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Privacy Policy and Privacy Collection Statement

Privacy Policy

The Trustee, Retail Employees Superannuation Pty Ltd, ABN 39 001 987 739, AFSL 240003, as Trustee of the Retail Employees Superannuation Trust (REST) Fund ABN 62 653 671 394 (we, us, our) recognise the importance of protecting privacy and the rights of individuals in relation to their personal information.  This document is our Privacy Policy and it sets out how we will handle your personal information.

What is personal information?

Under the Privacy Act 1988 (Cth) (Privacy Act), personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.  Personal information includes information such as your name, age or contact details.

What personal information do we collect and hold?

We collect and hold a variety of personal information, including the following:
  • your name, gender, date of birth, residency information;
  • contact details, such as your address, email address and telephone numbers;
  • financial details, such as tax file number and bank account details;
  • medical information, including details pertaining to your medical practitioners and their consultation notes;
  • information to verify your identity, such as your passport, driver’s licence information or birth certificate;
  • employment details, such as: occupation, salary, hours of work, employee identification number, employment dates or records of your or your employer’s interactions with us and our representatives; and
  • superannuation details, such as your investment option choices, membership commencement date and other superannuation funds you may have.
We may also collect information about your health or your membership of trade associations or trade unions which are defined to be sensitive information in the Privacy Act.  We will only collect sensitive information with your consent and we will only use sensitive information for providing you with superannuation, insurance, managing claims and for operating your account unless you specifically authorise us to use your sensitive information for another purpose.  We will always seek your permission before using or disclosing sensitive information for any other purpose.

Our websites contain links to other third party sites that may have personal information practices different to our practices. You should consult the other sites' privacy policies as we have no control over information that is submitted to, or collected by, these third parties.

What personal information are we required to collect?

We are required to collect your name, address, date of birth and other verification information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and we are required and authorised to collect your tax file number in various circumstances covered by the Superannuation Industry (Supervision) Act 1993 (Cth).

How do we collect and hold your personal information?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so.  When collecting personal information from you, we may collect it in ways including:
  • through your access and use of our websites or an online portal;
  • during interactions between us and you and you and our representatives, including discussions through our call centres; and
  • when you complete an application or other form, including surveys or promotions.
 
We may also collect personal information from third parties including:
  • your employers;
  • doctors or other medical advisers;
  • the Australian Taxation Office;
  • other superannuation and insurance entities;
  • clearing houses, gateway providers or similar entities;
  • address-matching service providers to help us keep our records accurate and to locate other accounts in your name;
  • service providers who conduct internet based surveys or run call centres; and
  • your spouse or friends.
 
Please see below for information about how we keep your personal information secure.
 

What happens if we are unable to collect your personal information?

If we cannot collect your personal information one or more of the following may occur:
  • we may be unable to provide you with superannuation, insurance or other products, services, benefits or options (REST Services) (or information about them) that you want or require;
  • we may be unable to provide you with information about products or services that you may want; or
  • we may be unable to tailor the content of our websites to your preferences or to give you more relevant content.

How do we use your personal information?

In addition to the purposes mentioned above, we collect, hold, use and disclose your personal information for the following purposes:
  • we will use your name, contact details, date of birth, tax file number and similar information to establish and operate your membership account, to process contributions to your account, to correspond with you regarding your account, to provide you with REST Services, to help locate your lost super and to consolidate your super;
  • certain personal information may be used to respond to your enquiries, including your requests for information;
  • certain personal information may be used for the purpose of surveys, research and analytics (by us or our third party service providers) and testing potential REST Services; and
  • certain personal information may be used to better understand and meet your superannuation needs over your lifetime.
From time to time we may also use information on a de-identified basis for planning, research and analysis so that we can operate effectively and efficiently, improve our REST Services and so that we can participate in superannuation and financial services related policy debate and development, either directly or through associations, forums or working groups that we are involved with.

Direct marketing

We, or our third party service providers, may engage in or send you direct marketing communications and information that we or our third party service providers consider may be of interest to you, whether you are a current, prospective or former member.  You consent to us and our third party service providers doing so.  They may be undertaken in various forms, including mail, email, telephone, SMS, MMS (Multimedia messaging service) and fax.  If you indicate a preference for a method of communication, we and our third party service providers will try to use that method wherever practical.  In addition, at any time you may opt-out of receiving direct marketing communications and information from us or our third party service providers by contacting us (see the details below in ‘How to contact us’) or by using any opt-out facilities provided in the communications and information.  We or our third party service provider will then ensure that your name is removed from the relevant contact list.

To whom may we disclose your personal information?

We may disclose your personal information to  third parties, including:
  • Mailing and printing companies – organisations contracted to distribute REST materials, including  direct marketing materials in various forms;
  • Archiving companies – organisations contracted to ensure that all documents are stored in a secure environment;
  • Auditors, actuaries and legal advisers – organisations that ensure we comply with legislation and contractual obligations;
  • Employers – who make contributions for you to REST;
  • Insurance related service providers – organisations that provide insurance cover for our members and organisations that provide administration services related to such insurance;
  • Medical practitioners and other service providers – that assist us with underwriting and the assessment of claims;
  • Service providers – organisations contracted to provide consulting services, contribution arrears collection services, address matching services and organisations which cross match personal details with information from superannuation funds and other sources to help keep our members’ contact details accurate and to locate any other superannuation accounts in a member’s name;
  • Marketing and communications agencies and research and analytics providers – organisations which provide survey, research, analytics and marketing and communications services relating to REST Services and our industry;
  • Administrators and advisers – organisations contracted to undertake administration, management and advisory services and other organisations we interact with within the superannuation industry and system (eg. clearing houses, gateway providers or similar entities);
  • IT services – organisations maintaining our information technology systems and providing information technology services; and
  • Our preferred financial services organisations and advice companies that are contracted to provide or assist members with their general and personal advice needs.
 
We will also disclose personal information in circumstances where REST is required by law to do so.  Those circumstances include:
  • The Family Law Act 1975 (Cth) enables certain persons to request information about the member's interest in a superannuation fund.  We may, if requested, be required to provide information about the member's interest in a superannuation fund to their spouse or a person who intends to enter into an agreement with the member about splitting their superannuation interests in the event of separation.  The request must be in a form prescribed by law.  The law prevents us from telling the member about any such request for information and from providing the member's address to the person requesting the information.
  • Under the Superannuation Industry (Supervision) Act 1993 (Cth), we may be required to disclose your tax file number and other identification information to the Commissioner of Taxation or, if you are transferring to another fund, to the trustee of that fund.
  • Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and its Rules, we may be required to provide personal information to AUSTRAC.
  • Under the Superannuation (Unclaimed Money and Lost Members) Act 1999 (Cth), we may provide information to the Commissioner of Taxation about unclaimed money and superannuation, lost members and lost member accounts.
 
If you wish to authorise another party to receive information or to undertake transactions on your behalf, you must notify us in writing using the contact details provided below in the ‘How to contact us’ section.
 
Unless authorised or required by law or for a purpose set out in this Privacy Policy, we do not give personal information about our current, prospective or former members to any third parties.

Do we disclose your personal information outside Australia?

We may disclose personal information to entities located outside of Australia (eg. our third party service providers) or to entities who use technology located outside of Australia, for some of the purposes listed above, including:
 
  • our data hosting and other IT service providers located in, or using technology located in, the United States of America; and
  • other third party service providers located in, or using technology located in, India, the Philippines, the United States of America and the United Kingdom.
 
In turn, those entities may disclose personal information to other organisations located outside of Australia or to other organisations who use technology located outside of Australia.
 
We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
 

How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by logging in to MemberAccess or by calling us on 1300 300 778.  Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it.  We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you.  We will not charge you for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold.  For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality.  If that happens, we will give you written reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it.  We will consider if the information requires amendment.  If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

How do we keep your personal information secure?

We take reasonable steps to ensure that your personal information is protected from misuse, interference and loss and from unauthorised access, modification and disclosure.  We will regularly audit access to our systems to ensure your personal information is securely stored.  We will also take reasonable steps to ensure that third party service providers which help us to provide you with REST Services (for example, insurance companies) have privacy arrangements which are consistent with the Privacy Act.

We only keep your personal information for as long as the information is required to provide you with REST Services or deal with any enquiries you may have.  We generally keep a member’s personal information for a period of at least seven years after they cease to be a member, and during this time we may continue to use or disclose personal information as set out in this Privacy Policy. 

As our websites are linked to the internet and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you send to us online.  You need to assess the potential risks when deciding whether to use our online services.  If you do not wish to transmit information via our websites, there are other ways in which you can provide us with your information, such as by mail, telephone or on-site visit.

Cookies

When you access our websites, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer.  This enables us to recognise your computer and greet you each time you visit our websites without bothering you with a request to register.  It also enables us to keep track of REST Services you view and, with some of our websites, to improve your browsing experience by tailoring the content you see by default on those websites.  We also use cookies to measure traffic patterns and to determine which areas of our websites have been visited.  Our cookies do not collect personal information although if you are a REST member, cookies sent to your computer from some of our websites may store your encrypted REST member number. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.

When you browse our websites, our service provider logs the following information for statistical purposes:
  • your server address;
  • your top level domain name (for example .com, .gov, .au, etc.);
  • the date and time of your website visit;
  • the pages you have looked at;
  • the documents you have downloaded;
  • the previous site you have visited; and
  • the type of browser you are using.
 
We will not try to identify you or your browsing activities. However, we may do so in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the service provider's logs, or to view your browsing activities on some of our websites that send cookies storing your encrypted REST member number to your computer.

We will only record your email address if you send us a message, if you choose to provide it to us, or if a third party provides it to us indicating that you may be interested in REST Services.  We will not add it to our contact list, nor continue to include it in a contact list, if you ask us or our third party service providers not to contact you.

Making a complaint

For any complaints about a possible breach of privacy, please contact our Privacy Officer in one of the ways set out in the ‘How to contact us’ section below. 

REST requests that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint.  Our Privacy Officer deals with privacy complaints.  We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you request as an outcome.  We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After REST has completed its enquiries, we will contact you to advise the outcome and invite a response to that outcome.  If we receive a response from you, we will assess it and advise if REST has changed its view.

If you are unsatisfied with the resolution of any complaints made to us, you can refer the matter to the Australian Information Commissioner.  The contact details for the Office of the Australian Information Commissioner are as follows:

Office of the Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au

How to contact us

For further information on how we handle personal information, or to complain about a possible breach of privacy, you can contact our Privacy Officer in one of the following ways:
 
By phone on 1300 300 778
 
By e-mail at contact@rest.com.au
 
Write to:
Privacy Officer
REST Industry Super
Locked Bag 4085
Parramatta NSW 2124
 
Visit us at level 7, 50 Carrington Street, Sydney, NSW, 2000

Changes to our Privacy Policy

We endeavour to continually improve our standard of service, so from time to time we may update this Privacy Policy.  Any personal information we hold will be governed by the most current version of our Privacy Policy.

This Privacy Policy was last updated in May 2015.


REST Privacy Collection Statement

REST may collect personal information from you.  REST may also collect your personal information from your employers, medical advisers, the Australian Taxation Office, other superannuation and insurance entities, clearing houses, gateway providers, address-matching service providers, service providers who conduct internet based surveys or run call centres and your spouse or friends.

We are required to collect your name, address, date of birth and other verification information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and we are required and authorised to collect your Tax File Number in various circumstances covered by the Superannuation Industry (Supervision) Act 1993 (Cth).

We collect, hold, use and disclose your personal information to:
  • establish and operate your membership account
  • process contributions to your account
  • correspond with you regarding your account
  • provide you with superannuation, insurance or other products, services, benefits or options (REST Services) (or information about them)
  • help locate your lost super and to consolidate your super
  • respond to your enquiries and requests for information
  • conduct surveys, research and analytics
  • test potential REST Services
  • understand and meet your superannuation needs over your lifetime.
If we cannot collect your personal information we may be unable to provide you with REST Services (or information about them) or we may be unable to tailor the content of our websites to your preferences or to give you more relevant content.

We may disclose your personal information to third parties, including:
  • mailing and printing companies
  • archiving companies
  • auditors, actuaries and legal advisers
  • employers
  • insurers
  • medical practitioners
  • service providers, including contribution arrears collection services and address matching services
  • marketing and communications agencies
  • research and analytics providers
  • administrators and advisers
  • IT services
  • our preferred financial services organisations and advice companies.
We may disclose personal information to entities located overseas, including India, the Philippines, the United States of America and the United Kingdom.

Our Privacy Policy contains information about how you may access and correct the personal information that we hold about you and how to lodge a complaint relating to our treatment of your personal information, and how we will deal with the complaint.  Our Privacy Policy is available at www.rest.com.au or by contacting us.

How to contact us

You may contact us by phone on 1300 300 778, by email at contact@rest.com.au, or by writing to Privacy Officer, REST Industry Super, Locked Bag 4085, Parramatta NSW 2124, or you can visit us at level 7, 50 Carrington Street, Sydney NSW 2000.

Retail Employees Superannuation Pty Ltd, ABN 39 001 987 739, AFSL 240003, as trustee of the Retail Employees Superannuation Trust (REST) Fund ABN 62 653 671 394

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Page last updated on: 27 May 2015

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