Vision Super is committed to upholding the Australian Privacy Principles covering the collection, use, storage, and disclosure of personal information. Personal information is information or an opinion about a person (whether true or not) which could identify a person.  It includes information such as name, date of birth, address.

How we collect and hold your personal information

All personal information is collected by lawful, fair and reasonable means and only for the purposes of establishing and maintaining member accounts, providing, protecting, assessing, reporting, paying superannuation and insurance benefits, and associated services such as general and personal financial product advice in relation to those benefits. We do not collect unnecessary personal information or collect medical information about you without your consent. We will generally collect personal information directly from you.  Sometimes we collect from a third party such as your employer, adviser or previous superannuation fund. Vision Super makes every effort to protect personal information from misuse, loss, unauthorised access, modification or unauthorised disclosure. If you request it, we will give you access to your records for the purposes of verification or correction. There are certain exceptions to this, which include where it would be illegal to do so, or where giving access would have an unreasonable impact on the privacy of other people. Other than as permitted or required by law, Vision Super will not disclose or use personal information for any purpose other than that for which the information is collected. In the course of conducting our normal business activities, Vision Super collects, records, maintains and uses personal and sensitive information about our members, their beneficiaries and employees of relevant authorities and participating employers. Personal and sensitive information is securely stored. The personal information we collect and store may include:

• Your personal particulars
• Contact details
• Details of your nominated beneficiaries
• Your employment details including your employer, salary, duration of employment and contribution history
• Tax file number (TFN)
• Insurance cover and claims history, including medical reports and underwriting assessments.

Other personal information we may collect and store includes:

• Membership information from other superannuation providers
• Identification information or documents
• Details of other financial institutions
• Information from Services Australia
• Complaint information.

If you decline to provide Vision Super with your personal information, we may not be able to grant membership, establish or maintain an account, provide, assess, report or pay your superannuation or insurance benefits. You do not have to provide us with your TFN, however if you do not, you may pay more tax on contributions made to your account. You will also not be able to make personal contributions to your super account. Quoting your TFN makes it easier to keep track of your superannuation. If you do not wish to provide your TFN or for us to receive it directly from the ATO or from another superannuation trustee or retirement savings account (RSA) provider, please call our Member Services team on 1300 300 820 or email us at [email protected] let us know. If we ask you for information, our request will always include Vision Super’s contact details and the reason why we’re asking you for your information, as well as containing a statement that your information will be protected in accordance with the Privacy Act 1988 and Vision Super’s Privacy policy, and letting you know where those documents can be found. If Vision Super receives unsolicited personal information from you, we will (within a reasonable period) determine whether or not we could have collected the information in line with the Australian Privacy Principles. If we could not have collected the information, and it is not contained in a Commonwealth Government record, we will destroy or de-identify the information as soon as we can, provided we can do so legally. Vision Super also collects personal information from employment candidates such as employment history, contact details and other information, for recruitment purposes. Similarly, Vision Super collects and holds personal information about its staff to enable payroll and other administrative processes associated with employment.

Using and disclosing your personal information

Your information will be kept confidential and will only be used for the purposes for which it was collected, which include:

• Establishing, managing superannuation and pension accounts
• Processing and paying superannuation and pension benefits
• Verifying personal identification documents
• Informing and educating you about your super
• Assessing eligibility and claims for insurance
• Investigate and address complaints or inquiries
• Providing, assessing and paying death benefits
• Providing associated services, such as general and personal financial product advice about superannuation and insurance benefits and retirement benefits generally
• Direct marketing activities designed to grow the fund and improve our products and services
• Providing access to online services and the Vision Super app
• Conducting member surveys
• Complying with regulatory or legal requirements under superannuation, taxation and other relevant Australian laws
• Locating and consolidating superannuation accounts.

It is important to note that in carrying out these purposes, Vision Super may be required to disclose your information to an overseas entity. In doing so, Vision Super is obliged to make all reasonable efforts in ensuring that adequate privacy measures are in place (or put in place) to protect your information.  Further  detail about how we store your information is included below. To provide you with products and services, we may disclose your personal information to the following types of organisations:

• Any person nominated by you in writing
• Financial institutions including banks, superannuation funds, custodians and fund managers
• Legal advisors, auditors or regulatory bodies
• Our insurance provider for the purposes of administering our insurance policy
• Our administration software provider and other technology service providers
• The Australian Financial Complaints Authority (AFCA), the Office of the Australian Information Commissioner (OAIC) or any other external complaint handling agency
• Other government bodies including law enforcement agencies
• Mail house or mailing organisations.

Vision Super will not use or disclose personal or sensitive information for any purpose other than that for which it was collected, except where:

• It relates directly to the purpose for which it was collected
• You have given your consent
• It is required by law or a government or regulatory body
• Vision Super reasonably believes that the use/disclosure is necessary to lessen or prevent a serious and imminent threat to an individual’s life, health or safety or public health or safety
• Vision Super is required by the Family Law Act 1975 (Cth) to disclose personal information to an individual’s spouse/partner or former spouse/partner.

If personal information is disclosed in any of the scenarios described above, that disclosure will be noted on the individual’s record, and (if permitted by an Australian law or court/tribunal order) the individual’s information will be de-identified before Vision Super discloses the information to the relevant party in accordance with the above points.

Marketing

Vision Super does not consider any activity associated with managing the fund or informing and educating our members to be marketing. We use direct marketing to contact members to provide information about your Vision Super accounts, to promote our products and services, other activities associated with managing the fund, informing and educating our members and growing the fund’s membership. We use the services of third parties to help us deliver marketing messages and provide members with relevant content. We also undertake market research, member data analysis and direct marketing activities designed to grow the fund. We may use your information to undertake these activities. This may involve providing your personal information to third-party service providers to facilitate delivery of marketing material through multiple channels. We engage service providers to help us attract new members and tailor our messages and content to the needs of existing members. If you do not want your information to be used for these activities, you can opt out of receiving marketing material by using the unsubscribe link that appears on all of our marketing emails or opt out of all marketing activities by calling us on 1300 300 820. We have ongoing disclosure obligations to members and are required by law to provide you with important information about your Vision Super account and any changes to products and services. If you unsubscribe from our marketing emails or opt out of marketing activities, you will continue to receive the information we are legally required to send you.

Website visitors

Vision Super uses cookies to collect general information for each visitor to our website, which we use to monitor the success and the points of interest on our website. This may include information about:

• The number of visitors to the Vision Super website
• The number of pages they visit
• The average amount of time visitors spend on our site
• Common entry and exit points to and from the site.

This information does not include personal information.

Cookies

Cookies are a small text file that track a user’s internet activity through their web browser. The kinds of information collected varies depending on the site visited and the types of cookies stored for that site. Some sites do use cookies to collect personal information and monitor user behaviours. You can manage the use of cookies within your internet browser or mobile device settings. We also use Google Analytics to collect user activity and information to provide you with information we think will interest you. Google Analytics uses cookies to collect information about you, your device, your location, websites you visit and the apps you download. Google shares information it collects with affiliates within the Google group of companies and other third parties. Information about how Google collects, stores and discloses information is detailed in the Google Privacy Policy. Google also provides a Google Analytics opt-out browser add-on; visit Google’s Ads Setting or Add Settings for mobile apps for more information.  

Social media

Vision Super uses social media including Facebook, Twitter, Instagram, YouTube and LinkedIn to promote our products and services, and to inform members of changes to superannuation that may affect you. We will never ask you to provide your personal details on social media or an unsecure public forum and we discourage members from providing personal information to us on social media. Social media sites also use cookies to collect information. The collection, storage and disclosure of personal information is subject to the privacy policy of the relevant site.

How we store your information safely

External service providers/contractors

Vision Super requires all our domestic external service providers/contractors, such as facilities management, actuaries, underwriting specialists, medical consultants, printing, mailing and other professional advisers, to comply with the Privacy Act 1988 and Vision Super’s privacy policy. When Vision Super engages external service providers/contractors that are based overseas, and the external service provider/contractor does not have an Australian base for operations, we make all reasonable efforts to ensure that adequate privacy measures are in place (or put in place) for handling your information. Vision Super does not transfer personal information to third parties unless at least one of the following conditions applies:

• We are sure the third party is subject to legal obligations substantially similar to the Australian Privacy Principles
• You consent to the disclosure of your personal information
• The transfer is necessary to comply with a contractual obligation with you or a third party, and the contract was entered into in your interest
• The transfer is for your benefit but in a situation where it is impracticable to obtain your consent, it is likely that you would consent to the transfer of your personal information.

Physical security

We ensure there is secure access control and 24-hour monitoring of any building where personal information is held, including Vision Super’s offices, and that our outsourced computing and backup storage facilities meet or exceed industry accepted standards of physical access security.

Computer and network security

Vision Super has a comprehensive suite of protections in place to help keep your information safe, including:

• Thorough data backup procedures
• An industry standard cyber security management strategy
• Maintenance and independent testing of network security devices to guard against unauthorised electronic access wherever a connection to a public network exists
• Implementation of industry recognised virus protection software
• Secure destruction, de-identification, or erasure of all media holding an individual’s information once no longer required for any legitimate purpose, or no longer required by or under an Australian law or court/tribunal order to retain the individual’s information. For example, the shredding of paper documentation and the permanent erasure of magnetic media, including data stored on computer equipment prior to disposal
• The design of the Vision Super website, which ensures that no personal information is stored on the actual web server. Personal information transferred to, or from, Vision Super using web services is encrypted using industry recognised methods, without being recorded on the web server
• Regular review of business risks, and mitigation through the maintenance of an approved and tested Business continuity plan.

Member hotline

Our contact centre staff will check your identity before discussing your personal information or any account details with you over the telephone. We require the same checks if you communicate with us by email.

The people who can access your information

Vision Super restricts access to member records to ensure access to your information is limited to those who need access to manage your account. Before staff can access member accounts, they must be authorised, qualified and appropriately trained. We put confidentiality agreements in place with any third parties that may handle personal information on behalf of Vision Super. Wherever we can, we obscure sensitive personal information through the use of non-identifying codes. For example, the use of member numbers instead of names, and coded medical categories instead of descriptions of medical conditions. We review all of our security measures and procedures regularly to ensure your personal information continues to be properly protected.

Clean desk policy

Under Australian Privacy Principle 11 – Security of personal information, we must take reasonable steps to protect personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. In order to ensure our member and employer data is secure, Vision Super has a clean desk policy. This means any files that contain member or employer data must be locked in cabinets/drawers when an employee is not actively working on them, including during lunch and other breaks.

Updating and accessing personal information

You may request a copy of your personal information. You may make amendments to this information if you believe it to be inaccurate. Privacy law provides some exceptions to this rule, however, and if any of these arise, we can refuse your request. If we do so, we will provide you with an explanation of why your request has been refused. If you wish to update your personal information or obtain a copy of your personal information, please call us. You will be required to answer a series of questions to verify your identity before we can share information about your account.

Privacy Complaints

Complaints regarding your privacy can be made verbally or in writing to the Resolutions Officer. If you have any difficulty writing an email or letter of complaint, please contact us on 1300 300 820. Complaints can also be emailed to: [email protected] or submitted using our online form. We’re committed to resolving your complaint  as quickly as possible, in any event we will try to resolve your complaint within 30 days. If your complaint  is not resolved to your satisfaction by our internal complaints process, you can refer it to the Office of the Australian Information Commissioner using the following contact information: Phone: 1300 363 992 Email: [email protected] Online: https://oaic.gov.au/privacy/privacy-complaints/ Post: GPO Box 5218 Sydney NSW 2001 For further information about privacy laws or lodging a complaint, please visit the Office of the Australian Information Commissioner’s website