Privacy policy

Introduction

This privacy policy applies to Liston Newton Advisory Pty Ltd (ACN 112 694 658) and its Related Entities and Related Bodies Corporate, as defined under the Corporations Act 2001 (Cth) (together LNA, We, Us) in relation to LNA’s operations in Australia. The LNA Privacy Policy sets out how we may collect, store, use and disclose your personal information. Your privacy is important to LNA and we are committed to handling your personal information in a responsible way in accordance with the Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles in the Privacy Act.

Cookies

Cookies are small files that are placed on your device by websites which collect information about your use of those websites. 

LNA uses cookies for various purposes including:

• Determining if your browser has previously visited the website; and
• remembering your settings/preferences and tracking and reporting on website usage.

You can choose to change your browser’s cookie settings via your browser privacy settings, including blocking the use of cookies. If you choose to delete or block cookies, your experience on our website may be limited.

What Information will LNA collect about you?

LNA collects and holds personal information from clients, customers, employees, job applicants, suppliers, contractors and other individuals necessary for business purposes.  

The main types of personal information LNA may collect and hold includes:

• an individual’s name, address, e-mail address, phone numbers, date of birth, emergency contact details and other similar contact or identity details;
• investment details, payroll details, taxation details, banking details, job titles and other accounting and financial services related information regarding an individual; and
• information about an individual’s financial circumstances and objectives, including the individual’s assets, liabilities, income, expenditure and investment preferences.

Generally, we do not collect sensitive information about individuals (e.g., information about your health, racial or ethnic origin, political views etc) and if we do need to collect such information, we will only do so with your consent or where we are required to do so by law.

How do we collect information?

LNA collects most information directly from you when we deal with you. The personal information LNA collects may be provided in forms filled out by you, face to face meetings, where you use our websites or other online services, email messages, telephone conversations or if you post on our social media sites. If you contact LNA, a record of that contact may be kept. We may also from time to time collect information about you from a third party, such as your other advisors or from publicly available databases or registers.  On all occasions, your information is collected, held, used and disclosed by us in accordance with this Privacy Policy.

The nature of the services provided by LNA may limit us from allowing the use of pseudonym or otherwise dealing with you on an anonymous basis (including where it is not practical to do so or where we are required by law to deal with identified individuals).  

How do we use your information?

LNA collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities. If you choose not to provide us with personal information, LNA may be unable to perform such business functions and activities. Some examples of the purposes for which LNA collects, holds, uses and discloses your personal information include:

• enable us to supply you with information you request from us;
• supply our services to you, including our accounting and other financial advisory related services;
• to manage and improve our website;
• personalise your experience with our services; undertake direct marketing (as detailed below);
• analyse information we collect so that we can administer, support, improve and develop our business and the products and services we offer; and
• comply with the obligations of LNA under any applicable laws.

LNA may collect, hold and use personal information about individuals to market its services, including by email. However, individuals always have the opportunity to elect not to receive further marketing information from LNA by contacting our Privacy Officer (see the contact details below). Please allow for 28 days for your request to be processed. Alternatively, if LNA contacts you by email, you may use the unsubscribe function in that email to notify LNA that you do not want to receive further marketing information by email.

LNA will only use your information for the purpose for which you provided it to us, related purposes, the purposes set out in this Privacy Policy and as permitted or required by law.

In addition to the purposes listed above, LNA may use your personal information for other purposes which we notify you of when we collect the information.

How will your information be disclosed?

Staff of LNA will have access to personal information in relation to client matters, for use in the provision of services to LNA clients. Other LNA staff will have access to personal information relevant to the performance of their roles and tasks.

LNA only discloses your personal information for the purpose for which LNA collects it. That is, generally, LNA will only disclose your personal information for the purpose carrying out our business functions and activities. This may include disclosing your personal information to third parties engaged to perform administrative or other business management services or to other organisations such as:

• A client’s personal financial advisor and their service provider;
• Individuals or organisations that are your representatives including a client’s legal advisors;
• Organisations authorised by Federal or State legislation;
• Other organisations where a client has given their express consent;
• The Australian Tax Office;
• The Australian Securities and Investments Commission;
• Off-site third-party organisations providing storage and archiving services; and
• Other third parties as required by us in performing the functions and activities of the service.

This disclosure is always on a confidential basis or otherwise in accordance with law. LNA may disclose your personal information with your consent or if disclosure is required or authorised by law.

Overseas disclosure

Our business is affiliated with other businesses located overseas. In the course of doing business with you, we may disclose some of your personal information to overseas recipients. However, we will only do so where:

• It is necessary to complete the transaction you have entered into; and
• You have provided consent; or
• We believe on reasonable grounds that the overseas recipient is required to deal with your personal information in a way that complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme; or
• It is otherwise permitted by law.

At present, some of our network entities may exchange data with our overseas affiliate located in India and the Philippines. However, any such exchange does not change any of our commitments to safeguarding your privacy and the data remains subject to existing confidentiality obligations.

How is your personal information secured?

LNA will take reasonable steps to keep secure any personal information which it holds about you, whether electronically or in hard-copy, and to keep this information accurate and up to date.

LNA utilises a range of procedures to protect your personal information. These may include:

• Security procedures within our offices and associated with access to our business premises;
• IT systems designed to ensure personal information is only available to those staff who require access;
• IT security procedures including Spam and Virus protection, firewalls, intrusion detection and site monitoring; 
• Mandatory confidentiality guidelines for all staff and data processors within the business; and
• Requiring any third-party providers to have adequate security measures.

We will retain your personal information whilst it is required for any of our business functions, or for any other lawful purpose and we will also retain your personal information for the time periods required by law. Personal information no longer required to be retained by us will be deleted or destroyed in accordance with our document deletion and retention policies and procedures.

Access by you to your personal information

LNA will provide access to personal information held by LNA upon request, except in limited circumstances in which it is permitted to withhold this information (for instance, where granting access would infringe on another person’s privacy). Where restrictions exist on our ability to provide you with access, we will advise you of those reasons at the time of your request.

Should you wish to view the personal information that we hold about you, you should contact the member of staff responsible for your file or the Privacy Officer of LNA, and request a “Personal Information Access Form”. We will require you to verify your identity.

While we do not charge a client for making a request to access their personal information, LNA may charge an administration fee for time and cost in the following circumstances:

• Staff costs: if an extended amount of time is required in searching for, locating, retrieving, collating, and preparing the material; and
• Costs associated with using an intermediary.

Any charges for accessing the information will be advised prior to commencement (estimated time and cost).

Accuracy and correction of your personal information

If you wish to advise us of changes to the personal information we hold, please contact your LNA representative by phone, email, mail or fax, and we will amend your file accordingly.  In certain situations, we may not agree to a request to correct information we hold about you. If this occurs, we will advise you of this and our reason for not agreeing to the correction request and you have the right to complain about the refusal in the manner set out below.

If you wish to have your personal information deleted, please contact the Privacy Officer and we will take reasonable steps to delete it (unless we need to keep it for legal, auditing, or internal risk management reasons).

Notifiable Data Breaches

LNA complies with the amendments to the Privacy Act, effective from 22 February 2018, in relation to notifiable data breaches and has an updated plan to ensure compliance with the new requirements, including notification of the Australian Information Commissioner and affected individuals of certain types of data breaches, and is able to promptly respond to any suspected data breaches. A notifiable data breach happens when there is unauthorised access to, unauthorised disclosure of, or loss of, personal information which is likely to result in serious harm to the individual to whom the information relates.  

What you can do if you have a complaint?

If you believe that LNA has breached one or more of its privacy obligations, your complaint (including a summary of the privacy concern or alleged breach and copies of any relevant documentation) should firstly be addressed to our Privacy Officer:  

The Privacy Officer
‍Liston Newton Advisory
246 Glenferrie Rd, Malvern VIC 3144‍

E: data.notification@listonnewton.com.au 
T: 61  3 9069 2605

Our Privacy Officer will investigate the complaint and will endeavour to respond within a reasonable period after the request is made (not exceeding 30 calendar days). If the matter proves to be more complex, we will advise you of a revised response timeframe in writing.

If you are not satisfied with the response from our Privacy Officer, you may refer your complaint to the Office of the Australian Information Commissioner. 

The Office of the Australian Information Commissioner

T: 1300 363 992
E: enquiries@oaic.gov.au
www.oaic.gov.au/privacy

Privacy Policy Updates

This Privacy Policy is not a static document. LNA may from time to time make changes and update this Privacy Policy. The most current LNA Privacy Policy will always appear on our website.

The amended policy will apply between us whether or not we have given you specific notice of any change.

This policy was last updated May 2023.