Privacy Policy

NATIONAL CAPITAL FINANCE BROKERAGE PTY LTD
ABN 51 008 581 566
(“NCF”)
PRIVACY POLICY
This document sets out NCF’s policy on collection, disclosure, use, storage and handling of personal information.
    
1.    Purpose
1.1.    This purpose of this Privacy Policy is to provide a summary of the personal information that is held by NCF, of why, how and when such personal information is collected, held, disclosed, used, stored and otherwise handled by NCF. The Privacy Policy also sets out access and correction procedures for personal information, complaint-handling procedures and details of cross-border disclosure of personal information.  The Policy relates to personal information collected by any means and by any technology.
1.2.    NCF treats the handling of personal information very seriously. To that end, NCF has systems and procedures in place to protect privacy in relation to the handling of personal information.
1.3.    NCF abides by the Privacy Act 1988 (Cth) (“Privacy Act”) and its objective is to handle personal information responsibly.
1.4.    The Privacy Act provides for an exemption in relation to employee records (being records relating to a current or former employment relationship between NCF and the individual).  Accordingly, NCF is not required to comply with the National Privacy Principles (which may be updated from time to time (“Privacy Principles”) when dealing with employee records.

2.    Collection of Personal Information
2.1.    Personal information is information or opinion from which an individual's identity may be ascertained (“Personal Information”). The nature of Personal Information collected by NCF generally comprises an individual's name, contact details (including address, phone, fax and e-mail) and in some circumstances, financial details. Such Personal Information is collected for the purposes of performing services in accordance with NCF’s business activities.
2.2.    NCF does not collect Personal Information unless it is reasonably necessary for, or directly related to, one or more of its functions or activities.  NCF will destroy Personal Information when it is no longer required for such functions and activities.

3.    Use & Disclosure of Personal Information
3.1.    Personal Information provided to NCF may be shared with related companies where it will be kept strictly confidential and will only be disclosed on a need to know basis.
3.2.    NCF will use and disclose Personal Information for the purpose for which the Personal Information was initially collected.
3.3.    NCF may also use Personal Information for a purpose related to the initial purpose of collection if that other purpose would be within the provider of the Personal Information (“Information Provider”)’s reasonable expectations. Related purposes might include internal auditing and administration or adding a name to a contact list, guest list or invitation list.
3.4.    NCF will not use or disclose a person’s Personal Information for any other purposes without first obtaining express or implied consent from the Information Provider. NCF may however be required to disclose Personal Information without consent if the disclosure is:
3.4.1.    required or authorised by law;
3.4.2.    required in order to investigate an unlawful activity;
3.4.3.    required by an enforcement body for investigative activities;
3.4.4.    required when a person escalates a complaint to NCF’s External Dispute Resolution Scheme; or
3.4.5.    necessary to prevent a serious and imminent threat to a person's life, health or safety, or to public health or safety.
3.5.    Generally, NCF will retain Personal Information within Australia and not use or disclose it overseas. However, on some occasions the Personal Information may need to be transferred overseas in order to perform one of NCF's functions or activities. In these circumstances, NCF will either obtain express or implied consent from the Information Provider and will take all such steps that are reasonable in the circumstances to ensure that the overseas recipient of the information does not breach the Privacy Principles.   NCF will use its best endeavours to ensure that Personal Information will receive protection similar to that which it would have if the Personal Information were in Australia.
3.6.    NCF relies on third party suppliers who are contracted to conduct certain specialised activities. While Personal Information may be provided to these suppliers in order to enable them to perform the agreed tasks, NCF will make every effort to ensure that the supplier handles the Personal Information in accordance with the Privacy Principles.

4.    Direct marketing
4.1.    From time to time NCF may use Personal Information to send a person information regarding NCF’s services and products.
4.2.    If a person does not wish to receive direct marketing information, that person can notify this to NCF using the contact details set out in paragraph 10 and NCF will take immediate steps to ensure that the person does not receive any direct marketing information in future.

5.    Personal Information Quality
5.1.    NCF will take all steps as are reasonable in the circumstances to ensure that all Personal Information collected by NCF is accurate, complete and up-to-date.  NCF will update records upon request if notified and satisfied that Personal Information is not accurate, complete or up-to-date.  NCF will respond to all requests for correction of Personal Information within 30 days of receipt.
5.2.    If the request for correction is refused, NCF will provide written reasons for such refusal.

6.    Personal Information Security
6.1.    NCF is committed to keeping Personal Information secure, and will take all reasonable precautions to protect Personal Information from misuse, interference, loss unauthorised access, unauthorised modification and unauthorised disclosure.
6.2.    Personal Information may be stored in hard copy documents, or electronically on NCF’s software or systems.
6.3.    NCF maintains physical security over its paper and electronic data stores, such as locks and security systems. NCF also maintains computer and network security using passwords to control and restrict access to authorised staff for approved purposes.

7.    Access To Personal Information
7.1.    Any person may request access to the Personal Information NCF holds about them.  Requests should be made in writing and addressed to the Compliance Officer care of the address set out in paragraph 10.
7.2.    In some circumstances, NCF may not be in a position to provide access. If NCF denies access, in accordance with the Privacy Principles, it will provide its reasons in writing.
7.3.    If it is not prevented by law from doing so, NCF will provide access to the individual of his or her Personal Information within a reasonable period after the request is made.  

8.    Changes To This Privacy Policy
8.1.    The Compliance Officer may change this Privacy Policy from time to time for any reason and will update the Privacy Policy accordingly.
8.2.    The Compliance Officer is responsible for monitoring NCF and its representatives’ compliance with this Policy.  

9.    Complaints
9.1.    If Information Providers perceive that their Personal Information has not been dealt with pursuant to the Privacy Principles, they may make a complaint.
9.2.    Any complaints should be directed to the NCF Dispute Resolution Manager in the first instance.
9.3.    If you believe NCF has not adequately dealt with your complaint, you may escalate your complaint to NCF’s External Dispute Resolution Scheme or the Privacy Commissioner.

10.    Contact Details
NCF can be contacted using the following details:

Name:          NATIONAL CAPITAL FINANCE BROKERAGE PTY LTD ABN 51 008 581 566
Address:       Scollay Street
                       Tuggeranong, ACT 2900
Phone:         1800 637 311

Email:           privacy@nationalcapitalfinance.com.au
Website:      www.nationalcapitalfinance.com.au