Privacy Policy

If you have any questions regarding the below DDH Privacy Policy, the operation of DDH Graham Limited (DDH), or your dealings with DDH, please email us through the Contact us page.

 

 

1. Introduction

DDH Graham Limited ABN 28 010 639 219 (referred to as “DDH”, “our”, “we” and “us”) and its named related entities below recognise that the privacy of your personal information is important to you and is committed to protecting the privacy of any personal information it collects from you. Unless you give us your consent to do otherwise, we will only collect and use your personal information as set out below.

DDH uphold high standards of privacy practices and security and complies with The Privacy Act 1988 and the Australian Privacy Principles (“Privacy legislation”). Whenever we handle personal information, we take steps to ensure that appropriate standards of privacy and security are applied.

This Privacy Policy outlines how we will handle and manage personal information that we collect about you. This Policy also describes how you can access or correct information we hold about you or how you can contact us, make a complaint, or ask further questions. You can obtain information about the Australian Privacy Principles (APPs) and your privacy rights at the website of the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

 

2. What information do we collect?

DDH collects and holds personal information from clients, customers, employees, contractors, and other individuals. When we refer to personal information, we mean information from which your identity is reasonably apparent, and which may include information or an opinion about you and any of the following:

  • Your name, date of birth, address, account details, occupation, any other information we may need to identify you.
  • Sensitive information (includes information or an opinion about an individual’s racial or ethnic origin, political opinion, religious beliefs, sexual orientation, biometric information or criminal record).
  • Health information.
  • Tax file number information.

Where relevant we may ask you for other information, for example, qualifications and employment history if you are applying for employment with us. See the Employment Applications section for more information.

 

3. How do we collect and hold your personal information?

We usually collect personal information in the following ways:

  • Directly from you, either in person, in documents, by email, facsimile or via our websites. We may also collect information via telephone, where calls we receive from you may be recorded for quality assurance purposes.
  • From third parties, such as your employer, our related companies, financial advisers, stockbrokers, financial institutions, or self-managed superannuation fund administrators, where we have established accounts or other banking facilities in your name, business associates and business counterparties, lessors, and solicitors.
  • From publicly available resources.

 

4. Employment applications

By providing personal details, submitting an application (including where you undertake video interviewing) or CV, or registering interest in employment with DDH, you will supply us with personal information, including your application data, gender, right to work status, educational history, and contact details (‘your information’). Please note that, once collected, DDH will only collect, use, and disclose your information where this is necessary for the administration of the recruitment process and, where applicable, your employment/engagement with DDH, or where DDH has a legitimate interest in processing the data. For example, this could be for the following purposes:

  • To assess and administer your application for employment/engagement in accordance with DDH’s recruitment and administrative practices (including conducting police and reference checks).
  • To communicate with you in relation to your application or other suitable roles within DDH.
  • To comply with any legal or regulatory obligations.
  • Internal reporting.

If your application is unsuccessful, DDH may retain your information on file for one year and may contact you if another role arises (if you apply for another role before the one-year mark is reached, the one-year period for all information will re-start from the date you apply for that subsequent role). When the one-year mark is reached, DDH will make best efforts to either delete, anonymise, or put personal information about you ‘beyond use’ within a period of three months. Please contact DDH if you do not want us to retain your information on file. If your application is successful, DDH will retain your information as part of your employment records.

Any personal identification information (e.g., drivers licence details) that is held by DDH for the purpose of a police check application will be deleted upon receipt of the final police check from the relevant authority.

 

5. Collection of information from our websites

When using one of our websites you may voluntarily disclose personal information to us. Our service provider logs the following information for statistical purposes: your server address, top level domain name (e.g. .com, .gov, .au, .uk, etc.), the date and time of your visit, the pages accessed, the documents downloaded, the previous site visited and the type of browser used. This information is used for internal purposes only and to effectively manage our website, including statistical purposes. None of this information specifically identifies an individual.

We will not seek to identify users or their browsing activities except as necessary to investigate or report any suspected unlawful activity, as required, or authorised by law or as reasonably necessary for the activity of an enforcement body.

Cookies are used on our website. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work or work more efficiently as well as to provide information (noted above) to the owners of the site.

For our customers who have online account access, there are cookies in place which cache login user details to be used throughout the application for authorising transaction instructions. For those customers using the online application process, there are also cookies on our website that are being used to store data for the Application as part of the Application Centre to allow users to retrieve the status of their application.

 

6. Direct marketing

We will keep you informed about the financial services we offer (or those offered by our subsidiaries, joint venture partners and third parties for which we act as agent) if we believe this information may be of interest to you, or if it may help us develop and improve our services to you.

We respect your wishes with regard to your privacy, so if you do not wish to receive this information, please contact us regarding direct marketing. If we are not advised in this regard, we will continue to use your personal information for this purpose.

We will also continue to send you information relating to the financial services that you have selected, such as newsletters, statements, statement inserts or offer to upgrade these services.

 

7. What are the consequences of not providing us with the information requested?

If you do not provide us with the requested personal information, or if the information you give us is incomplete or inaccurate, we may be delayed or prevented from providing you any products or services, carrying out any transaction for you, providing information to you, processing any application, or otherwise meeting our obligations to you.

If you choose not to provide your tax file number, and do not claim an exemption, we are required to deduct tax on any income distribution at the prescribed rate plus Medicare levy.

 

8. How do we use your personal information?

We use the personal information we collect primarily to provide you with a range of products and services, to meet our obligations to you and to enable us to conduct our business, including:

  • Administering and reporting to you on a variety of investment products, carrying out investments on your behalf as well as managing and reporting to you on your investments.
  • Providing you with superannuation administration services and insurance claims processing.
  • Establishing accounts or other banking facilities on your behalf with third-party financial institutions and administering your accounts or other banking facilities.
  • Negotiating and documenting leases and related decisions; communicating operational matters in relation to tenancies; and arranging for the sale of premises.
  • Conducting our internal business operations (including meeting any relevant legal requirements).
  • Preventing or investigating any actual or suspected fraudulent or unlawful activity or misconduct.
  • Identifying you or establishing your tax status under any Australian or foreign legislation, regulation or treaty pursuant to an agreement with any tax authority.
  • Testing new systems of functionality for product improvement purposes (in a controlled environment).
  • Managing client relationships and improving the services we provide.
  • Assessing applications for employment.
  • Performing other functions and activities associated with managing our relationship such as, staff training, market research, risk management, audits/reviews, complaint management and product or service development among other things.

We may also anonymise your data for our own purposes including new product development; and from time to time use your personal information to provide you with information about financial and superannuation products and services or events which we expect may be of interest to you, through our newsletters and other promotional materials. However, we respect your right to ask us not to do this.

 

9. Electronic verification

To meet our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) with your consent, we may use your personal information to verify your identity through the process of electronic verification. We may also perform the same process to re-identify you, from time to time. We will disclose your personal information to our service provider for electronic verification, who will match and exchange your personal information with external data sources, via the Australian Governments document verification service (DVS) which allows organisations to compare individuals ID information with government records. If you do not consent to us verifying your identity electronically, we may offer you an alternate verification process.

 

10. To whom do we disclose personal information?

We will only disclose personal information to third parties only as the Privacy legislation permits and where there is a valid reason to do so. All third parties must use your information only for the specific purpose for which we supply it. Third parties may include:

  • Employees, contractors, auditors and advisers.
  • Any entity owned or controlled by DDH.
  • Our related bodies corporate.
  • Any person where necessary or desirable in connection with the provision of our products or services, including to financial institutions where we may establish accounts or other banking facilities on your behalf.
  • Our professional advisers such as auditors, accountants and lawyers, insurance companies, property managers, consistent with normal business practices.
  • Your nominated financial advisers or agents with your permission.
  • Superannuation trustees and promoters.
  • Third parties we may engage from time to time to assist us in the promotion of our products and services, and who may receive limited personal information for that purpose.
  • External service providers (on a confidential basis) so they can provide us services related to our business, for example mailing services, IT services, unit registry and custodial services, archives services, and off-site secure data storage providers. We require our service providers to adhere to our Privacy Policy and not to keep, use or disclose personal information we provide to them for any unauthorised purpose.
  • Third parties where required or authorised by law.
  • Third parties you provide consent for us to disclosure to.

We do not sell personal information for marketing purposes to other organisations or allow other companies that we have shared your information with, to do this.

 

11. Cross-border disclosure of personal information

In some circumstances the parties with whom we share personal information may operate outside of Australia, as a result, your personal information may be disclosed to a recipient in a foreign country, including, but not limited to India, New Zealand, and the United Kingdom. Where this occurs, we require the recipient to take steps to protect personal information against loss, misuse and unauthorised access, modification, or disclosure.

 

12. How do we store your information?

We keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include the processing and storage of this information in the cloud. Our cloud providers store this information in Australia.

 

13. How can you access and correct your personal information?

You have a right to access personal information we hold about you. We will comply with any request to access your personal information that you send us by email at privacy@ddhgraham.com.au except where the Act or the APPs allow us to refuse to do so. There is no fee for making a request to access your personal information, but we may charge a fee for giving you access to your personal information in a mutually agreed format, usually by sighting the accessible information held on file.

You also have the right to ask us to correct information about you that is inaccurate, incomplete, out-of-date, irrelevant, or misleading. If we refuse to correct your personal information as requested, we must:

  • Notify you in writing of the reasons for the refusal unless it would be unreasonable to do so, and how to complain about our refusal.
  • Upon request from you that we associate a statement that the information is inaccurate, incomplete, out-of-date, irrelevant, or misleading, take such steps as are reasonable in the circumstances to associate such a statement so that it will be apparent to users of the information.

 

14. DDH links to other websites

Sometimes the DDH website may contain a link to third-party websites. We are not responsible for the content or material contained in, or obtained through, any third-party website or for the privacy practices of the third-party website. We suggest that you review the privacy policy of each website that you visit.

 

15. Complaints or concerns

If you are not satisfied with the how we have dealt with your information or you have a complaint about our compliance with the Privacy legislation, you may contact us on:

Mail: Complaints Officer
GPO Box 330
BRISBANE QLD 4001
Phone: 1800 226 174
Email through the Contact us page: Contact Us – DDH Graham

 

If you lodge a complaint with us, we will investigate your complaint in an efficient and timely manner. We will advise you of the outcome of the investigation of the complaint within 30 days from receipt/notification of the complaint. If we require a longer period to investigate your complaint, we will notify you prior to the expiry of the 30 days.

If you are not satisfied with how we handle your complaint or the outcome, please advise us so we may escalate your complaint through our Internal Dispute Resolution process for review.

If you are not satisfied with our final response, you may lodge a formal complaint with the Australian Financial Complaints Authority (“AFCA”) on the below details:

Online: https://www.afca.org.au
Email: info@afca.org.au
Phone: 1800 931 678
Write to: Australian Financial Complaints Authority
GPO Box 3
MELBOURNE VIC 3001

 

If your complaint is about a privacy related matter, you may alternatively make a complaint to the Office of the Australian Information Commissioner (“OAIC”) on the below details:

Online: https://www.oaic.gov.au
Email: enquiries@oaic.gov.au
Phone: 1300 363 992 or +61 2 9942 4099 (if calling from outside Australia)
Write to: Office of the Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001

 

16. How can I contact DDH?

If you wish to contact us, you have the right to remain anonymous or to use a pseudonym. However, if you do so, we may not be able to assist you with your enquiry or complaint.

It is important to us that the personal information we hold about you is accurate and up to date. We may ask you from time to time, if any of your personal information has changed.

If you wish to contact us to have your information updated or corrected, you may contact us at:

Write to: DDH Graham Limited
GPO Box 330
Brisbane QLD 4001
Phone: 1800 226 174
Email through the Contact us page: Contact Us – DDH Graham

 

17. Changes to this Privacy Policy

This is our current Privacy Policy outlining our personal information management practices. This Policy replaces any other privacy policy published by us to date. We may vary this policy from time to time. We encourage you to review the DDH website regularly to ensure that you are aware of our current Privacy Policy.

Got questions? Get in touch.