PRIVACY POLICY

2.1 TYPES OF INFORMATION

We may collect the following kinds of personal information about members, beneficiaries or potential beneficiaries, claim participants, advice clients and other people who interact with us:

• name;

• address;

• email address;

• phone number;

• date of birth;

• Tax File Number;

• employment details (including salary information);

• bank account details;

• your superannuation contributions; and

• the name of beneficiaries.

In some situations, we may need to collect sensitive information, such as health information or membership of a trade union or professional association.

For employees, employment candidates and individual contractors, we may also collect personal information during the recruitment process about your employment history and about any pre-existing injuries or illnesses that may prevent you from performing the inherent requirements of a position. The following additional personal information may be collected after you have accepted an offer of employment or entered into an engagement agreement with us:

• professional licences / certifications;

• academic transcripts;

• Tax File Number;

• identification documents (e.g. passport and driver’s licence details);

• bank account details;

• superannuation details; and

• criminal history checks and health or medical information.

Without limitation, we are authorised under various laws, including the Superannuation Industry (Supervision) Act 1993 (Cth), Corporations Act 2001 (Cth), Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) and the Insurance Contracts Act 1984 (Cth), to collect personal information about you.

2.2 HOW INFORMATION IS COLLECTED AND HELD

Personal information is generally collected directly from you, however in some circumstances may be provided by a third party, such as an employer, agent, previous superannuation fund, organisations we use in managing the Fund (for example insurers or organisations engaged to conduct member surveys for us) or other representative (as authorised by you).

We collect personal information from you in many ways including through forms and applications, use of our website, telephone conversations, personal interaction, email and other correspondence.

We may receive salary information from you or from your employer which may be used for income protection insurance purposes. Salary information may also be used to assist in analysing and understanding membership demographics and for developing appropriate and/or targeted products and services for members. From time to time, we may require you to provide your Centrelink Customer Reference Number for the purposes of validating whether you are entitled to the early release of superannuation on the ground of financial hardship.

We may collect health information to enable you to obtain insurance cover or to process an insurance claim. This may be collected from you directly or from a medical practitioner in accordance with your signed authority.

For employees, employment candidates and individual contractors, we will collect personal information during the recruitment process and after you have accepted an offer of employment or entered into an engagement agreement with us. This information may be collected directly from you or through recruiters or recruitment agencies.

Personal information may be held and stored by us or our Administrator electronically within our secure electronic network, servers and cloud service providers. It is also held in hardcopy form, for example, in paper files. The Group takes all reasonable steps to ensure that the personal information held by the Group is kept confidential and secure, including the implementation of technical and organisational measures.

Hardcopy files containing personal information are archived in a secure offsite archiving facility. Personal information contained in electronic form is secured by encryption and firewalls which are in line with Australian information security practices.

Various levels of access restrictions, systems and passwords are used to protect the personal information held on our systems and the systems of our Administrator.

2.3 PURPOSES OF COLLECTING AND HOLDING INFORMATION

We collect personal information for the purposes of:

• opening and administering superannuation and retirement accounts, including insurance entitlements;

• providing financial advice and education;

• managing and resolving complaints;

• ensuring members are eligible for products and services (such as insurance);

• undertaking market research and direct marketing activities;

• running promotions and competitions; and

• complying with relevant laws including reporting information required by law or regulations.

For employment candidates, the Group collect personal information for recruitment purposes, to manage an employment application and if successful, manage the ongoing employment arrangements with the individual.

If you do not provide all of the necessary personal information or, where relevant, do not allow your employer to do so, we may not be able to perform the functions listed above. For example, if you submit incomplete or inaccurate information, we or our Administrator may not be able to accept contributions or provide products and services that best meet your needs.

2.4 ANONYMITY AND PSEUDONYMITY

In certain circumstances, you may be able to deal with us without providing your personal information (either anonymously or by using a pseudonym). We will give you the option of remaining anonymous, unless your personal information is required by law, or it is not practicable to deal anonymously (or through a pseudonym).

Typically, if you are requesting general information, you may do so without providing your personal information. However, if you have specific account or insurance enquiries, you will need to provide your personal information so the service can be provided to you.

3.1 USE AND DISCLOSURE

In undertaking our obligations to you, we may disclose your personal information to third parties as required by law or where appropriate and as reasonably expected by you. For example, we may disclose personal information:

• to the Administrator, which acts as agent of the Trustee for the administration of the Fund and your account;

• to anyone you have asked or allowed us to send your personal information to;

• to government regulators and departments, including the Australian Taxation Office, the Australian Prudential Regulation Authority, the Australian Securities and Investments Commission, the Australian Transaction Reports and Analysis Centre and the Office of the Australian Information Commissioner;

• where there is a complaint, the Australian Financial Complaints Authority;

• third parties that provide us with specialist or professional services, such as mail houses, market research and survey organisations, IT companies and auditors;

• to another superannuation fund where you seek to transfer to that fund;

• if you have insurance, TAL Life Limited (ABN 70 870 050 109 450 AFSL 237848. Our insurer may also pass your personal information to claims investigators, medical practitioners and other organisations who the insurer outsources its functions as set out in the relevant insurer’s privacy policy or statement. Our insurer’s privacy policy is available at www.tal.com.au/privacy-policy or available on request;

• to authorised financial advisers for the purposes of receiving financial advice;

• in limited circumstances, your employer;

• in family law matters, your spouse;

• in respect of employees, employment candidates and individual contractors, to recruiters or recruitment agencies who are acting on your behalf; and/or;

• to other parties as required or permitted by law.

Where personal information is disclosed, we will seek to ensure that the information is held, used or disclosed consistently with the APPs and other applicable privacy laws and codes.

The personal information collected may be used or disclosed by us for a secondary purpose related to the purposes described in section 2.3 of this Policy if you would reasonably expect us to use or disclose the information for this secondary purpose, or as otherwise permitted by the APPs.

3.2 DISCLOSURE OVERSEAS

We may provide personal information to recipients who may be based in or have severs located outside of Australia. We (and some of our service providers) may also use cloud platforms which are based in overseas locations, including the USA, the European Union and Singapore.

We will only disclose personal information to third parties who may be based in or have servers overseas if:

• we have taken reasonable steps to ensure the overseas recipient is compliant with the APPs;

• we reasonably believe that the overseas recipient is subject to a law or binding scheme that are, overall, substantially similar to the APPs (and can be enforced);

• the overseas recipient is subject to a law or binding scheme that are prescribed by regulations as providing substantially similar levels of protection as the APPs; or

• we are required to disclose the personal information by order or an Australian court or tribunal.

If you would like any information on what we send overseas, the controls we have over the data and the protections that are in place, please contact our Privacy Officer.

4.1 USE OF COOKIES

We may use cookies and other digital identifiers to improve our website’s functionality and to allow it to improve your interactive experience. When you visit the website, details about the visit, such as time and date, pages accessed, duration of visit and type of browser may be recorded. This information is collected for statistical purposes and to help provide relevant information to you. For instance, we may use cookies to learn more about the way you interact with our content and help us to improve your experience when visiting our website or having other contact with us. By using the website, you agree to our use of technology of this type. If you do not wish to receive cookies, you can configure your preferences and options in your browser to reject cookies, however this may mean that parts of our website may not work as it should.

Personal information will not be recorded unless personal information is provided by the user through the completion of a web form.

4.2 LINKS TO OTHER SITES

You may be able to access external websites by clicking on links provided on our website. Those other websites are not subject to our privacy standards, policies and procedures. Those websites may contain cookies, and you should review the third party’s privacy policy on cookies and other privacy issues.

One of the purposes for which we collect personal information is to inform you of products and services available to you as a member of the Fund.

If you do not wish to receive direct marketing material, you may opt out of receiving it. You may also request that we not facilitate direct marketing by a third party. Further, you may request that we notify you of where we obtained your information, which we will do unless it is impracticable or unreasonable to do so.

You have a right to access your own personal information under the APPs; however, your identity will need to be verified before access to your personal information is granted. Where costs are incurred for providing access to personal information, we may charge need to charge you for the associated costs.

We will respond to a request for access to personal information within a reasonable period after the request is made, by either providing you access or notifying you of our refusal to give access. In some circumstances, we may not allow access to personal information, such as where:

• the information would reveal a confidential or commercially sensitive decision making process;

• the information relates to existing or anticipated legal proceedings;

• where the privacy of others may be breached if the information was accessed; or

• where the law requires or authorises such access to be denied.

The Privacy Officer will advise if any of these circumstances apply.

If the information held by us is inaccurate, incomplete or not up to date, you may request that we correct the information.

If you are concerned about a possible interference with privacy, a breach of this Privacy Policy, or a breach of the APPs, you should contact our Privacy Officer.

If you wish to make a complaint, please go to our Lodging a complaint page.

If your concerns are not resolved to your satisfaction, the matter can be referred to the Office of the Australian Information Commissioner on 1300 363 992 or oaic.gov.au.

If your concerns relate to a superannuation or financial advice matter, the matter can be referred to the Australian Financial Complaints Authority on 1800 931 678 or afca.org.au.

Name: Privacy Officer

Street address: 168 Parry Street, Newcastle West NSW 2302

Postal address: PO Box 9, Newcastle NSW 2300

Phone: 02 4948 3333 or 13 64 63

Facsimile: 02 4962 3469

Email: privacy@teamsuper.com