Your Rights to Privacy
We note for you that personal information may pass between the Fund and the Fund’s administrator which is Mercer Outsourcing (Australia) Pty Ltd ABN 83 068 908 912 AFS Licence 411980 (Mercer) and professional advisers, insurers, government bodies, and other parties as required. Also to be noted is that your personal information may be sent and accessed outside Australia (see information in this Policy under the heading ‘Overseas Disclosure’.)
The Fund also has in place a Privacy Collection Statement which is an appendix to this Policy.
What personal information do we collect and hold?
The types of information that we collect and hold about you could include:
- ID information such as your name, postal or email address, telephone numbers, and date of birth;
- other contact details such as social media handles;
- financial details such as your tax file number;
- health information;
- your nominated beneficiary details; and
- other information we think is reasonably necessary.
In general, we do not use or disclose your personal information for a purpose other than:
- a purpose set out in this Policy; or
- a purpose you would reasonably expect; or
- a purpose required or permitted by law; or
- a purpose otherwise disclosed to you to which you have consented.
"Sensitive information" is information or opinion about an individual which is:
- personal information which is also information or an opinion about the individual's racial or ethnic origins;
- political opinions;
- political association membership;
- religious beliefs or affiliations;
- philosophical beliefs;
- professional or trade association membership;
- trade union membership;
- sexual orientation or practices, or criminal record; or
- health, genetic or biometric information about the individual.
We will only collect sensitive information (including health information) about you with your consent, except where we are required or permitted by law to collect your sensitive information without your consent.
Collection required by Law
When the law authorises or requires us to collect information
We may collect information about you because we are required or authorised by law to collect it. Your personal information will not be used or disclosed for any other purpose without your consent, except where required by superannuation, taxation or other relevant law. For example, Mercer, as REI Super’s fund administrator is required to report certain information to the Australian Taxation Office for tax related purposes and other information to the Australian Transaction Reports and Analysis Centre for anti-money laundering and counter-terrorism financing reasons.
What do we collect via your website activity?
The main way the Fund would collect personal information from you is if you used the REI Super website to lodge forms, such as membership application and change of personal details form etc., or completed hard copy paperwork sent to you. Also, there are circumstances where your employer may transfer your personal details to Mercer to establish a membership account on your behalf. In these cases, Mercer, on behalf of the Fund, will advise you how your personal information will be used.
We also know that some members like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However for all confidential matters, we’ll ensure we interact with you via a secure forum.
To improve our services and products, we sometimes collect de-identified information from web users. That information could include IP addresses or geographical information to ensure your use of our mobile application is secure.
We also collect de-identified information if you use one of our calculators. Although the information collected does not identify an individual, it does provide the Fund with useful statistics so that we can analyse and improve our web services.
A cookie is a small text file sent to the user’s browser that allows the web page server to retrieve information from the computer. Cookies can either be temporary session cookies, or stored permanently on a computer. They are used for a range of purposes, including security and personalising services.
The SuperFacts component of the REI Super website uses temporary session cookies to provide secure, personalised services. These cookies are removed from your computer when you log out of SuperFacts.
How do we collect your personal information?
How we collect and hold your information
There are many ways we seek information from you. We might collect your information when you fill out a form with us, when you have given us a call, used our websites. We also find using electronic means, such as email a convenient way to communicate with you and to verify your details. Please refer below to “How we handle email”.
REI Super has appointed Mercer as fund administrator, along with a life insurer and other organisations to provide services for you on our behalf. They are authorised to use your personal information only to administer your fund membership and benefit claims made by or in respect of you, under the strictest confidence.
From time to time, REI Super may also commission independent consultants to undertake research, which involves contacting Members as part of random research methodology. For this purpose, REI Super provides Members’ names and contact details. The objective of surveying Members is to ensure that REI Super tracks Member satisfaction and the effectiveness of REI Super services and products.
How we handle email
We will preserve the content of any email that you send us, if we believe we have a legal requirement to do so. Your email message content may be monitored for security issues, including where email abuse is suspected. Our response to you may be monitored for quality assurance purposes.
If you provide us with your email address, we may use it to send our regular communications such as updates on new and existing products and services that will enhance our relationship with you. If you do not wish to receive such information, or previously indicated that you would like to and have now changed your mind, call REI Super on 1300 13 44 33.
Consequences of not providing your Personal Information
What if you don’t want to provide us with your personal information?
If you don’t provide your personal information to us, we may not be able to:
- provide you with the Superannuation service you want;
- manage or administer your superannuation;
- verify your identity or protect against fraud; or
- let you know about other Superannuation products that might better meet your financial and lifestyle needs.
Unsolicited Personal Information
What do we do when we get information we didn’t ask for?
Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.
When will we notify you that we have received your information?
When we receive personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.
Sometimes we collect your personal information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.
How we collect your information from other sources
Sometimes we collect information about you from other sources. We do this only if it’s necessary to do so. Instances of when we may need to include where:
- we can’t get hold of you and we rely on publicly available information to update your contact details;
- we need information from an insurer about an insurance application you make through us;
- we are checking the security you are offering through public registers and our service providers; and
- at your request, we exchange information with your legal or financial advisers or other representatives.
The personal information collected by Mercer, on behalf of the Trustee, is used to establish a superannuation membership account, to which your employer contributes, to correspond with you and to provide you with the superannuation benefits and options offered by your superannuation plan.
The consequences of not providing requested personal information may mean that Mercer, on behalf of the Trustee, will not be able to provide superannuation administration services to you, including offering you some benefits and options of your superannuation plan.
Other organisations which will have access to your personal information may include;
- A mailing house – an organisation contracted to undertake all mailing for REI Super;
- Archiving companies – Mercer contracted organisations to ensure that all hard copy documents are stored off site in a secure environment;
- Auditors and Regulators & Government Agencies – organisations that ensure REI Super and the Administrator are complying with legislation and can comment on contractual obligations;
- Underwriters – insurance organisations which provide underwriting services for insured benefits;
- Solicitors, barristers and medical specialists engaged by the Trustee and/or Mercer in respect of the REI Super. Your name and address will be de-identified as far as is possible in respect of these disclosures;
- Computing or information technology professionals engaged to assist Mercer with the provision of administration services for REI Super; and
- Should the Trustee enter into a strategic alliance with an organisation offering financial planning services to the public, disclosure of members' personal information to that organisation for provision of those services may become necessary.
Taking care of your personal information
How do we take care of your personal information?
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:
- confidentiality requirements of our employees;
- document storage security policies;
- security measures for access to our systems;
- only giving access to personal information to a person who is verified to be able to receive that information;
- control of access to our buildings; and
- electronic security systems, such as firewalls and data encryption on our websites.
We can store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.
If your personal information held by REI Super or REI Super’s service provider is lost or subjected to unauthorised access or misuse, we will follow our Data Breach Response Plan to
- assess the incident;
- notify you as required in the Act; and
- implement the necessary procedures to prevent a similar incident occurring in the future.
What happens when we no longer need your information?
We’ll only keep your information for as long as we require it for our purposes. We’re also required to keep some of your information for certain periods of time under law, such as for the Corporations Act and the Anti-Money Laundering & Counter-Terrorism Financing Act. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
Using your personal information
What are the main reasons we collect, hold and use your information?
The Information will be used primarily for the purpose of managing your superannuation under the terms of the Trust Deed (as amended from time to time) which governs the Fund. This includes but is not limited to:
- calculation and payment of benefits;
- managing the insured death and disability benefits offered from the Fund;
- transferring moneys to other superannuation funds, rollover funds and approved arrangements; and
- allocations to and from the allocated pension area of the Fund.
Can we use your information for marketing our products and services?
We may use or disclose your personal information to let you know about products and services that might better serve your financial and lifestyle needs, or running competitions or promotions and other opportunities in which you may be interested.
We may conduct these marketing activities via email, telephone, SMS, mail, or any other electronic means. We may also market our products to you through third party channels (such as social networking sites).
Where we market to prospective members, we are happy to let them know how we obtained their information and will provide easy to follow opt-outs.
We won’t sell your personal information to any organisation outside of REI Super.
Yes, You Can Opt-Out
You can let us know at any time if you no longer wish to receive direct marketing offers from REI Super. We will process your request as soon as practicable.
What are the other ways we use your information?
We’ve just told you some of the main reasons why we collect your information, so here’s some more insight into the ways we use your personal information including:
- identifying you or verifying your authority to act on behalf of a member;
- telling you about other products or services that may be of interest to you, or running competitions and other promotions (this can be via email, telephone, SMS, mail, or any other electronic means including via social networking forums), unless you tell us not to;
- allowing us to run our business and perform administrative and operational tasks, such as:
- determining whether a beneficiary will be paid a benefit;
- preventing or investigating any fraud or crime, or any suspected fraud or crime;
- as required by law, regulation or codes binding us; and
- for any purpose for which you have given your consent.
Sharing outside of Australia
We run our business in Australia. In managing your superannuation, your personal information may be disclosed to service providers in another country to Australia, most likely being to Mercer’s administration processing centre in India. Mercer’s Indian administration processing strictly adheres to Australia’s privacy laws and Mercer is responsible for this under our administration agreement.
You can view a list of the countries in which those overseas organisations are located at https://secure.superfacts.com/web/IWfiles/attachments/Form/MercerAustraliaPrivacyPolicy.pdf. Disclosure may also occur to the trustees of other Australian superannuation funds or approved off-shore arrangements which your superannuation may be transferred to.
We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.
Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
Accessing your personal information
How do you access your personal information?
We‘ll always give you access to your personal information unless there are certain legal reasons why we can’t. You can ask us to access your personal information that we hold by contacting us on 1300 13 44 33.
We will give you access to your information in the form you want it where it’s reasonable and practical (such as a copy of a phone call you may have had with us – we can put it on a disk for you). We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first.
We’re not always required to give you access to your personal information. Some of the situations where we don’t have to give you access include when:
- we believe there is a threat to life or public safety;
- there is an unreasonable impact on other individuals;
- the request is frivolous;
- the information wouldn’t be ordinarily accessible because of legal proceedings;
- it would prejudice negotiations with you;
- it would be unlawful;
- it would jeopardise taking action against serious misconduct by you;
- it would be likely to harm the activities of an enforcement body (e.g. the police); or
- it would harm the confidentiality of our commercial information.
If we can’t provide your information in the way you’ve requested, we will tell you why in writing. If you have concerns, you can complain. See our Complaints section.
Correcting your personal information
How we correct your information
Contact us if you think there is something wrong with the information we hold about you and we’ll try to correct it if it’s:
- out of date;
- irrelevant; or
If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can - if we can’t, then we’ll let you know in writing.
Helping you manage corrections
Whether we made the mistake or someone else made it, we are required to help you ask for the information to be corrected. So we can do this, we might need to talk to others. However, the most efficient way for you to make a correction request is to send it to the organisation which made the mistake.
Where we correct information
If we’re able to correct the information, we’ll let you know within five business days of deciding to do this. We’ll also let the relevant third parties know as well as any others you tell us about.
Where we can’t correct information
If we’re unable to correct your information, we’ll explain why in writing within five business days of making this decision. If you have any concerns, you should refer to the information in this Policy under the heading ‘Resolving your privacy issues’).
Time frame for correcting information
If we agree to correct your information, we’ll do so within 30 days from when you asked us, or a longer period that’s been agreed by you.
If we can’t make corrections within a 30 day time frame or the agreed time frame, we must:
- let you know about the delay, the reasons for it and when we expect to resolve the matter;
- ask you to agree in writing to give us more time; and
- let you know you can complain to us or the Office of the Australian Information Commissioner.
In some cases, it may be necessary to charge a fee to access or compile certain information e.g. archived materials. Persons requesting access will be informed about any fee before it is charged. Any fee will not be excessive and no fee will apply to the making of the request to access.
Resolving your privacy issues
How do you generally make a complaint
To find out more about the personal information we hold about you and how it is handled, please call REI Super on 1300 13 44 33.
If you believe your privacy has been breached, you should write to:
REI Super Privacy Officer
GPO Box 4303
Melbourne VIC 3001
If the Trustee has not responded to your issue within 90 days, or you are not satisfied with the Trustee’s decision, as must be conveyed to you within 30 days or any longer agreed timeframe, you can raise your concerns with the Office of the Australian Information Commissioner:
Phone: 1300 363 992
Email: [email protected]
Fax: +61 2 9284 9666
Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601
We care about your privacy. Please contact us if you have any questions or comments about our privacy policies and procedures. We welcome your feedback.
You can contact us in writing by letter addressed to:
REI Super Privacy Officer
GPO Box 4303
Melbourne VIC 3001
Telephone: 1300 13 44 33
Government related identifiers
What do we do with government-related identifiers?
In certain circumstances we may be required to collect government-related identifiers such as your tax file number. We will not use or disclose this information unless we are authorised by law.
This Policy may change. We will let you know of any changes to this Policy by posting a notification on our website. Any information collected after an amended privacy statement has been posted on the site, will be subject to that amended privacy statement. This policy is dated 22 February 2018.
Privacy Collection Statement
The Fund is administered by us along with our service provider, Mercer Outsourcing Australia Pty Ltd (Mercer). We collect, use and disclose personal information about you in order to manage your superannuation benefits and give you information about your super. We may also use it to supply you with information about the other products and services offered by us and our related companies. If you do not wish to receive marketing material, please contact us on 1300 13 44 33.
Our Privacy Policies are available to view at reisuper.com.au or you can obtain a copy by contacting us on 1300 13 44 33.
If you do not provide the personal information requested, we may not be able to manage your superannuation.
We may sometimes collect information about you from third parties such as your employer, a previous super fund, your financial adviser, our related entities and publicly available sources.
We may disclose your information to various organisations in order to manage your super, including your employer, our professional advisers, insurers, our related companies which provide services or products relevant to the provision of your super, any relevant government authority that requires your personal information to be disclosed, and our other service providers used to assist with managing your super.
In managing your super your personal information will be disclosed to service providers in another country, most likely to Mercer’s processing centre in India. Our Privacy Policies list all other relevant offshore locations.
Our Privacy Policies set out in more detail how we deal with your personal information and who you can talk to if you wish to access and seek correction of the information we hold about you. It also provides detail about how you may lodge a complaint about the way we have dealt with your information and how that complaint will be handled.
If you have any other queries in relation to privacy issues, you may contact us on 1300 13 44 33 or write to our Privacy Officer, GPO Box 4303, Melbourne VIC 3001.