Privacy Policy

At Sterling Private Group Pty Ltd (Sterling Private Wealth) we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth). This Policy describes our policies and practices for collecting, handling, storing, using, and disclosing personal information. It also deals with how you can complain about a breach of the privacy laws, access the personal information we hold about you and have that information corrected (where necessary).

What personal information do we collect and hold, and how do we get it?

Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its services, Sterling Private Wealth may collect your personal information.

The personal information the Sterling Private Wealth collects depends on, and is specific to, the products and services you engage us to provide. Generally, the kinds of personal information we collect includes:

• Your name, address, telephone number, email address and date of birth

• Other identification verification information, including photographic information, from documents including your birth certificate, passport, driver’s license, pension card, citizenship certificate, tax notice assessment, Medicare card and utilities notices

• Financial information about your assets, occupation and income, account balances, bank account details, account activities, trust arrangements, payment history and transactions with us and third parties

• Tax information including your tax file number, tax returns and related information

• Professional and business information about your membership of a professional association, partnerships, directorships, business names and trust arrangements.

Sterling Private Wealth is also required to collect and verify identification information as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). In some circumstances, we may also hold other personal information provided by you.

This information is primarily collected from application forms you have completed, your use of our online facilities or through ongoing communications with you or persons you authorise to communicate with us on your behalf.

There are specific circumstances in which we will ask for your consent to provide sensitive information such as:

• Health Information when you apply for insurance or from medical practitioners when you make a claim

• income information from employers when you apply for additional insurance protection or salary continuance insurance

• details of your dependents, as defined at section 10 of the Superannuation Industry (Supervision) Act 1993 (Cth), to pay benefits in the event of your death.

We will inform you of any legal requirements for us to request information about you and the consequences of not providing that information. For example, in addition to the personal information we will obtain from you, whenever you acquire a new product or service from us, we will require documents evidencing your identity. Such evidence may include a certified copy of your driver’s licence, Passport, or birth certificate. If you do not provide identity documentation, we may not be able to action your request.

Generally, Sterling Private Wealth collects your personal information directly from you, through:

• Completion of an application or other form either online or in hard copy

• Provision of original, or copies of, documentation whether delivered in person, by post or electronically

• Direct communication via meetings or telephone meetings and exchanges

• Recordings of conversations (in which case you will be informed of such recording prior to the recording commencing)

• Email, or other electronic correspondence

• Receipt of mail which you have directed to be sent to Sterling Private Wealth

We will only solicit personal information about you where you have knowingly provided that information to us, we believe you have authorised a third party to provide that information to us, or we are obligated by law to obtain such information. Third parties that we may need to collect information from include your financial adviser, product issuer, employer, accountant, or solicitor. To verify your identity for Know Your Customer (KYC) purposes, we may also solicit personal information about you from reliable identity verification service providers.

We may also collect your information from third parties such as your bank, superannuation fund, insurance provider doctor, or other service that we reasonably require information from.

How do we use your information?

We use your personal information for the purpose for which it has been obtained and for related purposes. For example, we collect your personal information so that we are able to:

• provide financial advice to you

• establish and manage your investments and accounts

• implement your investment instructions

• establish and maintain insurance protection

• process contributions, transfer monies or pay benefits

• report the investment performance of your account

• keep you up to date on other products and services that may be of interest to you

• improve the operation of our business and enhance the delivery of our products and services.

We may use technology such as cookies, beacons, tags, scripts and tracking pixels to collect, store and use anonymous data about how you use our website / mobile technology. This includes your server address, the date and time of your visit, the pages and links accessed, the type of browser used and other information about your browsing activities. This data is used to increase functionality and can also enable us to display information and content that is tailored to our understanding of your interests. This information alone cannot be used to discover your identity.

What if you don’t provide information to us?

You are not obligated to give us the information that we request. However, if you do not give us the information that we ask for, or the information you give is not complete or accurate, this may:

• prevent or delay the processing of your application or claim

• affect your eligibility for specified insurance cover

• preclude us from providing you financial advice

• prevent us from contacting you about your product or services

• impact the taxation treatment of your account.

For example, we are required to ask for your TFN when you become a member of one of our superannuation products. If you choose to not give us your TFN, you may be subject to higher tax charges on your superannuation, we may not be able to locate different accounts in your name, and we may not be able to accept personal contributions.

You can contact us without using your name or by using a pseudonym.  However, we may need your name or contact details to respond to you.

How do we store and protect your personal information?

We strive to maintain the relevance, accuracy and completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal reporting or document retention requirements.

Sterling Private Wealth regards the security of personal information as very important and has implemented a range of measures to ensure the personal information it holds is protected from misuse, interference, and loss and from unauthorised access, modification or disclosure. The protection measures in place include:

• Confidentiality requirements for employees

• Confidentiality statements on all outgoing correspondence including email

• Document storage security policies

• Security measures including encryption, firewalls, site monitoring and intrusion detection

• Providing a discreet environment for confidential discussions; and

However, Sterling Private Wealth cannot guarantee the security of personal information provided to us electronically via the internet, email or text nor can it guarantee the safe delivery of personal information via ordinary post and as such any communication is made at your own risk. The security arrangements are reviewed and tested from time to time.

Will we disclose your personal information to anyone?

We do not sell, trade, or rent your personal information to others. Generally, Sterling Private Wealth will only disclose your personal information for the purposes of providing its products and services to you. This may include disclosing your personal information to various entities within Sterling Private Wealth and third parties where necessary to provide you with our products and services.  

These third parties may include government departments or other regulatory authorities and professional associations, lawyers, auditors, financial market and clearing and settlement facility operators, lenders, credit providers, insurers and audit insurance providers, custodians, share registries, certain software and IT providers, third parties engaged to perform administrative tasks, professional advisers or, if authorised by you, your staff, family members, and associated entities This disclosure is always on a confidential basis.

Sterling Private Wealth may also disclose your personal information with your consent or if disclosure is required or authorised by law.

How can you check, update or change the information we are holding?

Sterling Private Wealth seeks to ensure personal information we hold is accurate, current, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that we collect and hold.

If at any time you would like to access or correct the personal information Sterling Private Wealth holds about you, or you would like more information on information security or privacy please contact our offices. Sterling Private Wealth will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate. To obtain access or make a correction to your personal information we may have to verify your identity.

In some limited situations, we may need to refuse access to your information or refuse a request for correction. We will advise you as soon as possible after your request if this is the case and the reasons for our refusal.

What happens if you want to complain?

We welcome your questions and comments about how we manage your privacy. If you have any concerns about whether we have complied with the Privacy Act, the Australian Privacy Principles or this Privacy Policy, please write to our Privacy Officer at:

Privacy Officer
C/- Sterling Private Wealth
Level 4, 448 St Kilda Road
Melbourne VIC 3004
Telephone: (03) 9975 7200

We will consider your complaint through our internal complaints resolution process and we will try to respond with a decision within 30 days of you making the complaint.

If you are dissatisfied with the outcome of your privacy complaint, you may refer the complaint to the Office of the Australian Information Commissioner (OAIC) on 1300 363 992 or via email [email protected]

Your consent

By asking us to assist with your financial planning, insurance, or other servicing needs, you consent to the collection and use of the information you have provided to us for the purposes described above.

Updating this policy 

This Privacy Policy was prepared on 1st July 2020. We may update it at any time. The new version will be published on our website.