1 Purpose
1.1 MORE Super Superannuation Pty Ltd ("MORE Super") is an experienced and exclusive provider of comprehensive SMSF services.
1.2 MORE SUPER Super necessarily collects and stores financial and personal details in order to provide a holistic range of self-managed super fund (SMSF) compliance related services. MORE Super manages this personal information in an open and transparent way, operating in the spirit of the Privacy Act 1998.
1.3 What follows is an outline of MORE Super's Privacy Policy. It is strongly recommended that you and/or your firm familiarise yourself with the following policy and direct any questions you may have regarding the policy to our team prior to engagement.
2 Types of Personal Information Collected and Held by MORE Super
2.1 The Privacy Act 1998 defines personal information as information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. This is a broad definition and may include a broad manner of types of personal information.
2.2 Personal information collected and held by MORE Super can include, but is not necessarily limited to the following:
a. Tax File Number, Australian Business Number/s, Australian Company Number/s and employment details;
b. Trust Deed and related details;
c. Company incorporation details, including details of directors;
d. Banking and/or other financial institution details and correspondence;
e. Personal contact information;
f. Related engagement with the Australian Taxation Office (ATO);
g. Financial strategy and goal information; and
h. Familial details.
3 Collection and Storage of Personal Information
3.1 The Privacy Act 1998 considers the collection of personal information to occur if an entity collects the personal information for inclusion in a record or generally available publication.
3.2 MORE Super collects personal information directly and indirectly for the proper performance of actual SMSF service offerings or in anticipation of potential engagement. This is MORE Super's purpose in collecting and storing personal information. This personal information may also be used to assess the accuracy of feedback and generate general and unattributable business metrics to measure and enhance performance.
3.3 Whilst MORE Super does have some direct clients, the firm typically engages with Financial Planners and Accounting Firms who provide MORE Super with the categories of personal information above. MORE Super may request additional personal information from the intermediary (Financial Planner or Accounting Firm) or directly of the client, depending on engagement requirements, where necessary for the proper undertakings of the stipulated service provision. This may happen at any time during the period of engagement. Any intermediary providing personal information to MORE Super must do so with the informed consent of the ultimate client.
3.4 MORE Super may receive some personal information from the ATO, as part of its normal compliance related business activities for engaged clients.
3.5 MORE Super may also request personal information from a non-engaged entity in order to be able to better contemplate engagement or respond to a query.
3.6 Failure to provide personal information required by MORE Super may result in:
a. Delays in service provision, engagement or responses; and
b. Non-engagement or discontinued engagement
3.7 The Privacy Act 1998 considers the holding of personal information to occur where an entity has possession or control of a record that contains the personal information. As MORE Super is a largely a paperless business, all personal information is held electronically.
3.8 Personal information collected by MORE Super, either directly or indirectly or actual or potential use, is stored on a server located in Australia.
4 Access to Personal Information
4.1 All personal information held by MORE Super is accessible by currently engaged intermediaries and direct clients via the Client Portal. For MORE Super instructions on how to access the Client Portal contact MORE Super. This personal information can be updated by the intermediaries (with the fully informed consent of the ultimate client) and direct clients at any time. If you are encountering difficulties updating this personal information, please contact MORE Super at your earliest convenience. If at any time you are concerned that the personal information provided by you has been compromised, please contact MORE Super.
4.2 Personal information provided to MORE Super by non-engaged entities in order to facilitate a query response or in contemplation of engagement will not be stored on the Client Portal. Entities wishing to access, update or correct such personal information provided to MORE Super should submit a query to MORE Super Super.
5 Disclosure to Overseas Recipients
5.1 At MORE Super, we value diversity and our team includes talented and highly skilled people from across a number of locations. In fact, staff members are based in Australia, India and Germany. Disclosure of personal information to those overseas staff is necessary for the proper performance of MORE Super's SMSF compliance function.
5.2 Offshore operations is not a compromise of quality or our commitment to observing privacy and confidentiality principle.
6 Conclusion
6.1 If you would like a hard copy of this policy, please contact MORE SUPER Super. Please provide your mail contact details.
6.2 If you have any complaints about the way your personal information, or that your client, is collected, stored or used by MORE SUPER Super, please do not hesitate to contact MORE SUPER Super. MORE Super Super endeavours to respond within a reasonable timeframe.