MPG Funds Management Limited and its associated entities, collectively trading as MPG, are committed to respecting your right to privacy and protecting your personal information. We are bound by the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles set out in the Act. We will ensure that all staff and subcontractors are aware of and understand MPG’s obligations as well as their own obligations under the Act.
1. Collection of Personal Information
Whenever you deal with MPG we will collect personal information in order to provide services to you. We do not collect personal information unless it is reasonably necessary for, or directly related to, one or more of the services we provide or functions we carry out.
The types of personal information we generally collect includes but is not limited to:
- Date of birth
- Residential address
- Postal address.
- Email address.
- Home telephone number.
- Work telephone number.
- Mobile telephone number.
- Your occupation and business address.
- Financial information including details of your employer, income, name of bank or financial institution.
- Details of properties owned by you.
- Company turnover
- Company profit and loss statements
- Other information as deemed necessary
We will, if it is reasonable or practicable to do so, collect your personal information directly from you. This may happen when you fill out a form or when you give us personal information in person, or via telephone, email, correspondence or our website.
Sometimes we will collect personal information from a third party or a publicly available source. For example, we may need to collect personal information from a credit reporting agency, your legal adviser or accountant.
Personal information collected by MPG will ordinarily be used for the following purposes:
- Assisting you to invest in a fund.
- Recording or accessing information at the Titles Registry Office or other governmental agency.
- Client and business relationship management.
- Marketing of products and services.
In order to achieve this, we may disclose your personal information to the persons/organisations described below:
- Our legal advisor(s) and the legal advisor(s) representing the other party(s) involved in your transaction.
- Your financial institution and/or financial advisor.
- Insurance providers and brokers;
- Utility providers and utility connection service providers;
- Organisations involved in maintaining, reviewing and developing our business and computer systems.
- Organisations involved in the payments systems including financial institutions,
- Merchants and payment organisations.
- The Titles Registry Office or other government agency.
We will only use and disclose personal information for the primary purpose for which it was initially collected, or for purposes which are directly related to one of our functions or activities.
We will not disclose your personal information to government agencies, private sector organisations or any third parties unless one of the following applies:
- You have consented.
- You would reasonably expect, or you have been told, that information of that kind is usually passed to those individuals, bodies or agencies.
- It is otherwise required or authorised by law.
- It is reasonably necessary for enforcement related activities conducted by, or on behalf of, an enforcement body (e.g. police, ASIC, Austrac, ATO).
Personal information provided to MPG may be shared with its related companies. We will take all reasonable and practical measures to keep such information strictly confidential.
Like many other businesses in Australia, MPG may rely on third party suppliers or contractors to provide specialised services such as web hosting, cloud computing technology and data storage services. If personal information is provided to these suppliers and contractors in order to enable them to perform the agreed tasks, we will make every effort to ensure that the supplier or contractor handles the personal information in accordance with the Act and the Australian Privacy Principles. We will also require all suppliers and contractors to provide privacy undertakings and enter into confidentiality agreements.
There may be limited circumstances in which it is necessary for us to collect a government related identifier such as your tax file number. We will not use or disclose your government related identifiers unless we are required or authorised to do so by law or by a court or tribunal order, or in order to fulfil our obligations to a State or Territory authority.
MPG may use your personal information to let you know about products and services that you may be interested in. MPG will not disclose your personal information to third parties for marketing purposes. You can contact us at any time if you no longer wish us to market our products and services to you (see the Contacting Us section for more information).
MPG will take reasonable steps to ensure that all personal information it collects, uses or discloses is accurate, complete and up-to-date.
If you believe your personal information is not accurate, complete or up-to-date, please contact us (see the Contacting Us section for more information).
Your personal information may be stored in hard copy documents or electronically. MPG is committed to keeping your personal information secure and safe. Some of the ways we do this are:
- Requiring employees and contractors to enter into confidentiality agreements.
- Secure hard copy document storage (i.e. storing hard copy documents in locked filing cabinets).
- Security measures for access to our computer systems.
- Providing a discreet environment for confidential discussions.
- Access control for our buildings.
We will review and update our security measures from time to time. In addition, we will review the personal information and sensitive information held by us from time to time; ensuring that information which is no longer needed for a purpose for which it was initially collected is destroyed or de-identified.
We use ‘cookies’ to provide you with better and more customised service and with a more effective website.
A ‘cookie’ is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your internet browser.
- to allocate a unique number to your internet browsers;
- to customise our website for you;
- for statistical purposes;
- to identify if you have accessed a Third Party Website; and
- for security purposes.
Your IP address is the identifier for your computer when you are using the internet.
It may be necessary for us to collect your IP address for your interaction with various parts of our website.
The security of your information is very important to us. We regularly review developments in security and encryption technologies. Unfortunately, no data transmission over the internet can be guaranteed as totally secure. We take all reasonable steps to protect the information in our systems from misuse, interference, loss, and any unauthorised access, modification or disclosure.
If we no longer require your information, and we are legally permitted to, we will take all reasonable steps to destroy or de-identify the information.
We take reasonable steps to preserve the security of cookie and personal information in accordance with this policy. If your browser is suitably configured, it will advise you whether the information you are sending us will be secure (encrypted) or not secure (unencrypted).
You may request access to personal information that MPG holds about you.
We will acknowledge your request within 14 business days of the request being made. Access will usually be granted within 21 business days of our acknowledgment or, if the request involves complex considerations or voluminous photocopying or scanning, within 28 business days. We will let you know which timeframe applies to your request and if any delays are anticipated.
You will need to verify your identity before access to your personal information is granted.
While we cannot and do not charge an application fee” for you applying to access your personal information, we may charge a fee for actually giving you access to your personal information in your preferred format (where reasonable and possible), which will cover our costs involved in locating and collating information as well as reproduction costs.
Once your request has been processed by MPG, you may be forwarded the information by mail or email or you may personally inspect it at the location where the information is held or another appropriate place. Whenever possible, we will endeavour to make the information available to you in the manner requested by you unless it is unreasonable for us to do so (e.g. if you have asked for the information to be emailed to you, we will endeavour to email the information to you. If the file size would be too large, we may send you the information by hard copy instead of email).
If you are aware that we hold personal information about you that is no longer accurate, complete or up-to-date, please contact us (see the Contacting Us section for more information).
If you request access to your personal information, or if you request that we correct your personal information, we will allow access or make the correction unless we consider that there is a sound reason to withhold the information, or not make the correction.
Under the Act, we may refuse to grant access to personal information if:
- We believe that granting access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety.
- Granting access would have an unreasonable impact upon the privacy of other individuals.
- Denial of access is required or authorised by law or by a Court or Tribunal order.
- Giving access would be unlawful.
- The request for access is frivolous or vexatious.
- Legal proceedings are underway or anticipated and the information would not be accessible by way of the discovery process in those proceedings.
- Giving access would reveal our intentions in relation to negotiations between us and you in such a way as to prejudice those negotiations.
- Giving access is likely to prejudice enforcement related activities conducted by, or on behalf of, an enforcement body.
- Giving access is likely to prejudice action being taken or to be taken with respect to suspected unlawful activity or serious misconduct relating to our functions or activities.
- Giving access would reveal information in connection with a commercially sensitive decision-making process.
- If we do not agree to make a correction to your personal information, you may provide a statement about the requested corrections, and we will ensure that the statement is apparent to any users of the relevant personal information.
- If we do not agree to provide access to your personal information or to correct your personal information, we will provide written reasons for the refusal and the mechanisms available to complain about the refusal (see the Complaints section for more information).
You may contact us by mail, email or telephone as follows:
PO Box 1307, Camberwell, VIC 3124
1300 668 247
If you consider that there has been a breach of the Australian Privacy Principles, you are entitled to complain to MPG (see the Contacting Us section for more information).
We will acknowledge receipt of a complaint within 2 business days.
We will investigate the complaint and attempt to resolve it within 20 business days after the complaint was received. Where it is anticipated that this timeframe is not achievable, we will contact you to provide an estimate of how long it will take to investigate and respond to the complaint.
If you consider that we have not adequately dealt with a complaint, you may complain to the Office of the Australian Information Commissioner at:
Officer of the Australian Information Commissioner (OAIC)
GPO Box 5218
SYDNEY NSW 2001
1300 363 992