1. Who we are and what this policy is about.
New Brighton Capital assists its clients in the establishment and administration of self-managed super funds (SMFS). New Brighton Capital provides a range of services to its clients in relation to their SMSF. In the process of providing its clients with the services, New Brighton Capital may collect, receive, deal with and store its client’s Personal Related Information.
New Brighton Capital is committed to safeguarding its client’s Personal Information it collects, receives and discloses and is committed to doing so in accordance with the requirements of the Privacy Act, 1988 Commonwealth (Privacy Act) as amended from time to time.
This policy describes our commitment in relation to protecting our client’s privacy.
2. What information does this policy apply to?
This policy only applies to:
(a) Personal Information including Tax File Number;
(b) Credit Eligible Information;
(c) Credit Information (if relevant); and
(d) Sensitive and or Health Information.
These items are defined in the in the Privacy Act.
Generally speaking, Personal Information is information (or opinion), in any form, about an individual (not a business, company or trust) whose identity is apparent or can be ascertained from the information held whether the information is true or not.
Credit Eligibility Information means information we collect from a credit reporting entity or that has been derived from information that is about the individual’s consumer and or commercial credit worthiness.
Credit Information means information that includes the following.
Sensitive and or Health Information is information we may require or are exposed to when assisting (for example) in insurance related matters as part of the SMSF.
Instead of referring to each of the categories separately, we refer to the categories in aggregation as Personal Related Information. Accordingly, Personal Related Information – for the purpose of this policy includes, as relevant, any information we collect, store, use or disclose which is Personal Information, Credit Eligibility Information, Credit Information and or Sensitive and Health Information.
You do not have to disclose Personal Related Information to us. If you do not agree or do not provide some or all of the information requested, we may not be able to provide you with the services we offer to our clients.
3. Our general commitment
New Brighton Capital undertakes to collect, store and use Personal Related Information only in a manner which is compliant with the Privacy Act.
New Brighton Capital will not use or disclose Personal Related Information other than for:
(b) for a purpose for which the information was provided;
(c) for a purpose required or permitted by law;
(d) a purpose you authorised or is disclosed to you; and
(e) to give effect to your instructions .
New Brighton Capital may collect, store and or disclose information about you to third parties for the following purposes:
(a) To comply with the law;
(b) to obtain a credit report about you (if relevant),
(c) allow the credit reporting agency to create or maintain a credit information file containing information about you.
(d) to provide you with promotional information about services and products we may provide (see section 7);
(e) to manage and administer the agreement with you;
(f) to protect our lawful interests;
(g) to give effect to your instructions;
(h) If we negotiate with a third party the possibility of an acquisition of part or the whole of our business;
(i) to those involved in providing, managing or administering your SMSF product or service;
(j) authorised representatives of New Brighton Capital who advise and/or assist New Brighton Capital in providing you with services;
(k) to better understand the organisations in which you invest, superannuation and managed funds organisations, and their advisers and service providers;
(l) if necessary, to obtain medical advice that relates to the services we provide;
(m) to assist you with any insurance inquiry under your SMSF;
(n) your financial institutions such as banks, credit unions or building societies;
(o) arranging debt collection as relevant;
(p) assisting you to manage the risk of fraud, fraud investigation and prevention;
(q) assisting you in receiving other professional advice such as real estate, financial, investment and insurance;
(r) liaising with any government or regulatory bodies (including Australia Securities and Investment Commission and the Australian Tax Office) as required or authorised by law or by you;
(s) to assist you to secure finance, improve your credit rating, manage risk and or manage investment; and
(t) improving our services to you;
4. Our collection and Disclosure of Personal Information
New Brighton Capital collects and discloses Personal Related Information as it may become necessary to provide you with our services and give effect to your instructions. We will always endeavour to collect Personal Related Information from you directly but sometimes, we are not able to collect the information directly from you and in this case, we may collect information from third parties.
The information we may collect or disclose includes, when permitted by law:
(a) identification information;
(b) general personal information;
(c) investment and financial information including strategy;
(d) the fact that you have applied for credit, the type of credit and the amount;
(e) information from any credit report that may assist our services;
(f) income and other credit related information;
(g) information about court judgments against you;
(h) any information which is publicly available and relevant to your credit worthiness;
(i) certain insolvency information from the National Personal Insolvency Index.
Third Party Service Provider
Subject to the Privacy Act, in the process of providing you with the services, we may share, as relevant, Personal Related Information with related bodies corporate and with third parties with whom we have dealings in the usual course of carrying on our business. These third party service provider may include agents, portfolio managers, mailhouse operators, collection agencies, research providers, dispute resolution schemes, accounting and legal advisers.
We may disclose your Personal Related Information to other organisations, for example:
Additionally, we may disclose your Personal Related Information for the purpose of:
If we disclose Personal Related Information to third parties, we will ensure that these organisations are bound by similar (but not necessary the same) framework of privacy protection as the framework that governs us.
5. Access to your Personal Information
You have the right to seek access to any information we hold about you. Contact our privacy officer in this regards. We may charge you a fee to access and or correct your Personal Information that is held with us. You have the right to ask us to correct any information we hold about you if the information is inaccurate or erroneous.
If we amend you your record, we will notify you of the amendment. If we consider that your request to access your information is unreasonable, frivolous, not necessary, will harm or prevent enforcement action or any other lawful activity by a government or semi government authority, we may decline your request to access or correction of the 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 days’ time frame or the agreed time frame, we must notify you and agree with you an alternative time frame to amend the record.
6. Security of your Personal Information
New Brighton Capital maintains strict procedures and standards and takes all reasonable care to prevent unauthorised access to, and modification and disclosure of, your Personal Information.
New Brighton Capital will protect any Personal Related Information it holds against misuse or loss. If we no longer need the Personal Information, we will take steps to either destroy the information or de-identify it.
7. Direct marketing
New Brighton Capital may use your Personal Information to provide you with information from time to time in relation to additional services and or products we provide. You expressly authorise us to provide you with this information. You may withdraw your consent at any time by calling us.
8. Government identifiers
New Brighton Capital does not have access to any Personal Information that can be regarded as or be used as an identifier. For example, New Brighton Capital does not have access to your Medicare number or tax file number unless you disclose it to us. New Brighton Capital will not use any government identifier that was disclosed to us (such as TFN or Medicare number) to identify you.
If you believe that your Personal Information is been mishandled by us or that we have breached this policy in any way, we invite you to write to our privacy officer at firstname.lastname@example.org. We will make every effort to resolve your complaint internally.
We will acknowledge your complaint within 5 business days of receiving it and we will look to provide a resolution to you compliant within a 30 days’ time frame. If we cannot resolve the matter within the 30 days’ time frame, we will inform you and agree with you on a different time frame to resolve the compliant.
If you are dissatisfied with the resolution, we offered you, you may file a complaint by escalating the grievance to New Brighton Capital’s executive team (CEO) who will endeavour to resolve your complaint expeditiously.
If you are still dissatisfied with our action, you may lodge a complaint with the Australian Information Commissioner (Privacy Commissioner.
The Commissioner can be contacted on
Phone: 1300 363 992
Fax: +61 2 9284 9666
Mail: GPO Box 5218 Sydney NSW 2001
11. Transboarder of data
It is not likely that we will disclose Personal Related Information to overseas entities. If we disclose Personal Related Information to overseas entities, we will provide details on who they are and will ensure that they are bound by similar privacy commitments as we expressed in this Policy.
When you use our website, we may collect statistical data in relation to your use of the site. This date includes the time and date of the visit to the site, the nature of the inquiry and any documents loaded. We may record your browser type and other internet protocols as permitted.
If you disclosed any Personal Information on the site, the information will be governed under this policy. The use of public internet public access to our website is not without risk. If you transmit Persona Information via the internet you should ensure that the transmission is secured.
13. More Information?
Phone: 1300 264 022
End of Policy
New Brighton Capital offers guidance and assistance in the set up of Self Managed Super Funds (SMSF) & the ongoing accounting admin associated with SMSFs.
New Brighton Capital does not offer financial advice, except for the sole purpose of, and only to the extent reasonably necessary for, ensuring compliance with the superannuation legislation and advice on the process of creating ,winding up or exiting an SMSF as per regulation 7.1.29(5) of the Corporations Regulations 2001.
Copyright © 2019 New Brighton Capital - All Rights Reserved. ABN 48623251614.