfer of personal information

SIIP does not disclose personal information to persons or entities in foreign countries. 

However, in some cases, personal information may be used (or accessed) by third party service providers located overseas to perform administrative functions in relation to your products. In such cases, SIIP will review these arrangements to ensure appropriate security protections are in place to protect your personal information.

In some cases, SIIP may utilise 'Cloud' storage solutions for data storage purposes, and the relevant servers may be located overseas. Please see the 'Storage and security of information' section of this policy for further details.

6. Use of service providers

We may contract out some of our administrative and support functions such as mailing, settlement services, product administration services, document and data storage, background checking or identity verification services to external service providers from time to time. Only information necessary for the service provider to carry out their function will be provided and will be subject to confidentiality clauses in the relevant services agreement.

7. Keeping us up-to-date

Personal information such as your contact details may change from time-to-time and we ask that you keep us informed of any changes by notifying us. Where you have previously provided information about another person related to your investment (such as a beneficial owner or beneficiary) and the information is no longer current, you must provide up-to-date information.

Changes to some details, such as a change of name, may require additional documentation to verify the change. 

Please see the 'Contacting us' section of this policy if you would like to request an update to the personal information we hold about you or your nominated beneficiary.

8. Storage and security of information

SIIP stores personal information in a combination of computer storage facilities, paper-based files and other records. These are held on our premises and systems as well as offsite using trusted third parties. Some personal information may be held by data service providers located overseas (such as 'Cloud' service providers for data storage and management purposes) and SIIP maintains effective control of the information under contractual arrangements. We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure.

Where personal information is no longer required to be retained, we will take such steps as are reasonable in the circumstances to de-identify the information or put it beyond use.

9. Openness

This policy sets out SIIP’s policies on the management of personal information and is made freely available on our website.

10. Access and correction

Generally, SIIP will provide you with access to your personal information that we hold, unless a particular exception applies, such as where:

  • it would be unlawful to provide the information;

  • providing access would be likely to prejudice an investigation of possible unlawful activity;

  • the information is relevant to legal proceedings and would not be accessible in the normal discovery process;

  • giving access would have an unreasonable impact on the privacy of other individuals;

  • it would pose a serious and imminent threat to the life or health of any individual; or

  • the request is frivolous or vexatious.

If a request for access would divulge a commercially sensitive decision-making process, then SIIP may provide an explanation rather than direct access to the information.

If we become aware that the personal information we hold about you is inaccurate, incomplete, misleading or irrelevant, then we will take reasonable steps to amend it. If we receive a request from you to correct your information, then we will seek to correct it within 30 days. If you and SIIP disagree about the accuracy, completeness or currency of our records, then you have the right to request that we note your disagreement on those records.

Please see the 'Contacting us' section of this policy if you would like to request an update or seek access to the personal information we hold about you.

11. Identifiers

SIIP does not use any government-issued identifiers (such as TFNs, Medicare numbers and Drivers Licence numbers) for use as its own identifier for individuals. Instead, SIIP issues numbers such as investor numbers and account numbers are used to identify individuals and the SIIP products and services they obtain.

12. Anonymity and pseudonymity

Given legal requirements relating to customer identification, in most situations SIIP is unable to allow you to transact with it on the basis of anonymity (including the use of pseudonym). Access to the SIIP public website and some other interactions with SIIP may be done anonymously, or in the case of general enquiries, using a pseudonym. However, we may not be able to respond to your queries unless you provide us with certain information.

13. Direct marketing

SIIP will not use your personal information for direct marketing purposes unless:

  • we have obtained your consent or you would reasonably expect us to use your personal information for direct marketing purposes; and

  • we have provided you with a simple means to "opt-out" from receiving direct marketing; and

  • we have not received such a request from you.

SIIP will not use any sensitive information collected from you for direct marketing purposes. To opt-out of receiving direct marketing, please contact us (see 'Contacting us' section of this policy). 

14. Use of our website

We will collect some information from you when you visit the SIIP website. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. Some of this information will not be personal information because it will not reveal your identity.

The only personal information which we collect about you when you use the website is what you tell us about yourself; for example, by completing an online form such as an application form, within a tool or sending us an email. 

Website analytics

SIIP uses Google Analytics and third-party web analytics providers to collect information on how people use our website and to help us know what our customers find interesting and useful on our website. Our web analytics providers use "cookies" and in some cases "clear gifs/web beacons" to collect information. For more information on our web analytics providers, please see Google Analytics.

Cookies

Cookies are pieces of information that are transferred to your computer when you visit a website so that sites can record usage and, in some cases, provide you with tailored content or targeted advertising. Most web browsers are set to accept cookies. You can choose to disallow cookies by changing settings on your web browser. However, if you reject all cookies you may not be able to use some areas of our websites.

15. Employment opportunities at SIIP

If you are seeking employment or contracting opportunities with SIIP, we will collect personal information from you and, where applicable, from any referees you have provided to us during the recruitment process. We may also collect sensitive information about you as part of our background checking process (with your consent). This information may be disclosed to (and obtained from) third party agencies that we engage to conduct screening checks on our behalf. Personal information gathered during the recruitment process will only be used to assess your suitability for the relevant role, and if you are not the preferred candidate, your information may be retained to assess your suitability for roles offered in the future.

16. Contacting us

If you would like more information about how we manage your personal information, please contact us on +61 2 8004 6700 or +61 2 8650 4500. Alternatively, you can write to us at the following address:

The Privacy Officer
Social Infrastructure Investment Partners Pty Ltd
Level 7, 1 Chifley Square
Sydney NSW 2000

Or send an email to: info@synergisfund.com.au

17. Complaints about your privacy

If you wish to raise any concerns about any breach or potential breach of your privacy, please contact our Privacy Officer and we will make every effort to resolve your complaint internally. If you wish to raise a concern, you should be aware of the following:

  • your complaint should be made in writing to the Privacy Officer (via post or email);

  • we will attempt to respond within 30 days from receipt of your request;

  • if you feel your concerns have not been resolved, you may take them to an external dispute resolution service (such as the Australian Financial Complaints Authority (AFCA));

  • AFCA provides fair and independent financial services complaint resolution that is free to consumers. There are some time limits for lodging certain complaints, please consult the AFCA website to find out if or when the time limit relevant to your circumstances expires; and

  • the complaint may be taken to the Office of the Australian Information Commissioner (OAIC).

For more information on how you may lodge a complaint with the OAIC, please contact the OAIC hotline service on 1300 363 992 or email enquiries@oaic.gov.au.

18. Changes to our Privacy Policy

SIIP may make changes to this policy from time to time for any reason and we will update the website in a timely manner.