1. About MH Carnegie and how to contact us
1.1 This Privacy Policy applies to the activities of the M H Carnegie Group (M H Carnegie).
1.2 MH Carnegie’s contact details are as follows:
Registered Address: 52 Victoria Street Paddington NSW 2021
Telephone: +61 2 9397 1400
Email: enquiries@mhcarnegie.com
Website: www.mhcarnegie.com
Privacy Officer: Kate Thompson
2. Privacy Compliance
2.1 This Privacy Policy set outs MH Carnegie’s policies on the management of personal information it collects, uses, discloses and stores as defined by and in accordance with the Australian Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles (APPs) contained in the Privacy Act, which MH Carnegie is bound by.
2.2 A copy of the Act and the APPs can be obtained from the website of the Office of the Australian Information Commissioner (www.oaic.gov.au).
3. Collection
3.1 The type of information MH Carnegie generally collects and holds includes (but is not limited to) personal information from employees, individuals at investors and investee companies, people who contact us with enquiries, eg via our website and from clients in the course of providing our services, conducting business on their behalf and communicating with them.
3.2 The kind of personal information which MH Carnegie collects and holds includes (but is not limited to) names, address and contact details as well as other personal information necessary for providing the financial services requested by its clients.
4. Use and disclosure
4.1 MH Carnegie generally uses personal information it collects to:
1. respond to enquiries;
2. perform our services; and
3. communicate with clients and inform them about our services.
4.2 MH Carnegie may disclose personal information to external contractors and service providers we engage in the normal course of our business, such as our legal and technology advisors, to enable us to provide our services. We may also disclose personal information about individuals to overseas contractors and service providers. We expect our contractors and service providers to comply with the Privacy Act and APPs.
4.3 MH Carnegie will only use or disclose personal information about a person for the primary purpose for which it was collected or for another secondary purpose if:
1. that other purpose is related to the primary purpose of collection;
2. the person would reasonably expect us to use or disclose the information for the secondary purpose;
3. the person has consented to the use or disclosure; or
4. the use or disclosure is permitted or required under the law, including for customer verification purposes in relation to our financial services, including (but not limited to) to AUSTRAC in respect of any suspicious or threshold transactions or activities, or as otherwise permitted under the APPs.
4.4 You may at any stage opt out of receiving any marketing or promotional communications from MH Carnegie. If you do not wish to consent to us using your personal information for any marketing purposes, please contact our Privacy Officer via the contact details at paragraph 1.2 above.
Information collected and stored when visiting our website
4.5 When you look at our website, a record is made of your visit and for the purpose of analysing and evaluating the performance and operation of our website, the following information is logged:
1. your IP address;
2. the date and time of your visit to the site;
3. the pages you accessed and documents downloaded;
4. the previous site you have visited; and
5. the type of browser you are using.
How MH Carnegie uses cookies
4.6 A “cookie” is a type of file, often including a unique identifier, that is sent by a web server to web browsers, and which may then be sent back to the server each time a browser requests a page from the server. The purpose of a cookie is to help analyse web traffic and may let the website know when you visit a particular site. Cookies allow a web application to respond to you as an individual. They can record information about your visit to the site, allowing it to remember you next time you visit and provide any relevant information to you. Cookies are also used to enhance the secure use of websites.
4.7 Cookies can be stored in your hard drive (“persistent cookies”) or in memory (“session cookies”). A persistent cookie is a cookie which will enable a continuing record to be kept of your visits to the website. A session cookie is a cookie which is a transient cookie and tracks your visits for a website session only.
4.8 MH Carnegie only uses session cookies to identify which pages of the website are being used for a website session only. Upon closing your browser the session cookie set by this website is destroyed and no personal information is maintained. MH Carnegie does not make any attempt to identify users or their general browsing activities.
5. Data quality and security
5.1 MH Carnegie is committed to ensuring that all the personal information it collects remains accurate, complete and up to date. MH Carnegie will from time to time request that clients and information providers update relevant personal details.
5.2 MH Carnegie stores personal information in both hard copy and electronic format in its offices. Personal information stored electronically is maintained in a secure environment. These records are only accessible to personnel of MH Carnegie who require access to enable them to perform their duties. All personnel have signed Privacy and Confidentiality Agreements binding them to comply with the APPs.
5.3 MH Carnegie will destroy records of personal information when it is no longer necessary to be retained within MH Carnegie records. Personal information will be destroyed by shredding or other secure process.
6. Access to records
6.1 Any requests for access to personal information held by MH Carnegie should be made in writing to the MH Carnegie Privacy Officer. Individuals may request access to the personal information MH Carnegie holds about them by completing the MH Carnegie Request for Information Form and forwarding the Form to MH Carnegie’s Privacy Officer. Copies of the Form are available from the Privacy Officer. No reasons have to be provided for seeking access. MH Carnegie will respond to a request to access to personal information as soon as possible. Where MH Carnegie holds information to which a person is entitled to access, it will endeavour to provide a suitable range of choices as to how access may be given. Where MH Carnegie is unable to provide access MH Carnegie will provide the individual with reasons for the refusal.
6.2 If a person believes that information held by MH Carnegie is incorrect, incomplete or inaccurate they may request amendment of that personal information. MH Carnegie will consider if the information requires amendment, and will respond to a request to amend personal information as soon as possible. If MH Carnegie does not agree that there is any ground for amendment it will, if the person seeking the amendment requires, place with that person’s personal information, a statement from that person as to why the information is not accurate or up to date. Where MH Carnegie is unable to correct the personal information MH Carnegie will provide the individual with reasons for the refusal.
7. Complaints Procedure
7.1 MH Carnegie is committed to providing those persons whose personal information it holds, a fair and responsible system for the handling of complaints concerning the collection, accuracy or disclosure of personal information.
7.2 MH Carnegie has a designated Privacy Officer whose role includes dealing with complaints, concerns or queries that individuals may have with respect to personal information held by MH Carnegie. Should you have any issues concerning your personal information, they should be made in writing and addressed to the Privacy Officer of MH Carnegie at the address referred to in paragraph 1.2 of this Policy.
7.3 The Privacy Officer is empowered to deal with all such complaints as expeditiously as possible through MH Carnegie's complaints handling process. However, if after you have put your concerns in writing and we have had an opportunity to address them, you feel that we have not adequately dealt with your concerns you may refer the matter to the Office of the Australian Information Commissioner at:
Postal: GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Facsimile: (02) 9284 9666
Email: enquiries@oaic.gov.au
8. Changes to this Privacy Policy
As we plan to ensure our Privacy Policy remains current, this Policy is subject to change. Our most current Privacy Policy will appear on our internet site and you should return periodically to our internet site to review our Privacy Policy.
Last updated: December 2018