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Privacy Statement

Safeguarding the privacy of our clients is a top priority for us. In alignment with the Privacy Act 1988 (Cth) and our commitment to protecting confidential information, we have established this Privacy Policy. The Privacy Act mandates adherence to the Australian Privacy Principles, guiding the collection, use, correction, disclosure, and transfer of personal information in the financial industry.

If you seek more details on our privacy protection measures, please contact us.

What data do we collect?

Our Privacy Policy outlines our practices regarding the collection, utilisation, and management of personal information, adhering to the Australian Privacy Principles (APP). We gather and retain personal information to provide financial advisory services. This may include:

  • Personal details such as name, age, and occupation
  • Financial information like income, expenses, assets, and liabilities
  • Tax file number (TFN)
  • Information about your partner and dependents
  • Current insurance details

Sensitive information, like health data, is collected only if necessary for financial product and service provision. Failure to provide accurate information may impact our ability to offer appropriate advice.

We are legally obligated to request specific information, such as identity verification documents, to comply with AML/CTF laws.

We will only collect personal information by lawful and fair means, which could include having you complete our Personal & Financial Overview, an application form, or when you give us information by telephone or electronic correspondence. In circumstances where you have specifically authorised us to do so, we may obtain information from a third party you have a professional relationship with, if applicable

We may also collect information from our website for internal purposes but not information that can identify you. This may include the number of users who visit the site, date and time of visits, number of pages viewed and traffic patterns, to assist us with determining usage patterns, so we can make the website easier to use and enable us to better meet the needs of its users. To collect this information we use ‘cookies’, or small computer data files that are saved on your hard drive. These cookies do not contain any personally identifying information and you can also disable the use of cookies on your browser. All information collected via the website will be subject to the same Privacy outlined in this policy.

How do we utilise collected information?

Personal information is employed solely for delivering financial services and advice.

Who receives your information?

We may disclose your information to:

  • Product issuers from who you are investing or taking out an insurance policy with
  • Internal staff of Custodian Financial Group
  • External compliance contractors for the purposes of auditing our financial advice
  • Accountants, solicitors, and professionals with your consent for the purpose of providing services to you related to your financial planning requirements
  • Authorities as required or authorised by law
  • Overseas recipients (such as foreign governments) in compliance with APPs for the purpose of foreign taxation

Will my information be disclosed overseas?

To deliver our services, it may be necessary to disclose your information to organisations located outside of Australia, such as information technology providers or administration hubs. Currently, we utilise the services of a administration service located in the Philippines.

Your personal information may be disclosed, allowing access to organisations whose personnel access our data outside Australia for service delivery. In such cases, please be aware that information is accessed through secure internet connections and, in some cases, via email. We may store your information in cloud or other networked/electronic storage types. External organizations we engage adhere to the APPs and are bound by confidentiality agreements.

Given that electronic or networked storage is accessible from various countries via the internet, it may not always be feasible to determine the specific country where your information is held. If stored in this manner, disclosures may occur in countries not explicitly listed. Overseas organisations might be obligated to disclose shared information under foreign laws, and in such instances, we disclaim responsibility for such disclosures.

We refrain from sending personal information to recipients outside Australia unless:

  1. We’ve taken reasonable measures to ensure the recipient complies with the Privacy Act and APPs.
  2. The recipient is subject to an information privacy scheme akin to the Privacy Act.
  3. The individual has given consent for the disclosure.

Storage of information

We store personal information securely in physical files, financial planning software, and on protected servers. Rigorous security measures are in place to prevent unauthorised access, modification, loss, or disclosure.

All computer-based information is protected through use of firewalls, access passwords and Multi Factor Authentication, where possible. Data is regularly backed up and stored securely off site. All paper files are stored in lockable cabinets. Access to Custodian Financial Group’s premises is tightly controlled and security systems are in place within the building.

It is not appropriate for information about you to be de-identified or destroyed. In order to comply with legislative and professional requirements, we have to maintain our records for a period of up to seven years. After this time and once we consider information is no longer needed, we will securely destroy the records.

Can you access your information?

You have the right to access the personal information we hold about you, with certain legal exceptions. For instance, access may be restricted if it would unreasonably impact the privacy of others. If we decline an access request, we will furnish you with the reasons behind this decision.

Correcting your personal information

We make efforts to ensure the accuracy, completeness, and currency of the personal information we collect, use, or disclose. If you believe any information we hold is inaccurate, incomplete, or outdated, please contact us and provide supporting evidence.

If we acknowledge the need for correction, we will promptly take reasonable steps to rectify the information. In instances where correction is not made, we will furnish you with the reasons for our decision. Should you request, we will attach a statement to the information, affirming its inaccuracy, incompleteness, or lack of currency, and we will diligently adhere to this request.

Contacting us and privacy issues

Feel free to request additional details about how we handle the personal information we hold or to address any privacy concerns, including filing a privacy-related complaint. You can contact us using the provided details below, and we are dedicated to resolving any complaints you may have.


If you still feel your issue hasn’t been resolved to your satisfaction, then you can escalate your privacy concerns to the Information Commissioner by: