1. Introduction – AustralianSuper respects your privacy
Protecting your personal information is important to us, and is required by law. The Privacy Act determines that we must handle your personal information in accordance with a set of Australian Privacy Principles.
2. What personal information is collected and held by AustralianSuper?
We collect the following kinds of personal information: your name, address, email address, phone number, date of birth, your Tax File Number (TFN), the names of your beneficiaries and employment details including salary information.
In some situations we may collect information about your health, including medical information.
3. How does AustralianSuper collect and hold personal information?
Personal information is generally collected directly from you or through your employer, adviser, previous superannuation fund, or other representative authorised by you. Our Privacy Collection Statement can be read here.
Health information is collected from you or your employer, adviser, other insurer, or other representative authorised by you and is provided to us or to our insurers. If required, we obtain independent medical reports directly from your medical practitioner(s).
Where AustralianSuper collects your personal information from a third party, it is that third party’s responsibility to notify you about the disclosure of your personal information to us.
For employment candidates, AustralianSuper collects your personal information including employment history and other information during the recruitment process either directly from you or from recruiters.
For non-members, the way AustralianSuper collects your personal information will depend on the type of service or information you require from us. Typically, we will collect your personal information directly from you if you are a non-member.
Once your details have been recorded by our administrator, your original application is securely stored based on the following application method:
paper applications are held at our administrator’s document storage facility on our behalf
online applications are stored within our secure electronic network.
Within AustralianSuper and our administrator, access to your information is restricted to staff who require the information to administer your account and provide information and services to you. A system of passwords and different levels of access is used to protect the information held on the system.
You may choose to remain anonymous or use a pseudonym when interacting with AustralianSuper, unless it is impracticable for AustralianSuper to deal with you without you identifying yourself.
4. What are the purposes for which AustralianSuper collects, holds, uses and discloses personal information?
The personal information we collect will be used by AustralianSuper and its staff to:
open and administer your super and insurance accounts, and keep you informed about your super and insurance and opportunities available to you as a Fund member
ensure you’re eligible for products and services (including insurance)
help you combine your super accounts and check if you have lost super (when you ask us to)
provide financial education
help improve our products and services
undertake market research, member data analysis and direct marketing activities
manage and resolve complaints made
report information required by law or regulations
perform any other appropriate related functions.
For employment candidates, AustralianSuper collects your personal information for recruitment purposes, to manage your employment application and, if you are successfully placed in a position at AustralianSuper, your ongoing employment.
For non-members, we will only collect the personal information necessary for us to provide the relevant service or information that you require from us. For example, if you attend an AustralianSuper event, we may collect the following kinds of personal information from you so that we can manage your attendance at the event: your name, address, email address and phone number.
If AustralianSuper can’t collect your personal information from you it may be difficult to perform the activities listed above.
If you submit incomplete or inaccurate information to our insurers, they may not be able to provide you with the insurance cover you are seeking, or complete their assessment of your insurance-related matters.
5. Why does AustralianSuper ask you to nominate your dependants for death benefits?
You are asked to advise AustralianSuper of the names and addresses of the persons who you would like to receive your superannuation in the event of your death. This information assists us to distribute your death benefit fairly to your dependants or to your legal personal representative (which means the executor or administrator of your estate). You can make a “non-binding” or “binding” nomination.
If you make a non-binding nomination, we will take your wishes into account, but will also look at all your dependants at the date of your death. Advising us about your relationship with the persons you nominate is not required for a non-binding nomination if you consider this to be an unreasonably intrusive request.
If you make a binding nomination, we will pay your death benefit in accordance with your wishes, so long as your nomination is valid. We need to know the nature of your relationship with the persons you nominate in order to determine whether your nomination is valid. As such, you will need to advise us about your relationship with the persons you nominate in order to make a binding nomination.
6. To whom does AustralianSuper disclose personal information?
We will only share your personal information:
with any third party on specific matters if you have consented to the disclosure
as required by law or regulations, by Courts/Tribunals, or Government or regulatory bodies/authorities
with service providers/third parties that we need to deal with for the purposes described in section 4 above including: our administrator (Australian Administration Services Pty Ltd, part of Link Group), insurers (including TAL Life Limited), your employer, mail houses, independent consultants and market research companies, auditors, actuaries and lawyers, web hosting companies, web and application developers, online calculator providers, our Member Direct platform partners, other superannuation, pension and investment fund trustees or administrators if you transfer your investment to another fund, and other organisations for the purposes described in section 4 above.
Where you provide your personal details for the purpose of online data verification, our third party service provider will use your details for this purpose. Your information will be subject to an information match request in relation to relevant official record holder information and a corresponding information match result will be provided via the use of third party systems.
If you die while you are an AustralianSuper member, AustralianSuper may share details about your super and insurance with your dependants and legal personal representative (which means the executor or administrator of your estate) as appropriate. The information we share may include the names of your nominated beneficiaries, your account balance and any insurance amount payable.
In the event that you claim an insurance benefit for either Total and Permanent Disablement or Income Protection (Temporary Disablement):
the relevant insurer may collect personal information from or about you and may provide your personal information to AustralianSuper and our administrator, to assist with the assessment and administration of the insurance claim
the insurers may also pass information to claims investigators, medical practitioners, reinsurers, insurance reference bureaus and certain organisations to whom they outsource some functions. This will be set out in the relevant insurer’s privacy statement.
If your insurance claim is declined and you take legal action or complain to an external dispute resolution body, AustralianSuper and our service providers must, on request, provide your personal details and information about your health to legal representatives of AustralianSuper and the insurer, officers of the Australian Financial Complaints Authority (AFCA) and Court officials.
For employment candidates, AustralianSuper may disclose your personal information to referees, recruiters and employment screening service providers for the purposes of considering your application for employment.
7. Is AustralianSuper likely to disclose personal information to overseas recipients?
Instances where your personal information may be accessed by an Australian service provider that sub-contracts certain services overseas, or by an overseas service provider include:
our software development service provider, Wipro, who are based in Australia, also use an offshore development team in India for some aspects of software development services and some aspects of our website incident rectification
to administer the Member Direct investment option. Some of these services are provided on behalf of UBS Securities Australia Limited (UBS) out of New Zealand
where, following an interaction that you have had with us, we send you a text message or email asking to you to participate in a survey designed to help us improve the services we offer you. Your personal information, including your name, email address and phone number will be provided to our service provider to facilitate this survey. Our service provider operates out of Canada and the UK.
8. How can you manage your communications with AustralianSuper?
Unless you have asked us not to, we may send you regular communications about products or services that are related to your AustralianSuper membership and other opportunities available to you as a Fund member.
If you do not wish to receive such information, or previously indicated that you would like to and have now changed your mind, you can log-in to your account and head to the “Manage my Communications” section to update your profile, or click the unsubscribe link within the email you receive.
9. What information does AustralianSuper collect when you browse our website and mobile App?
The information we collect about you depends on how you use the AustralianSuper website.
If you visit an unsecured area of the website (an area where you aren’t required to log-in) to read or download information, the only information recorded by us will be the date and time of your visit to the site, the pages viewed, the operating system in use, your geo-location and any information downloaded. We won’t record information that allows us to identify you, unless you provide your personal information via a web form.
AustralianSuper uses “session” cookies for analytical purposes. These cookies gather visitor behavioural information for analytical purposes. This information is not used to track a visitor, but is instead reported in aggregate to ensure the information delivered to a person via our website is relevant to the person accessing it. If the visitor is registered as a member on our website, they are allocated a unique tracking identification code, however, a third party cannot identify that visitor from the tracking identification code.
Third party cookies are also used on our website including the following:
Google Analytics cookies allows the identification of unique users across browsing sessions, but it cannot identify unique users across different browsers or devices. The “user ID” feature can associate data from one or more sessions from one or more devices via a persistent ID.
Google Optimize cookies are used to determine user inclusion in a content experiment and the expiry of an experiment a user has been included in.
Advertising cookies are used to track delivery of advertisements and which advertisements have been displayed to a particular user
YouTube.com tracks information on the video and browser settings of visitors.
LivePerson cookies are used to maintain session data and to identify returning visitors by saving LivePerson specific data such as visitor ID and last chat date but does not contain any private customer data.
Marketo cookies (Munchkin) are created when a user clicks on a link in an email sent by AustralianSuper. This is anonymous until certain behavioural actions occur at which point the cookie and resulting web activity can be associated to a known contact.
11. How can you access and seek correction of your personal information and lodge privacy complaints?
In order to keep your personal information as current as possible, we ask that you let us know of any changes to your personal details.
You may ask to see the personal information we hold about you and to have it corrected if necessary. We will need to verify your identity before giving you access.
We will respond to your request within a reasonable period after the request is made, by either providing you with access or by notifying you of our refusal to give you access.
In some circumstances, we may not be able to allow you access to your personal information, for example, where:
giving access would have an unreasonable impact on the privacy of other individuals
the information relates to existing or anticipated legal proceedings
giving access would be against the law
the information would reveal our commercially sensitive decision making process.
If we are unable to provide you with access to your personal information, we will notify you of the reasons for the refusal and the complaint mechanism available to you.
If we incur a cost in giving you access to your personal information, we may need to charge you for the associated cost(s).
If you would like to see the personal information we hold about you and have it corrected if necessary, please call us on 1300 300 273.
If you believe your privacy has been breached or you have a privacy complaint, you should write to:
AustralianSuper Privacy Officer
AustralianSuper Pty Ltd
Level 26, 50 Lonsdale Street
Melbourne Vic 3000
or email us at: firstname.lastname@example.org
We will review your complaint and respond within a reasonable period of time after we receive your complaint.
If you are not satisfied with the resolution of your complaint, you can refer your complaint to the Office of the Australian Information Commissioner at www.oaic.gov.au.
Non-Member EEA Specific Addendum
1. Legal Basis for collection
In accordance with Article 13(1)(c) of the GDPR, we have a legitimate interest in collecting and using EEA PI, including:
Purpose and/or activity
Type of data
Legal basis for processing
To ensure better outcomes in retirement for our members, by managing the assets of the Fund, including fostering new and existing relationships, managing and investigating investments and investment opportunities, and advocating for better industry practice.
“Contact Data”, including your work address, email address and telephone numbers; and
“Identity Data”, including your first name, last name, gender, username or similar identifier, title.
Legitimate Interest: To ensure that we have your contact details so that we can fulfil the purposes and activities listed in this table.
Images are being monitored by CCTV for the purpose of public safety, crime prevention and detection, and prosecution of offenders.
Images” from CCTV footage of ingress and egress points from UK office (“Images”).
Legitimate Interest: To ensure security of UK office, assets and staff.
2. International transfers
3. Retention period
EEA PI will only be retained for a period of 7 years following the date on which AustralianSuper last had activity associated with that EEA PI.
Notwithstanding the aforementioned, Images will only be retained for a period of 1 month following the date on which the Images are recorded, after which time the Images will be automatically destroyed.
4. Data subject rights
In accordance with Article 13(2)(b) of the GDPR, all subjects of EEA PI have a right to request from AustralianSuper:
access to and rectification or erasure of any EEA PI;
a restriction on our processing of the EEA PI; and
a cessation to processing or portability of the EEA PI.
5. Failure to provide EEA PI data to us
Provision of EEA PI to us is not mandatory, however where we need to collect your EEA PI:
under the terms of a contract we have with you (if any), and you fail to provide that EEA PI when requested, we may not be able to perform the contract we have or are trying to enter into with you; and
in order to involve you in managing the assets of the Fund (which may include collection under contract), including fostering new and existing relationships, managing and investigating investments and investment opportunities, and advocating for better industry practice. If you fail to provide that EEA PI when requested, we may not be able to involve you in those activities.