Privacy and Security

Introduction
What personal information do we collect?
How we collect information
How we use your personal information
Tax File Numbers
Disclosure of personal information to third parties
Access and correction of information we hold about you
Keeping your personal information up to date
Use and disclosure of information
Resolving your concerns
Changes to this privacy statement
Collection of information via website activity
Cookies
Security Statement

Introduction

ComSuper is required to comply with the Information Privacy Principles under the Privacy Act 1988 in the collection, storage, use and disclosure of personal information in its possession. There is also other Commonwealth legislation which protects the security of your information.

This privacy statement explains in general terms how ComSuper protects the privacy of your personal information under the Information Privacy Principles. This statement will apply to any personal information you provide to us:

When you send documents or forms to us
When you access our website
When you contact us by telephone via our contact centre and
At any other time you contact us or provide us with information.

This privacy statement also applies to any information about you that is provided to us by your department or agency on your behalf, or your solicitor, accountant, tax agent or any other authorised agent.

You can also obtain further information from the Privacy Commissioner's website (www.privacy.gov au) or through direct personal contact with that agency.

What personal information do we collect?

The type of personal information we collect depends on the circumstances of collection and on the type of service we are providing to you.

For example, if you or your spouse are/were a member of one of the superannuation schemes we administer, we may have collected details such as your name, date of birth, address, salary, employment details, medical information, tax file number, marital status and previous employment information.

At other times, we may have collected information such as salary changes, bank account details, doctor's reports and date of death. Information will only be collected from you where it is lawful and fair to do so, and where the information collected directly relates to the functions or activities of ComSuper.

How we collect personal information

We may collect personal information when you deal with us over the telephone, send us correspondence (whether by letter, fax or email), join the Australian Public Service or Australian Defence Force, change your employment, visit one of our websites or when you have contact with us in person.

As well as collecting information directly from you, there may be occasions when we collect information about you from a third party, such as:

from your employer acting on your behalf
in invalidity cases - from the Department of Veterans' Affairs, the Department of Defence and treating doctors
in relation to deceased members - from the Registrar of Births, Deaths and Marriages and
from market research companies such as ORIMA, contracted by us to obtain information so that we may improve and market our products and services.

How we use your personal information

We generally collect your personal information to administer our superannuation schemes for the following purposes:

to maintain and record your contributions to your scheme
to allow correct and timely payment of any benefit
to allow us to report to you on the status of your benefit
to allow correct identification of people who fall into a special class of member, such as recipients of spouse or orphans benefits, or limited benefits members
to conduct surveys to evaluate ComSuper's performance
to provide information to CSS, PSS and PSSap members about State Super Financial Services (SSFS) which provides financial planning advice.

Some of the personal information we collect is essential for us to be able to accurately carry out the service required of us. Other types of personal information we collect helps us to profile the needs of our members and what improvements can be made to our services.

Tax File Numbers

Tax File Numbers are only used where permitted by law. Tax File Numbers are stored in a way that prevents their access by staff except where required to fulfil the request of a client.

Disclosure of personal information to third parties

General principles

We will disclose your personal information under the following circumstances:

with your consent
when it is reasonably expected that you are aware that the information is usually passed to that person, body or agency
to prevent a threat to life or health
when authorised or required by law
when reasonably necessary to enforce the criminal law or of a law imposing a pecuniary penalty or for the protection of the public revenue.

State Super Financial Services

State Super Financial Service (SSFS) is an investment of the ARIA Board which allows members to take up the opportunity to access professional responsible financial planning advice.

In order to give members an understanding about the various products being offered by SSFS, members who have given their consent will be provided with information from time to time. An opt out provision is available to anyone not wishing to receive the information.

If a member wishes to take advantage of the products available from SSFS, with the member's agreement some personal information will be provided to SSFS in order to comply with such a request. Again a member can opt out at any time from receiving information directly from SSFS.

Family law

Under the Family Law Act 1975 (as amended), ComSuper must provide information about the member's superannuation interest to assist the parties in negotiating a property settlement. This information may be requested by:

the member
the spouse of the member or
a person who intends to enter into a superannuation agreement with the member.

The information provided by ComSuper is used to calculate the value of the member's superannuation interest.

Before ComSuper will release any information regarding the member's superannuation interest for family law purposes, the member or non-member spouse must lodge a Form 6 application and declaration.

Family law matters are also covered by the usual Privacy legislation requirements that apply to members. The family law legislation also prohibits ComSuper from providing any indication to the member that a request for information has been made by the non-member spouse. Release of the member's address, including postal address, to the non-member spouse is also prohibited.

Surveys

ComSuper monitors and evaluates its performance against the standards set out in the Service Charter.

To continually improve our service we have commissioned an independent firm, ORIMA, to assess our performance against those standards.

For this purpose your name, address and telephone number may be passed to ORIMA to undertake random surveys.

These surveys may take the form of a telephone survey or a written request for your feedback, should you choose to participate. An opt out provision is available to anyone not wishing to participate in a survey. However, your valuable feedback is always appreciated.

The information collected will only be used to evaluate ComSuper's performance and ORIMA are required to protect all details collected under the provisions of the Privacy Act 1988.

Contractors

We may have to disclose your personal information to third parties, such as to contractors to whom we contract out certain services. For example we currently engage third party contractors to:

print and distribute annual statements and pension increase advice letters
provide programming services and
provide internal audit services.

In these and all other situations, we prohibit the third party contractor from using personal information about you except for the specific purpose for which we supply it. Contractors are required to agree to uphold the Information Privacy Principles.

Access to and correction of personal information we hold about you

In the unlikely event of an investigation, a law enforcement agency or other government agency may exercise its legal authority to inspect our Internet Service Provider's logs and ComSuper's logs.

We will, on request, under the Freedom of Information Act 1982, provide you with access to the information we hold about you, including for the purpose of correcting or updating that information.

In most circumstances, no charge will be incurred for releasing your personal information. If we do impose a fee, this will be based on the fees and charges set out in the Freedom of Information Regulations.

Your request to access information will be dealt with in a reasonable time.

If we refuse to provide you with access to information, we will provide you with reasons for the refusal and details of your appeal rights. Requests for the release of information should be sent to the Freedom of Information Officer. See 'Contact us'

Keeping your personal information up to date

We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it.

If the personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us and we will take reasonable steps to either correct this information or, if necessary, discuss alternative options with you.

Use and disclosure of information

Personal information provided to ComSuper when you send us a message will only be used for the purpose for which you have provided it. Your details will not be added to a general mailing list. Unless required or authorised by law, ComSuper will not disclose this information without consent.

Resolving your concerns

If you wish to gain access to your personal information, have a complaint about a privacy issue or wish to query how your personal information is collected or used, please forward your request, complaint or query to the relevant contact. See 'Contact us'.

Changes to this privacy statement

We may amend this privacy statement as our business requirements change or as the law changes. Any changes to this privacy statement will be updated on this website, so please visit this website periodically to ensure that you have our most current privacy statement.

Collection of information via website activity

When you visit our website

Each time someone visits one of our sites, we collect the following types of information:

how often the site was used
the time of day the site was accessed
what browser types are being used.

No attempts are made to identify anyone browsing our site. The data is captured so that we can accurately evaluate the quality of our content and make improvements.

When you use Member Services Online

The type of information we collect from you will depend on what part of Member Services Online you use. When any of these services are used, we will collect and hold your Access Number or user ID and details of all transactions. Details of these transactions will be stored to validate transactions against your computer record.

Access Numbers allow members secure access to Member Services Online where they can:

view their member statements
change their contact details
use our online calculator, the i-Estimator, and
for members of the Military Superannuation and Benefits Scheme, elect for Member Investment Choice.

In order to maintain the security of this service, ComSuper has a statutory responsibility to all members to ensure their Access Numbers are not disclosed to unlawful recipients. Therefore, we provide Access Numbers to members only after we are sure that they are the lawful recipients. To do this, we require members to apply for new or replacement Access Numbers in writing, either by fax or post. All applications must also contain the member's signature, AGS/Service number and current postal address.

As a further security measure, new or replacement Access Numbers will only be valid for a period of 60 days from the date of issue. If the Access Number is not activated within that time, it will expire.

When you email us

ComSuper records your email address but it is used only for the purpose for which it was provided.

Cookies

Cookies are pieces of information that a website can transfer to your computer's hard drive. Parts of this website use a temporary 'session cookie' to maintain the users current authenticated connection. The cookie does not contain any information about the user or their PC. The cookie becomes invalid as soon as the user closes their browser or their session times out.

Security statement

Commonwealth laws protect your personal information. These laws prohibit any person from accessing, using or disclosing any personal information in the possession of ComSuper unless it is in the performance of their duties or is in accordance with these laws. Penalties apply for failure to observe these provisions.

When using online services all information passing between your personal computer and the secure section of our website is encrypted using Secure Socket Layer (SSL).

While we endeavour to provide a secure Internet environment, users should note that there are inherent risks associated with the transmission of information via the Internet. We provide alternative means of communication including direct contact via telephone, facsimile, post or face-to-face meetings. See 'Contact us'

Last updated January 28, 2010