Privacy Policy

At BT Financial Group (BT), we are dedicated to protecting your privacy and safeguarding your personal information.

BT is bound by the Commonwealth Privacy Act and the National Principles for the handling of personal information, which are set out in that Act.

There is a single Privacy Policy for all BT Financial Group (BT) clients.

This privacy policy outlines to you all the ways in which BT Financial Group (also referred to as "we" or "us" in this policy) aims to protect your personal information and what sort of personal information we hold about you, for what purposes and how it is collected, held, used and disclosed.

Personal information is any information, including an opinion, that can be used to identify an individual or can be linked to an individual.

By continuing to use the products and services provided by BT, you consent to us dealing with your information in the manner set out in the Privacy Policy.

• Subject to legislative requirements, we will only collect personal information relevant to our business relationship with you. There is some personal information, which is necessary for us to collect to be able to provide you with a specific product and service, and in order for us to satisfy our obligations under relevant legislation such as the Anti-Money Laundering and Counter Terrorism Financing Act 2006 ("AML-CTF Act"). If you do not provide this personal information we may not be able to provide you with the product or service you have requested.
• Personal information is any information, including an opinion, that can be used to identify an individual or can be linked to an individual.
• Depending upon the products or service you have requested, some examples of the type of information we collect are your name, address, contact details, tax file number, date of birth, employment information, financial information such as your income, and information about your use of our products and services.
• The collection of sensitive personal information is restricted by the provisions of the Privacy Act. This means we will not collect any sensitive information, such as personal information relating to your religious views, ethnicity, political opinion, criminal record, health personal information or sexual preference, unless this is necessary to provide you with a specific product or service and you have consented to that collection.

• If it is reasonable and practicable to do so, we collect personal information directly from you. How we collect your information will depend upon how you interact with us. We may collect it through application forms, telephone, email and internet contact, from correspondence with you or your adviser and in person via Westpac branches.
• There are occasions where we may need to collect personal information from other parties with or without your direct involvement. Depending upon the product or service you have requested, some examples of the persons or organisations from which we may collect personal information, include:
  • other Westpac Group companies
  • service providers engaged to do something for or on behalf of us or any other Westpac Group company
  • publicly available sources of information (such as telephone directories)
  • market research organisations (such as shoppers’ surveys and telephone polls)
  • your representative (such as your legal adviser or financial adviser)
  • your employer
  • insurers and reinsurers, if you obtain insurance through us (including insurance obtained through a product or service issued or administered by us).
• When you ring us, we may monitor and/or record telephone calls for the purposes of staff training and administration of our products and services.

• We collect statistical information on web site activity, such as the number of users who visit, the date and time of visits, the number of pages viewed and how users navigate through our web sites. We will be aware of your identity if you log into our web sites. This information is collected through the use of cookies.
• A cookie is a small data file that's automatically placed on your computer's hard disk, and it contains information in relation to your visit to a web site.
• A cookie is created on your hard disk when you log into the secure areas of our web sites. This cookie ensures that accurate information is provided to you while you're transacting online. As soon as you log out of the secure areas, this cookie is deleted.
• Also, another cookie may be stored on your hard disk when you log into our web sites. This cookie lets us analyse our site traffic patterns with the view to continually improving our web sites. This cookie is not deleted once you log out of our secure areas.
• You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Refer to your browser instructions or help screens to learn about these functions. If you reject all cookies, you may not be able to use our web sites.

• When we collect personal information from you, we will inform you of the purposes for which it is collected. Primarily, this will be to establish and administer the financial products or services we or any Westpac Group company provides to you (such as investments, superannuation, insurance or loans), or to comply with legislative requirements such as the AML-CTF Act.
• We may also use your personal information to:
  • provide additional services to you, such as market updates and information on products and services available from us or any Westpac Group company. However, if you only hold BT products through an external financial adviser, no information will be used by non-BT Financial Group companies for marketing purposes. You can notify us at any time if you do not wish to receive any marketing information (see Marketing products and services to you).
  • carry out our business which includes performing our internal administration and operations including: accounting, risk management, record keeping, archiving, systems development and testing and staff training
  • develop and establish products and services and conduct market research
  • undertake planning and statistical analysis
  • assist you in your queries
  • prevent fraud and crime in relation to products and services you invest in or we provide; and
  • fulfil our legal requirements (for example, disclosure to enforcement bodies such as the Australian Securities and Investments Commission (ASIC), the Australian Taxation Office (ATO), the Australian Transaction Reports and Analysis Centre("AUSTRAC") or the courts).
• We may need to disclose your personal information to another person or organisation. However, we will only disclose your personal information where we are allowed to by law and have your express or implied consent, or where we are obliged to by law.
• You can give express consent by, for example, telling or agreeing with us in writing (such as, by signing an application form) or by telling us verbally.
• Implied consent is where we have reasonably assumed you have given consent from your behaviour. For example, consent can be implied when a person uses a telephone service and proceeds after hearing a recorded message that the call may be recorded for staff training purposes. Consent to use the information for staff training purposes is implied by the person’s action of continuing with the call.
• Where we disclose your personal information to organisations that perform specific essential services for us, for example mailing, we limit this disclosure to the information they need to perform the service.
• Depending upon the products or service you have requested, we may exchange information about you with, for example:
  • agents, contractors and external service providers of BT Financial Group or any other Westpac Group company
  • authorised representatives of BT Financial Group or any Westpac Group company
  • other financial institutions, including stockbrokers, custodians, funds managers and portfolio service providers
  • payment systems operators
  • regulatory bodies, government agencies and law enforcement bodies
  • agents acting on your behalf, including your legal adviser and financial adviser
  • insurers and reinsurers, if you obtain insurance through us (including insurance obtained through a product or service issued or administered by us)
  • your executor, administrator, trustee, guardian or attorney
  • superannuation funds
  • your employer; and
  • other organisations or firms, who jointly with us, provide products or services to you.
• Those parties which supply services to us, and to which we disclose personal information, have undertaken to comply with our confidentiality requirements under privacy law.
• Sometimes a member of the Westpac Group, a service provider or your adviser may be located outside Australia. We may transfer your information to a person such as this who is outside Australia if we have your consent to do so or in other circumstances where the law permits this transfer.
• We share your personal information with other members of the Westpac Group. The Westpac Group means the Westpac Banking Corporation (ABN 22 007 457 141) and its subsidiaries, and includes every company forming part of the BT Financial Group. All members of the BT Financial Group are bound by this privacy policy. Other members of the Westpac Group are bound by a separate privacy policy which is substantially similar to this policy.

We may use your personal information to offer you BT Financial Group and Westpac Group products and services. If you only hold BT products through an external financial adviser, no information will be used by non-BT Financial Group Companies for marketing purposes.

We may offer you products and services by various means - including by email, SMS or other electronic means.

From our current relationship with you, we believe that we have your implied consent to do so unless you have told us that you do not wish to receive them.

However, you can notify us at any time if you do not wish BT Financial Group to use your details to send these offers. BT Financial Group will act promptly on your request which you can make by

If you do not wish members of the Westpac Group (outside the BT Financial Group) to use your details to send these offers

• We will take reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification and disclosure.
• Paper documents are protected from unauthorised access or use through the various security systems that we have over our physical premises. We also maintain up-to-date computer and network security systems with appropriate firewalls, encryption technology and passwords to protect electronic copies of personal information.
• To ensure the security of your personal information, we ask that you observe the security requirements that relate to the use of your personal identification number and/or passwords used to access your investments or products or use our services electronically.
• We will take reasonable steps to destroy personal information in a secure manner or remove identifying features from it, if it is no longer required by us. This is subject to any legal obligations we have to retain information for a certain period of time.
• In order to protect your personal information online, we use up-to-date and secure technology methods.
• When we capture your personal information it is passed through our secure server using encryption technology which scrambles the personal information to ensure it is protected over the internet. In order to protect your investment information from unauthorised people, BT Financial Group has registered a security certificate with the Verisign Trust Network which provides you with a secure 128-bit SSL (Secure Socket Layer) encrypted connection via Server Gated Cryptography (SGC).
• Stored personal information about you is further protected from unauthorised access through the use of multiple firewalls, secure passwords and sign in processes:
  • BT Online uses an eight-character password (rather than your four-digit PIN).
  • If three unsuccessful attempts have been made to log into your Account Summary, your account will be locked. To unlock your account you will have to contact Customer Relations on 132 135 to verify your identity before unlocking the account.
  • Withdrawals from your BT funds can only be made to the bank account which you have nominated. New bank accounts can only be nominated in writing, signed by you.
  • If you are logged into BT Online but your session is inactive (for instance if you are called away from your PC or leave your session open accidentally), your session will be automatically closed after 1 hour of inactivity.
  • At no time are you required to enter credit card details into BT Online.
  • You have to request access to BT Online (by obtaining a password). So if you aren't comfortable with the internet, your accounts are not accessible at all unless you decide to turn the service on.
• We cannot guarantee the policies and procedures of any other web sites that may be linked from our web site. They may or may not comply to the same privacy standards that we do and therefore you should take care to evaluate their particular privacy standards and procedures as needed.

• We do not use Tax File Numbers, Medicare numbers or any other government identifier for the purposes of identifying you with our products or services.
• The only circumstances in which we collect, use or disclose these numbers is where we are required or authorised by law to do so. For example, we may be required by law to disclose your Tax File Number to the Australian Tax Office.

• We maintain your personal information by taking reasonable steps to make sure that the personal information collected, used and disclosed is accurate, complete and up-to-date.
• So that we can maintain the accuracy of your personal information at all times, we ask that you notify us immediately when you change your contact details such as your telephone number or address, or if you become aware that any personal information we hold about you is incorrect. See Contact us.

• You can access most of the personal information we hold about you and request corrections.
• Your right of access is subject to some exceptions. For example, you may not be able to obtain access to personal information which:
  • would reveal personal information about another person
  • would reveal a commercially sensitive decision making process; or
  • we are prevented by law from disclosing.
• We will tell you why if we are unable to give you access to your personal information on request.
• You can request access to your personal information by contacting us by

  Phone:	BT Customer Relations on 132 135
  Email:	customer.relations@btfinancialgroup.com
  Mail:	BT Financial Group, GPO Box 2675, Sydney NSW 2001

• This service is free unless the personal information you request requires research or preparation time. Before we act upon requests of this nature, we will provide you with an estimate of how much this service will cost and obtain your agreement before proceeding.

We can make changes to our privacy policy and the processes and systems relating to how we handle your personal information, from time to time, and for any reason. We will update this policy to reflect any changes.

BT Financial Group is bound by the Commonwealth Privacy Act and the ten National Privacy Principles for the handling of personal information, which are set out in that Act.Our policies, processes and systems have been developed to ensure we comply with all our obligations under the Privacy Act.

If you have a privacy concern:

Step 1. Contact our Customer Relations team

Where possible, your concerns received over the telephone will be resolved at that time.

Where possible, your concerns received via email will be resolved within three working days.

Step 2: Write to our BT Privacy Officer

If you feel your concerns have not been resolved, please refer the matter in writing to:

The BT Privacy Officer will review your concern and will endeavour to resolve the situation within 30 days of receiving the letter.

Step 3: Contact Office of the Australian Information Commissioner or FOS

If you are still not satisfied with our response, you may contact the Office of the Australian Information Commissioner. The Commissioner can be contacted on the privacy hotline: 1300 363 992. You may also contact the Financial Ombudsman Service (FOS) - they are an independent complaints body.

FOS contact details are:

Financial Industry Complaints Service Limited

Before you contact FOS, we recommend that you first try to resolve your concern with us

"BT Financial Group" means the investment management business of Westpac Banking Corporation (ABN 33 007 457 141) and includes the businesses of:

• Westpac Financial Services Limited (ABN 20 000 241 127)
• Westpac Securities Administration Limited (ABN 77 000 049 472)
• BT Funds Management Limited (ABN 63 002 916 458)
• BT Portfolio Services Limited (ABN 73 095 055 208)
• BT Funds Management No. 2 Limited (ABN 22 000 727 659)
• BT Securities Limited (ABN 84 000 720 114)
• Magnitude Group Pty Ltd (ABN 54 086 266 202)
• Westpac Securities Limited (ABN 39 087 924 221)
• Westpac Life Insurance Services Limited (ABN 31 003 149 157)
• BT Investment Management Limited (ABN 28 126 385 822)
• BT Investment Management (RE) Limited (ABN 17 126 390 627)

"Westpac Group" means Westpac Banking Corporation (ABN 33 007 457 141) and its subsidiaries and every member of the BT Financial Group, and "Westpac Group company" means each company forming part of the Westpac Group (including companies forming part of the BT Financial Group).

If you would like to contact us about this policy or our products and services, please call BT Customer Relations on 132 135 or to mail BT Financial Group, GPO Box 2675, Sydney NSW 2001