The privacy of your personal information is important to us.

1. Introduction
Implemented Portfolios Limited (IPL) take very seriously our obligations under the Commonwealth Privacy Act (Privacy Act) to protect your personal information. Under the Privacy Act, we are bound by the Australian Privacy Principles, and in this Privacy Policy, we describe how we intend to meet our privacy obligations.


2. Personal Information
The Privacy Act sets out the information that it protects.


Personal information generally means information or an opinion about a person, where the person is identified or is reasonably identifiable.


Sensitive information means a person's health information, genetic information, certain biometric information and biometric templates. It also means certain personal information, being an opinion about a person’s:

  • racial or ethnic origin;
  • political opinions;
  • membership of a political association;
  • religious beliefs or affiliations;
  • philosophical beliefs;
  • membership of a professional or trade association;
  • membership of a trade union;
  • sexual orientation or practices;
  • or criminal record.


Where in this Privacy Policy we refer to personal information, unless the context requires otherwise, that is a reference to both personal information and sensitive information.


3. Personal information collected and held

IPL only collect and hold personal information that is relevant to, and reasonably necessary for, the financial services we provide to you. In addition, we only collect sensitive information if you consent, or in specific circumstances set down in the Australian Privacy Principles.


The kind of personal information we will be likely to collect and hold includes:

  • your contact details, date of birth, gender;
  • your investment preferences;
  • your Tax File Number;
  • your Australian Business Number;
  • your bank account or other financial institution details; and
  • identification documents.


4. Consequences of not providing your personal information
You are not obliged to give us your personal information. However, if you decide not to give us information needed in order to provide you with services, we may not be able to provide those services to you.


5. How your personal information is collected and held
IPL will generally collect your personal information as much as possible directly from you. For example, we collect information about you through your application.


We may on occasion collect your personal information from publicly available sources of information and from third parties, including for example, from:

  • your financial adviser;
  • Australia Post and / or the Australian Taxation Office (if we cannot contact you); or
  • direct marketing organisations and data providers.


We only collect “sensitive information” if you have consented to the collection of the information and the information is reasonably necessary for one or more of our functions or activities or if the collection of sensitive information is authorised or required by a court / tribunal order or an Australian law, including the following Australian laws:

  • Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
  • Corporations Act 2001 (Cth);
  • Income Tax Assessment Act 1936 (Cth) and Income Tax Assessment Act 1997 (Cth);
  • Privacy Act 1988


Much of the information we hold about you will be stored electronically in secure data centres located in Australia. We also store information in the data centres of our contracted service providers, and some of these data centres may be located outside Australia.


We use a range of physical, electronic and other security measures to protect the security, confidentiality and integrity of the personal information we hold both in Australia and overseas.


6. How your personal information is used
We collect, use and disclose your personal information in order to provide managed discretionary account services to you, including for the following purposes:

  • Your identification details are used to process your application, manage your investment, ensure that you receive your distributions, provide you with information about your investment from time to time, process redemptions and to ensure that we comply with our legal and regulatory obligations.
  • During the time you are an investor in our managed discretionary account service we will hold investment-related information about you including the amount you have invested and your investment preferences.
  • Your Tax File Number and Australian Business Number (where relevant) is collected in order for us to ensure that your investment is taxed correctly.
  • Your identification details are used to provide you with information about any important changes to the managed discretionary account services we offer you, and related services, as well as any changes to Implemented Portfolios generally.
  • We may also use your personal information for any purpose:
    • for which your personal information was originally collected or you have consented;
    • for enforcement related activities conducted by, or on behalf of, an enforcement body; or
    • which is authorised or required by a court/tribunal order or an Australian law.


We may collect, use and disclose your personal information to provide you with information about our products and services offered by other parties that we believe may be of interest to you (including by way of direct mail, telephone, email, text, secure Implemented Portfolios portals, and online advertising and marketing) or to request your feedback for research purposes. You always have the right to opt-out of receiving such information. You may exercise that right by contacting us as set out below in section 12 below.


7. Do we disclose your personal information overseas?
We may disclose personal information to overseas recipients.


IPL will only disclose your personal information to a recipient overseas in accordance with the Privacy Act. Circumstances in which we will do this include:

  • you have asked us to or we have your consent to do so;
  • we have outsourced a business activity or function to an overseas service provider;
  • we reasonably believe that the overseas recipient is subject to a law or binding scheme that protects the information in a way that is substantially similar to the way the information is protected under the Privacy Act and the Australian Privacy Principles, and there are mechanisms you can access to take action to enforce that protection; or
  • the disclosure is required or authorised by or under an Australian law or a court/tribunal order.


8. Data quality and protection
IPL will take reasonable steps:

  • to make sure all personal information we collect is accurate, complete and up-to-date at all times; and
  • to make sure all personal information we use or disclose is (having regard to the purpose of the use or disclosure) accurate, complete up-to-date and relevant at all times.


We will also take reasonable steps to protect your personal information from misuse, interference and loss, and from unauthorised access, modification and disclosure. Once your personal information is no longer required by us, we will take reasonable steps to destroy or permanently de-identify that personal information, except in circumstances where we are required by law to retain it.


9. Access and correction

If you think the personal information IPL holds about you is not accurate, complete or up-to-date, you should let us know. Also, please let us know any relevant changes to your personal circumstances as soon as possible.


We will take reasonable steps to correct information where you provide sufficient evidence or we are otherwise satisfied, having regard for the purpose for which the information is held, that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. We will also notify the correction to other parties to whom we have previously disclosed the information and if such a party refuses to make a correction, we will notify you of that refusal and how you can make a complaint.


If you require access to personal information we hold about you, please send us an email to We will generally allow access, unless certain exceptions apply under the Australian Privacy Principles – for example, if we reasonably consider providing access would pose a serious threat to the life, health or safety of any person, or providing access would be likely to prejudice action being taken by an enforcement body, or providing access would be unlawful.


Your request should specify the information to which you require access or which you wish to be corrected. We will keep a record of your request for and the manner in which it was dealt with.


We will not charge you for requesting access to, or correction of, your personal information. We may, however, charge you the costs associated with meeting your request for access, for example photocopying and postage costs.


We are required to respond to your request for access or correction within a reasonable period, of receipt of your request.


We will provide you with access in the manner you request, if it is reasonable and practicable to do so.


If we cannot meet your request for access or correction, we will notify you by email and where reasonable we will give you our reason and take steps to provide you with access. We will also tell you about how you can complain about our decision.


10. Anonymity
You can contact us anonymously or by using a pseudonym. However, being unable to identify you will limit the services IPL can provide you and there may be specific cases where we are prevented by law from dealing with you unless we identify you.


11. Data Breach
Should a data breach occur, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) of the data breaches that are likely to result in serious harm within 30 days of the breach event.


The factors which might contribute to a reasonable person thinking “serious harm” might have occurred include:

  • The sensitivity of the information;
  • Whether the information was encrypted;
  • Whether the information was in a secure file;
  • How likely it is that the security could be breached; or
  • The identity of the person who obtained the information, whether they intend to cause harm to the affected person and the nature of the harm.


12. Complaints and further information
If you would like further information about how we handle your personal information, please send us an email to


If you are not satisfied with the services provided to you by IPL, you should take the following steps:

  1. Contact your external financial adviser and tell them about your complaint
  2. If your external financial adviser has not satisfactorily resolved your complaint within 5 days, please contact our Chief Operating Officer on (02) 9241 5955 or put your complaint in writing and send it to: 
    • Chief Operating Officer
    • Implemented Portfolios Limited
    • Level 10, 60 Carrington Street
    • Sydney, NSW, 2000
    Please mark the envelope “Notice of Complaint”. We will try and resolve your complaint quickly and fairly.
  3. If the complaint cannot be resolved to your satisfaction within 45 days, you have the right to escalate the matter to the Australian Financial Complaints Authority (AFCA). AFCA can be contacted in a number of ways:


13. Related policies
This policy is also related to the following separate policies:

  • Data Breach Policy
  • Complaints Policy
  • Incidents and Breaches Policy


14. Review of the policy
This policy will be reviewed every two years to ensure it remains consistent with all relevant legislative requirements, as well as the changing nature of the organisation.


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