Strategic Privacy Policy and Collection Statement




We recognise the importance of ensuring the confidentiality and security of your personal information.


We are bound by the Australian Privacy Principles (‘APPs’) and the Privacy Act 1988 (‘Privacy Act’). This Privacy Policy and Collection Statement (‘Policy’) outlines our practices, procedures and systems to manage and protect your personal information in accordance with the Privacy Act and the APPs. This Policy applies to the following entities:

  • Strategic Financial Management Pty Ltd
  • Strategic Asset Management Pty Ltd
  • Strategic Administration Services Pty Ltd
  • Strategic Investment Partners Pty Ltd
  • Strategic Investment Partners (Leeds) Pty Ltd


These entities are collectively referred to in this Policy as ‘Strategic’, ‘the Strategic Group’, ‘we’, ‘our’ or ‘us’.


All third parties (including clients, suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by Strategic must abide by this Policy.


Copies of this Policy are available free of charge by contacting the Privacy Officer or can be downloaded from the Privacy page of our website:


In this Policy:

  • Disclosure of information means providing information to persons outside of Strategic;
  • Personal information means information or an opinion relating to an individual, which can be used to identify that individual;
  • Privacy Officer means the contact person within Strategic for questions or complaints regarding Strategic’s handling of personal information;
  • Sensitive information is personal information that includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
  • Use of information means use of information within the Strategic Group.




We may collect and hold a range of information about you to provide you with our services, including your:

  • name;
  • address;
  • phone numbers;
  • email addresses;
  • occupation;
  • bank account details;
  • drivers’ licence and/or passport details;
  • financial information, including details of:
    • your investments;
    • your insurance policies;
    • income;
    • assets and liabilities;
    • estate planning strategies;
    • taxation information;
    • credit information; and
    • health information.




We generally collect personal information directly from you, the individual. For example, personal information will be collected when you enquire about or engage us to provide you with financial services, do business with us, visit our website, call us or send us correspondence.


Sometimes we may collect personal information about you from a third party, including the kinds of organisations and individuals described in section 8 below. In this case we will take reasonable steps to ensure that you are made aware of this Policy.


We will not collect sensitive information about you without your consent, unless an exemption under the APPs applies. These exceptions include if the collection is required or authorised by law, or is necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.


If the personal information we request is not provided by you, we may not be able to provide you with the benefit of our services, or meet your needs appropriately.


We do not give you the option of dealing with us anonymously, or under a pseudonym. This is because it is impractical, and in some circumstances illegal, for us to deal with individuals who are not identified.




Strategic may receive unsolicited personal information about you. We destroy or de-identify all unsolicited personal information we receive unless it is relevant to our purposes for collecting personal information.  We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect.  If we do this, we will retain the information in the same way we hold your other personal information.




The personal information we may collect and hold includes (but is not limited to) personal information about:

  • clients;
  • potential clients;
  • service providers or suppliers;
  • prospective employees, employees and contractors; and
  • other third parties with whom we come into




We collect personal information from our web site ( when we receive emails or when you complete an online form or log in to our website.




We may use and disclose the personal information we collect about you for the following purposes:

  • provide you with financial advice and services;
  • implement your instructions, including to establish and manage investments, margin loans and accounts, and arrange and maintain insurance cover;
  • make arrangements to accept and process deposits or contributions, transfer funds or pay benefits;
  • report on the implementation of your financial plan or performance of your investments;
  • let you know about other products or services we offer or invite you to events;
  • conduct our business and perform other management and administration tasks;
  • consider your concerns or complaints and manage legal actions involving Strategic;
  • comply with relevant laws, regulations and other legal obligations; and
  • help us improve the products and services, and enhance our overall


We may use and disclose your personal information for any of these purposes.  We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above and in other circumstances authorised by the Privacy Act.


Sensitive information, such as health information, will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise or an exemption in the Privacy Act applies.




We may disclose personal information to:

  • the entities listed in section 1 above and our other related entities;
  • any organisations that provide you with, manage or administer financial products or services, including any fund (administrator or trustee) to which your benefit is to be transferred or rolled over;
  • other financial advisers, custodians, external dispute resolution services, insurers, investment managers or mail houses;
  • your employer;
  • medical practitioners and other relevant professionals, where you have applied for insurance cover or made a claim;
  • any financial institution who holds an account for you;
  • any professional advisers appointed by us;
  • businesses that may have referred you to us;
  • an agent, professional adviser or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, information and IT managers, and identity verification services;
  • organisations involved in a transfer or sale of all or part of our assets or business;
  • organisations involved in managing payments, including payment merchants and other financial institutions such as banks;
  • regulatory bodies, government agencies, law enforcement bodies and courts;
  • anyone else to whom you authorise us to disclose it or is required by


If we disclose your personal information to service providers that perform business activities for us the service provider may use your personal information only for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues, and we will make third parties aware of this Policy.





We may disclose personal information to recipients that are located outside Australia in some circumstances. Generally, we will only disclose your personal information to overseas recipients if necessary to implement your instructions, for example, if you ask us to send information to your overseas tax agent to assist with completing your tax return. These recipients are likely to be located in the United Kingdom and the United States of America.


We will not send personal information to recipients outside of Australia unless:

  • we have taken reasonable steps to ensure that the recipient does not breach the Act and the APPs;
  • the recipient is subject to an information privacy scheme similar to the Privacy Act; or
  • the individual has consented to the disclosure.


If you consent to your personal information being disclosed to an overseas recipient, and the recipient breaches the APPs, we will not be accountable for that breach under the Privacy Act, and you will not be able to seek redress under the Privacy Act.




We recognise the importance of securing the personal information of our customers.  We will take steps to ensure your personal information is protected from misuse, interference or loss, and unauthorised access, modification or disclosure.


Your personal information is generally held in our computer database. Any paper files are stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:

  • passwords are required to access the system, and passwords are routinely checked;
  • data ownership is clearly defined;
  • we change employees’ access capabilities when they are assigned to a new position, if necessary;
  • employees have restricted access to certain sections of the system;
  • the system automatically logs and reviews all unauthorised access attempts;
  • unauthorised employees are barred from updating and editing personal information;
  • all computers which contain personal information are secured both physically and electronically;
  • data is encrypted during transmission over the network; and
  • printing of documents containing personal information is limited.


Where our employees work remotely or from home, we implement the following additional security measures:

  • two-factor authentication is enabled for all remote working arrangements;
  • password complexity is enforced, and employees are required to change their password at regular intervals;
  • we ensure that employees only have access to personal information which is directly relevant to their duties;
  • employees are not permitted to work in public spaces or access our system using public wifi networks;
  • we use audit trails and audit logs to track access to different areas of our client software system by an employee;
  • we monitor access to personal information, and will investigate and take appropriate action if any instances of unauthorised access by employees are detected;
  • employees must ensure that screens are locked when not in use;
  • employees must ensure that no other member of their household uses their work device;
  • employees must store devices in a safe location when not in use;
  • employees may not make hard copies of documents containing personal information, nor may they email documents containing personal information to their personal email accounts; and
  • employees may not disclose an individual’s personal information to colleagues or third parties via personal chat groups.




We may only use personal information we collect from you for the purposes of direct marketing without your consent if:

  • the personal information does not include sensitive information; and
  • you would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
  • we provide a simple way of opting out of direct marketing; and
  • you have not requested to opt out of receiving direct marketing from us.


If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us.  We will draw your attention to the fact you may make such a request in our direct marketing communications.


You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations.  We must give effect to the request within a reasonable period of time.  You may also request that we provide you with the source of their information.  If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.




We will not use identifiers assigned by the Government (such as drivers’ licence numbers) for our own file recording purposes, unless one of the exemptions in the Privacy Act applies.






We are committed to ensuring that the personal information we collect, use and disclose is relevant, accurate, complete and up-to-date.


We encourage you to contact us to update any personal information we hold about you. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge you for correcting the information.




Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information that we hold about you by contacting the Strategic Privacy Officer. We will provide access within 30 days of your request. If we refuse to provide the information, we will provide reasons for the refusal.


We will require identity verification and specification of what information is required.  An administrative fee for search and photocopying costs may be charged for providing access to your personal information.




This Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.




It is the responsibility of management to inform employees and other relevant third parties about this Policy.  Management must ensure that employees and other relevant third parties are advised of any changes to this Policy.  All new employees are to be provided with timely and appropriate access to this Policy, and all employees are provided with training in relation to appropriate handling of personal information.  Employees or other relevant third parties that do not comply with this Policy may be subject to disciplinary action.




Privacy breaches must be reported to management by employees and relevant third parties.  Ignorance of this Policy will not be an acceptable excuse for non-compliance.  Employees or other relevant third parties that do not comply with this Policy may be subject to disciplinary action.




If you have any questions, want to access your personal information or wish to make a complaint about how we have dealt with your personal information you can contact us by:

  • telephoning – (03) 9818 7222
  • by writing to – Strategic Privacy Officer, PO Box 6056, Hawthorn West LPO, Vic, 3122
  • by emailing –


If you are not satisfied with our response, you can ask the Office of the Australian Information Commissioner to consider it by:

  • telephoning – 1300 363 992
  • writing to – Office of the Australian Information Commissioner, GPO Box 5288, SYDNEY NSW 2001
  • emailing –




We ensure that all contractual arrangements with third parties adequately address privacy issues, and we make third parties aware of this Policy.


Third parties will be required to implement policies in relation to the management of your personal information in accordance with the Privacy Act.  These policies include:

  • regulating the collection, use and disclosure of personal and sensitive information;
  • de-identifying personal and sensitive information wherever possible;
  • ensuring that personal and sensitive information is kept securely, with access to it only by authorised employees or agents of the third parties; and
  • ensuring that the personal and sensitive information is only disclosed to organisations which are approved by us.




This Policy contains information about how:

  • you may access the personal information we hold about you;
  • you may seek the correction of your personal information;
  • you may complain about a breach of the Privacy Act, including the APPs; and
  • we will deal with a privacy complaint.