This policy sets out how UniSuper Limited and UniSuper Management Pty Ltd, manage the personal information they hold about you.
Both UniSuper Limited and UniSuper Management Pty Ltd recognise the importance of protecting your personal information and are committed to complying with their privacy law obligations.
UniSuper Limited ABN 54 006 027 121 (USL) is the trustee of the UniSuper Superannuation Fund ABN 91 385 943 850 (the Fund). UniSuper Management Pty Ltd ABN 91 006 961 799, Australian Financial Services Licence No. 235907 (USM) has been appointed by USL to administer the Fund. USM is also licensed to provide financial services to members, such as financial advice and related services. In this Policy, USL, USM and the Fund are referred to collectively as UniSuper.
USL and USM and any other UniSuper group entity may use and disclose the personal information it collects to any other entity within this group.
What kinds of personal information does UniSuper collect?
UniSuper collects personal information only if it is necessary for its functions or activities. Such information includes your name, address, phone number, email address and date of birth. UniSuper also collects details of your beneficiaries, your employer and salary, your tax file number and your contributions.
In some cases, UniSuper also collects certain health-related, lifestyle and financial information about members. (For more about how UniSuper collects and manages health-related information, please see the section below titled “How does UniSuper collect and manage health information?”). UniSuper does not collect any other sensitive personal information about its members except with member consent.
How does UniSuper collect personal information?
UniSuper collects personal information in a fair and lawful manner. This means that generally UniSuper collects personal information directly from you. However in some instances UniSuper collects personal information about you from your employer, particularly when you join the Fund.
Additionally in order to assess a claim or an application for insurance UniSuper or its insurer may need to collect personal information about you from other third parties such as medical or health professionals, medical facilities, health authorities, assessors, underwriters and associated bodies, reinsurers and fraud detection agencies.
Why does UniSuper collect personal information?
Primarily, UniSuper collects your personal information to provide you with UniSuper membership, benefits and services, to administer your UniSuper membership, benefits and services, to verify your identity and to improve member services.
We will also collect personal information from you if you wish to receive financial advice and related services from us.
In some cases, UniSuper is required by law to collect personal information about you. For example, under tax legislation, UniSuper is required to collect your tax file number before it can accept after-tax (non-concessional) contributions from you. Also, under anti-money laundering legislation, UniSuper must collect certain information about you before providing certain services to you.
What happens if UniSuper is unable to collect personal information?
If UniSuper is unable to collect certain personal information from you, it may not be able to provide your benefits to you or to your beneficiaries. For example, if you fail to provide UniSuper with an up-to-date address, UniSuper may be required to transfer your benefits to the Australian Taxation Office or to an eligible rollover fund, rather than provide those benefits through the Fund.
Also, if UniSuper is unable to collect certain personal information from you, it may not be able to administer your benefits at all or as favourably as it otherwise might. For example, if you fail to provide your tax file number, UniSuper will not able to accept any voluntary after-tax (non-concessional) contributions from you and additional tax will be deducted from any employer or salary sacrifice (concessional) contributions made by you or your employer.
In other cases, if UniSuper is unable to collect certain personal information (e.g. your email address), it will not be able to provide you with member communications or other services as quickly or as effectively as we prefer.
How does UniSuper use and disclose your personal information?
Primary and related uses
Generally, UniSuper uses and discloses your personal information for the primary purposes for which it was collected (namely, to provide and administer your superannuation benefit and/or improve your membership, benefits and services). However, from time to time, UniSuper may also use and disclose your personal information for a related purpose.
For instance UniSuper may use or disclose your personal information to:
- monitor, evaluate or audit a particular product or service UniSuper is providing;
- provide you with information and education about superannuation;
- roll over your benefits to another superannuation fund (e.g. when you move to a new employer);
- deal with complaints about the UniSuper products or services provided to you;
- issue reminders to members who have used a UniSuper product or service previously;
- issue market research, which may be managed by UniSuper, third party research consultants bodies or Universities according to the terms of an Australian Research Council Grant or similar;
- provide direct marketing from UniSuper to promote our services and products;
- provide you with financial advice; including financial product advice and related services. If you receive financial advice UniSuper will record your personal information. To best serve your needs UniSuper may disclose your personal information to third parties which typically these will include product issuers and life companies.
UniSuper does not disclose your personal information to any external organisation for the purposes of enabling those organisations to engage in direct marketing to you. From time to time, however, UniSuper will market its products and services to its own members.
UniSuper may provide marketing and information by email to the email address that you have provided to us. In some circumstances we may also write to you at your nominated postal address.
You will be given the opportunity to choose whether or not you wish to receive this information. You may opt-out of such contact at any time.
For email communications you can opt out of receiving emails by selecting the ‘unsubscribe’ option which is attached at the base of every email communication.
If you do not want to receive letters relating to direct marketing communication please notify us. Please see the details at the end of this policy for information about how to contact UniSuper.
UniSuper engages certain external organisations to assist in the provision of services to members (e.g., mail-houses, auditors, insurers, actuaries, lawyers, research consultants). Where your personal information is disclosed to these organisations we will seek to ensure that the information held is used and disclosed consistently with the privacy legislation including any relevant Health Privacy Principles under State or other applicable privacy legislation.
UniSuper discloses your personal information to such organisations but does so only for the purpose of providing, administering or improving your superannuation membership, benefits or services. In these instances UniSuper will engage these third parties on contractual terms to ensure the security and privacy of any personal information that it provides to these third parties.
UniSuper is required or authorised (e.g. under taxation, superannuation or anti-money laundering legislation) to disclose your personal information to certain government authorities (e.g. to the Australian Tax Office, the Australian Securities and Investments Commission, the Australian Prudential Regulation Authority and the Australian Transaction Reports and Analysis Centre).
UniSuper may also be required to provide personal information to other agencies that are authorised by their governing legislation. These agencies include law enforcement bodies such as state and federal police, revenue agencies or the agencies within the Department of Human Services; for example Centrelink or the Child Support Agency.
How does UniSuper maintain the quality of your personal information?
UniSuper relies on accurate, complete and up-to date personal information to fulfil its duties. Accordingly, whenever UniSuper sends you correspondence that includes your personal information (e.g., a benefit statement) we will ask you to check its accuracy and respond to us immediately with any changes. UniSuper also provides an update service via MemberOnline, you can also complete the Change of Details form, make an email enquiry at firstname.lastname@example.org or call us on 1800 331 685. We may also update your personal details based on information provided by your employer.
It is not possible for UniSuper to keep track of every change to your personal information. UniSuper must therefore rely on you to advise it of any changes to your personal information. UniSuper encourages you to advise it immediately of any changes to your personal information, especially if it may affect your benefits directly (e.g. changes to your name, address or nominated beneficiaries).
How does UniSuper keep your personal information secure?
UniSuper takes all necessary precautions to ensure your personal information (in both physical and electronic form) is secure. In particular, UniSuper operates in a secure environment that ensures protection of all paper-based personal information. As part of their role, UniSuper staff are required to respect the privacy of all personal information in their possession. Further, all UniSuper information technology systems employ the latest data security software and hardware. All users of these systems are registered with UniSuper and access is monitored on a constant basis. Users are able to access only the personal information they require to perform their role.
Any personal information held by UniSuper will be destroyed or permanently de-identified when it is no longer needed for any purpose for which UniSuper might legitimately use or disclose it.
How can you access and correct your personal information?
UniSuper will provide you with access to all personal information held about you upon request. Please see the details at the end of this policy for information about how to contact UniSuper. Your Benefit Statement (which is provided to you twice yearly) will generally include most of the personal information UniSuper holds about you.
Sometimes, UniSuper may refuse to provide you with access to your personal information, e.g. where it would be unlawful or may pose a serious and imminent threat to someone’s health. In some instances UniSuper is unable to release information provided to it by a third party, for example a medical practitioner or another health consultant’s report or information provided by a third party entity. Where this occurs UniSuper may refer you to the third party to access the information directly. In each of these cases UniSuper will provide you with reasons for the refusal.
Does UniSuper collect and use government identifiers?
As mentioned above, UniSuper may collect and use your tax file number. Tax file numbers are numbers assigned to every tax-payer by the Australian Tax Office to identify each such person uniquely for tax-related purposes. Tax file numbers are government-assigned identifiers. If UniSuper collects or uses any other government-assigned identifiers we will obtain your consent.
Collection and use of tax file numbers by UniSuper is authorised by law. UniSuper will use your TFN to locate multiple amounts or other memberships within the Fund; however in order to seek superannuation information relating to your accounts from the ATO or other superannuation entities we will seek your consent.
Are you able to transact with UniSuper anonymously?
When you make enquiries to UniSuper that are of a general nature (e.g. a general enquiry about UniSuper benefits before you become a member), it may be possible for you to do so on an anonymous basis. However, if you want to receive complete and accurate information from UniSuper (e.g. about your existing UniSuper account), you will need to provide us with your personal details so we can verify your identity.
Generally you will need to provide your member number when making enquiries. When you enter into certain transactions with UniSuper (e.g. when you seek to change your investment options or when you seek confidential information about your benefit or account), further personal information may be required and anonymous interaction will not be possible.
Does UniSuper disclose your information overseas?
UniSuper may in some instances transfer or disclose personal information to entities that are based overseas, for example if we have appointed a service provider who processes data off-shore. In some instances our third party providers may utilise servers that are based outside Australia.
If this occurs, we will comply with the following process:
- we will obtain your consent to the transfer; or
- we determine that the transfer of the information is necessary for the performance of a contract between you and the third party organisation; or
- where the transfer of personal information is for your benefit and it is impracticable to obtain your consent and we determine that if you had the opportunity to provide your consent, in the particular set of circumstances, you would consent.
In all cases UniSuper will:
- seek to ensure that the recipient of the information is subject to a law, binding scheme which effectively upholds the fair handling of the information that are substantially similar to the National Privacy Principles; or
- put in place appropriate contractual arrangements with such organisations with a view to providing a reasonable level of privacy protection equivalent to the standard you can expect in Australia.
Please note where information is transferred overseas UniSuper will seek to ensure the recipient of the data has security systems to prevent misuse, loss, unauthorised disclosure in line with current industry standards.
Does UniSuper collect and manage personal information on its website any differently to other personal information?
UniSuper operates a website (www.unisuper.com.au) for the benefit of existing and prospective members. Generally, any personal information that is collected from and managed via the website is collected and managed in the same manner as other personal information. However, there are a number of features of the website that are slightly different.
These are as follows:
- UniSuper collects certain tracking information from the way in which people use the website (e.g., by using ‘cookies’). This is collected for the purpose of improving the usefulness and usability of the site. None of this information identifies users personally.
- To access information about your account on MemberOnline (and to change your personal details), you will be required to enter a user name and password. Your user name and password will protect your personal information from unauthorised access and use. You must not disclose your user name and password to any other person.
- If you click on a link in UniSuper’s website that leads you to another organisation’s website, UniSuper will cease to be responsible for the privacy or security of any personal information that you may provide to the operator of the linked site. You should check with the linked site’s operator as to its policies on privacy before providing it with your personal information.
How does UniSuper collect and manage health information?
Generally, UniSuper does not collect health information about its members. However, it may be necessary for UniSuper to collect such information if:
- you apply for optional death and disablement or income protection insurance cover (so as to enable the insurer to determine whether to offer you the additional insurance cover); or
- you apply for a temporary incapacity or disablement benefit from UniSuper (so as to enable UniSuper and/or the insurer to assess your claim for payment of the benefit).
When UniSuper collects and manages health information, it complies with the terms of this policy and with the following additional rules:
- UniSuper will collect health information only with your consent or where it is required or authorised by law. Generally, UniSuper will collect health information from you directly. However, in some cases, UniSuper may collect health information about you from others (e.g. such as medical and health professionals, medical facilities, health authorities, assessors underwriters and associated bodies, reinsurers and fraud detection agencies; This will be done only with your consent which will be obtained when you make your initial application or claim.
- UniSuper may use and/or disclose your health information but will do so only with your consent or for the primary purpose for which it was collected (that is, to enable the insurer to determine whether to offer you additional insurance or to enable UniSuper and/or the insurer to assess your claim for payment of the relevant disablement benefit).
- It will not always be possible for UniSuper to give you the opportunity to correct health information held about you. However, even where UniSuper cannot correct health information as requested, UniSuper will take reasonable steps to note any statement you make about the relevant health information.
- Generally, enquiries to UniSuper which require reference to your health information will not be able to be made anonymously.
- Where UniSuper discloses health information to persons or organisations outside Victoria, it will do so only with your consent or where the recipient is subject to health privacy laws substantially similar to those in Victoria.
You should bear in mind that if you do not provide UniSuper with health information as requested, it may not be possible for the insurer to grant you the additional insurance cover you seek or it may not be possible for UniSuper and/or the insurer to assess your claim for payment of a disablement or temporary incapacity benefit.
More details and further queries
If you require:
- more detailed information on a specific privacy issue;
- or you have any concerns or complaints about UniSuper’s collection, use or disclosure of your personal information; or
- you would like to opt out of receiving certain communications or information;
- Write to the Privacy Officer, UniSuper, Level 35, 385 Bourke Street, Melbourne Vic 3000; or
- Call the UniSuper Helpline on 1800 331 685 between 8.30am and 7.00pm (AEST), Monday to Thursday and 8.30am and 6.30pm Fridays.
For more information about privacy in general, you can visit the Office of the Australian Information Commissioner's website www.oaic.gov.au