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We are bound by the Privacy Act 1988 (Cth) (the Privacy Act), which sets out a number of principles concerning the collection, disclosure and management of your personal information.
We may collect and hold the following types of personal information about you:
- Your name.
- Your contact details such as your email address, postal or home address and phone numbers.
- Your date of birth.
- Your profession, qualifications, occupation or job title and rank.
- Your dependant information, including gender and date of birth (if applicable).
- Your special needs information relating to you and/or any of your dependants (if applicable).
- Your financial institution / bank details.
- Your tax file number.
- Identification documentation such as passport or driver’s licence details.
- Details of shareholdings or other financial or beneficial interests, and
- Any other personal information you include in any form or other document you provide to us.
We will generally collect your personal information directly from you unless it is unreasonable or impracticable to do so. We will also collect your personal information from someone else with your consent or where we are required or authorised to do so by or under an Australian law or a court/tribunal order. When collecting personal information from you, we may collect your personal information in circumstances including:
- through your access and use of our website and/or apps
- during conversations between you and our employees
- via telephone or paper based surveys conducted by a representative of DHA
- when you enter into a contract with us (for example, to purchase a property or provide a service to us or on our behalf)
- from any regulator
- from your financial adviser, and
- when you make an enquiry or complete an application and/or registration.
We may also collect personal information from third parties including third party companies such as marketing and advertising agencies, credit reporting agencies, law enforcement agencies and other government entities.
We may collect other information when you access and use our website. For example, we may collect your server address, browser type, version and language, operating system, pages viewed and documents downloaded while browsing our website, page access times and referring website addresses. However, we do not link this information to your personal information and use it only to improve the experience of users of our website. No attempt will be made to identify you based on this information except, in the unlikely event of an investigation by a law enforcement agency or where we are required to do so by court order.
Personal information collected by us is securely held either in hard copy format on DHA paper files or stored electronically on DHA’s file servers.
We use Survey Monkey (a third party software supplier) to administer online surveys. Survey Monkey use third party cookies. The information collected by these cookies is not capable of identifying you and is only used to ensure our surveys run smoothly. We will only use the information collected from the surveys for statistical and maintenance purposes.
If you do not provide us with personal information as described above:
- we may not be able to provide the requested services to you, either to the same standard or at all
- we may not be able to provide you with information about our products and services that you may want
- we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful, or
- we may cease to provide our services to you or otherwise retain you as an investor.
We collect, hold, use and disclose your personal information for the following purposes:
- To contact you in response to an enquiry by you about our products or services.
- To perform our business activities and functions and to provide the best possible quality of customer service.
- To provide you with access to any protected areas of our website.
- To assess the performance of the website and to improve its operation.
- For recruitment and personnel management purposes (in relation to DHA employees and potential employees).
- For marketing (including direct marketing), planning, product or service development, quality control or research purposes for us and our related bodies corporate, contractors or service providers.
- To provide your updated personal information to our related bodies corporate, contractors or service providers for the performance and administration of our business operations.
- To respond to any communications from you or complaints made by you, and
- To comply with any law, regulation or binding decision of a regulator.
We may send you direct marketing communications and information about our services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth).
If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time, you may opt-out of receiving marketing materials from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list. We do not provide your personal information to other organisations for the purposes of direct marketing.
We may disclose your personal information:
- to our employees, related bodies corporate, contractors or service providers in the ordinary course of processing and storing your personal information and in the course of maintaining, updating or replacing the systems on which your personal information is stored
- as required or authorised by or under applicable laws or rules, such as the Privacy Act, Defence Housing Australia Act 1987 (Cth) and the Public Governance, Performance and Accountability Act 2013 (Cth), or
- to your nominated representative with your permission.
You have a right to access your personal information unless we are entitled to refuse access on grounds permitted under the Privacy Act. Those grounds are that access may be refused where such refusal is required or authorised by the Freedom of Information Act 1982 (Cth) (FOI Act) or another Commonwealth Act providing for access to documents. If you would like to access the personal information we hold about you, please let us know by contacting us via our contact details below. You may be required to complete a subject access request form and to prove your identity for security reasons.
You may also request us to correct any personal information that you believe is not accurate, up to date, complete or relevant or is misleading. We will take reasonable steps to make that correction.
We will not charge you for making a request to access or giving access to your personal information and we will not charge a fee for correcting your personal information.
If we do not give you access to your personal information or decide that we will not correct your personal information, we will provide you with written reasons for our decision within 30 days after the request is made.
The FOI Act also provides mechanisms for seeking access to, and the correction of, personal information. For further information about making an FOI request to DHA please go to Freedom of Information. Further information about the relevant operation of privacy and FOI laws in this context is available from our Privacy Contact Officer.
We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure.
You should be aware that there may be inherent risks associated with the transmission of information over the internet. If you are submitting personal details or other information over the internet which you wish to remain private, please note that, while all attempts are made to secure information transmitted to this website, there is a possibility that information you submit could be observed by a third party while in transit.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
If you believe that we have breached our obligations under the Privacy Act in respect of your personal information, you may contact us via the contact details below.
On receiving your complaint, we will investigate your complaint within a reasonable time. We will deal with your complaint confidentially. As part of that investigation, we may ask you for further information and may also ask you to provide us with details of your complaint in writing so that we can better understand the precise nature of your complaint.
Our Privacy Contact Officer will assist you with your complaint. In most cases, our Privacy Contact Officer will respond to you in writing (by letter or by email). If you believe that the Privacy Contact Officer’s decision or response is not correct in some respect, you may provide details of the claimed deficiency and ask the Privacy Contact Officer to further consider the issue. After the Privacy Contact Officer further responds, and if you remain unsatisfied, you may escalate the matter to DHA’s Company Secretary.
Under the Privacy Act, the Australian Information Commissioner has the power to investigate complaints, or acts or practices that may be a breach of privacy even if there is no complaint. If you make a complaint to DHA about a DHA practice which you think amounts to an arbitrary or unreasonable interference with your privacy and you do not believe that the matter has been resolved satisfactorily, you should write to the Office of the Australian Information Commissioner (OAIC), preferably using the online Privacy Complaint form available on the OAIC website.