Privacy Policy

SECTION A – INTRODUCTION
  1. INTRODUCTION
    • As part of Auburn Capital Pty Ltd and Auburn Capital Wealth Management Pty Ltd’s (together, “Auburn Capital”) process to ensure that it continues to maintain the highest levels of professional integrity and ethical conduct, Auburn Capital has adopted this Privacy Policy (“Policy”) to manage personal information in an open and transparent manner.
    • The provisions of this Policy will assist Auburn Capital in complying with the requirements of the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles in protecting the personal information Auburn Capital holds about its clients.
  2. WHEN DOES THIS POLICY APPLY?
    • This Policy applies to all representatives and employees of Auburn Capital at all times and the requirements remain in force on an ongoing basis.
  3. GLOSSARY
TERM DEFINITION
APP entity means an agency or organisation as defined in section 6 of the Privacy Act.
Australian law means(a)       an Act of the Commonwealth or of a State or Territory; or

(b)       regulations, or any other instrument, made under such an Act; or

(c)       a Norfolk Island enactment; or

(d)       a rule of common law or equity.
Collects Auburn Capital collects personal information only if Auburn Capital collects the personal information for inclusion in a record or generally available publication.
Court/tribunal order means an order, direction or other instrument made by:(a)       a court; or

(b)       a tribunal; or

(c)       a judge (including a judge acting in a personal capacity) or a person acting as a judge; or

(d)       a magistrate (including a magistrate acting in a personal capacity) or a person acting as a magistrate; or

(e)       a member or an officer of a tribunal;

and includes an order, direction or other instrument that is of an interim or interlocutory nature.
De-identified personal information is de-identified if the information is no longer about an identifiable individual or an individual who is reasonably identifiable.
Eligible Data Breach An eligible data breach occurs:(a)        where there has been unauthorised access of unauthorised disclosure of personal information, or a loss of personal information, that Auburn Capital holds; and

(b)        the unauthorised access or unauthorised disclosure is likely to result in serious harm to one or more clients; and

(c)        Auburn Capital is not able to prevent the likely risk of serious harm with remedial action.
Holds Auburn Capital holds personal information if it has possession or control of a record that contains the personal information.
Identifier of an individual means a number, letter or symbol, or a combination of any or all of those things, that is used to identify the individual or to verify the identity of the individual, but does not include:(a)       the individual’s name; or

(b)       the individual’s ABN (within the meaning of the A New Tax System (Australian Business Number) Act 1999); or

(c)       anything else prescribed by the regulations.
Permitted general situation As defined in s16A of the Privacy Act
Permitted health situation As defined in s16B of the Privacy Act
Personal information means means information or an opinion about an identified individual, or an individual who is reasonably identifiable:(a)  whether the information or opinion is true or not; and

(b)  whether the information or opinion is recorded in a material form or not.
Sensitive information means(a)       information or an opinion about an individual’s:

(i)         racial or ethnic origin; or

(ii)        political opinions; or

(iii)      membership of a political association; or

(iv)      religious beliefs or affiliations; or

(v)       philosophical beliefs; or

(vi)      membership of a professional or trade association; or

(vii)     membership of a trade union; or

(viii)    sexual orientation or practices; or

(ix)      criminal record;

that is also personal information; or

(b)       health information about an individual; or

(c)       genetic information about an individual that is not otherwise health information.

(d)       biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or

(e)       biometric templates.
SECTION B – Consideration of personal information privacy
  1. PRIVACY STATEMENT
    • Auburn Capital’s Compliance Officer must ensure that at all times the provisions of this policy are implemented in the day to day running of Auburn Capital.
    • Compliance Officer must ensure that at all times this Policy:
      • is current and reflects the latest applicable Australian laws; and
      • contains the following information:
    • the kinds of personal information that Auburn Capital collects and holds;
    • how Auburn Capital collects and holds personal information;
    • the purposes for which Auburn Capital collects, holds, uses and discloses personal information;
    • how an individual may complain about a breach of the Australian Privacy Principles, or other relevant legislation that binds Auburn Capital, and how Auburn Capital will deal with such a complaint;
    • whether Auburn Capital is likely to disclose personal information to overseas recipients;
    • if Auburn Capital is likely to disclose personal information to overseas recipients, the countries in which such recipients are likely to be located if it is practicable to specify those countries in this policy.
      • Auburn Capital must ensure that the Auburn Capital’s Privacy Statement is available free of charge and in such form as appropriate. Auburn Capital will make the Privacy Statement available on its website.
      • If the Privacy Statement is requested in a particular form, Auburn Capital will take such steps as are reasonable to provide the Privacy Statement in the form requested.
SECTION C – COLLECTION OF PERSONAL INFORMATION (Solicited personal information)
  1. PERSONAL INFORMATION (OTHER THAN SENSITIVE INFORMATION)
    • This Section C applies to the collection of personal information that is solicited by Auburn Capital.
    • Auburn Capital must not collect personal information (other than sensitive information) unless the information is reasonably necessary for one or more of Auburn Capital’s functions or activities.
    • Auburn Capital’s functions or activities include the provision of corporate advisory and wealth management services to its clients.
  2. SENSITIVE INFORMATION
    • Auburn Capital must not collect sensitive information about an individual unless:
      • the individual consents to the collection of the information and the information is reasonably necessary for one or more of Auburn Capital’s functions or activities (as described in section 5.3); or
      • the collection of the information is required or authorised by or under an Australian law or a Court/Tribunal order; or
      • a permitted general situation exists in relation to the collection of the information by Auburn Capital; or
      • a permitted health situation exists in relation to the collection of the information by Auburn Capital.
  1. MEANS OF COLLECTION
    • Auburn Capital must only collect personal information by lawful and fair means.
    • Auburn Capital must only collect personal information about an individual from the individual (rather than someone else), unless it is unreasonable or impracticable to do so or the individual has instructed Auburn Capital to liaise with someone else.
    • Auburn Capital will collect personal information from an individual when:
      • Auburn Capital’s onboarding forms are completed;
      • a Client provides the information to Auburn Capital’s representatives over the telephone, in person or via email;
      • a Client provides the information to Auburn Capital on the website;
      • provides information in connection with any other type of financial service that Auburn Capital is assisting with respect to.
  1. INFORMATION COLLECTED BY Auburn Capital
    • The information Auburn Capital collects may include the following:
      • name;
      • date of birth;
      • postal or email address; or
      • phone numbers;
      • other information Auburn Capital considers necessary to their functions and activities.
  1. PURPOSE OF COLLECTION
    • If an individual is acquiring or has acquired a product or service from Auburn Capital, the individual’s personal information will be collected and held for the purposes of:
      • checking whether an individual is eligible for Auburn Capital’s product or service;
      • providing the individual with Auburn Capital’s product or service or arranging for the products or services from a third party;
      • managing and administering Auburn Capital’s or a third party’s product or service;
      • protecting against fraud, crime or other activity which may cause harm in relation to Auburn Capital’s products or services;
      • complying with legislative and regulatory requirements in any jurisdiction;
      • to assist Auburn Capital in the running of its business.
    • Auburn Capital may also collect personal information for the purposes of letting an individual know about products or services that might better serve their needs or other opportunities in which they may be interested. Please refer to Section G for further information.
SECTION D – COLLECTION OF PERSONAL INFORMATION (Unsolicited personal information)
  1. DEALING WITH UNSOLICITED PERSONAL INFORMATION
    • If Auburn Capital:
      • receives personal information about an individual; and
      • the information is not solicited by Auburn Capital

Auburn Capital must, within a reasonable period after receiving the information, determine whether or not it was permitted to collect the information under Section C above.

  • Auburn Capital may use or disclose the personal information for the purposes of making the determination under paragraph 10.1.
  • If Auburn Capital:
    • determines that it could not have collected the personal information; and
    • the information is not contained in a Commonwealth record,

Auburn Capital must as soon as practicable, destroy the information or ensure that the information is de-identified, only if it is lawful and reasonable to do so.

SECTION E – Notification of the collection of personal information
  1. NOTIFICATION OF COLLECTION
    • This section 11 applies to:
      • solicited information; and
      • unsolicited information to which section 10 does not apply.
    • Auburn Capital must notify the individual of the following matters in the Privacy Statement:
      • Auburn Capital’s identity and contact details;
      • if Auburn Capital collects the personal information from a third party or the individual is not aware that Auburn Capital has collected the personal information, the fact that Auburn Capital so collects, or has collected the information and the circumstances of that collection;
      • if the collection of the personal information is required or authorised by or under an Australian law or a Court/Tribunal order, the fact that the collection is so required or authorised (including the details of the law or court);
      • the purposes for which Auburn Capital collects the personal information;
      • the main consequences (if any) for the individual if the information is not collected by Auburn Capital;
      • any other entities to which Auburn Capital usually discloses personal information of the kind collected by Auburn Capital;
      • that Auburn Capital’s Privacy Statement and this Privacy Policy contains information about how the individual may access the personal information about the individual that is held by Auburn Capital and seek correction of such information;
      • that Auburn Capital’s Privacy Statement contains information about how the individual may complain about a breach of the Australian Privacy Principles and how Auburn Capital will deal with such a complaint;
      • whether Auburn Capital will disclose the personal information to overseas recipients; and
      • if Auburn Capital discloses the personal information to overseas recipients – the countries in which such recipients will be located if it is practicable to specify those countries in the notification or to otherwise make the individual aware of them.
SECTION F – Use or disclosure of personal information
  1. USE OR DISCLOSURE
    • Where Auburn Capital holds personal information about an individual that was collected for a particular purpose (“the primary purpose”), Auburn Capital must not use or disclose the information for another purpose (“the secondary purpose”) unless:
      • the individual has consented to the use or disclosure of the information; or
      • the individual would reasonably expect Auburn Capital to use or disclose the information for the secondary purpose and the secondary purpose is:

directly related to the primary purpose (if the information is sensitive information); or

related to the primary purpose (if the information is not sensitive information);

  • the use or disclosure of the information is required or authorised by or under an Australian law or a Court/Tribunal order; or
  • a permitted general situation exists in relation to the use or disclosure of the information by Auburn Capital; or
  • Auburn Capital reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
  • Where Auburn Capital uses or discloses personal information in accordance with section 12.1(e), Auburn Capital will keep a copy of this disclosure (e.g.: the email or letter used to do so).
  • This section 12 does not apply to:
    • personal information for the purposes of direct marketing; or
    • government related identifiers.
  • If Auburn Capital collects personal information from a related body corporate, this section 12 applies as if Auburn Capital’s primary purpose for the collection was the primary purpose for which the related body corporate collected the information.
  1. WHO DOES AURBURN CAPITAL DISLCOSE PERSONAL INFORMATION TO?
    • Auburn Capital may disclose personal information collected from clients and prospective clients to the following:
      • professional advisers such as lawyers and accountants;
      • insurance companies;
      • financial institutions, including for the purpose of procuring finance for your investments where you have requested us to so;
      • organisations offering products and services which you wish to invest in or obtain;
      • Auburn Capital external service providers;
      • organisations involved in providing, managing or administering Auburn Capital’s product or service such as third-party suppliers, e.g. printers, posting services, and our advisers;
      • organisations involved in maintaining, reviewing and developing Auburn Capital’s business systems, procedures and infrastructure, including testing or upgrading Auburn Capital’s computer systems;
      • organisations involved in a corporate re-organisation;
      • organisations involved in the payments system, including financial institutions, merchants and payment organisations;
      • organisations involved in product planning and development;
      • other organisations, who jointly with Auburn Capital’s, provide its products or services;
      • authorised representatives who provide Auburn Capital’s products or services on its behalf;
      • the individual’s representatives, including your legal advisers;
      • Auburn Capital’s financial advisers, legal advisers or auditors;
      • fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct;
      • external dispute resolution schemes;
      • regulatory bodies, government agencies and law enforcement bodies in any jurisdiction.
SECTION G – Direct marketing
  1. DIRECT MARKETING
    • Auburn Capital must not use or disclose the personal information it holds about an individual for the purpose of direct marketing.
  2. EXCEPTION – PERSONAL INFORMATION OTHER THAN SENSITIVE INFORMATION
    • Auburn Capital may use or disclose personal information (other than sensitive information) about an individual for the purposes of direct marketing if:
      • Auburn Capital collected the information from the individual; and the individual would reasonably expect Auburn Capital to use or disclose the information for that purpose; or
      • Auburn Capital has collected the information from a third party; and either:
    • Auburn Capital has obtained the individual’s consent to the use or disclose the information for the purpose of direct marketing; or
    • it is impracticable for Auburn Capital to obtain the individual’s consent; and
      • Auburn Capital provides a simple way for the individual to opt out of receiving direct marketing communications from Auburn Capital;
      • each direct marketing communication with the individual Auburn Capital:
    • includes a prominent statement that the individual may make such a request; or
    • directs the individual’s attention to the fact that the individual may make such a request; and
      • the individual has not made a request to opt out of receiving direct marketing.
  1. EXCEPTION – SENSITIVE INFORMATION
    • Auburn Capital may use or disclose sensitive information about an individual for the purpose of direct marketing if the individual has consented to the use or disclosure of the information for that purpose.
  2. REQUESTS TO STOP DIRECT MARKETING
    • Where Auburn Capital uses or discloses personal information about an individual for the purposes of direct marketing by Auburn Capital or facilitating direct marketing by another organisation, the individual may request:
      • that Auburn Capital no longer provide them with direct marketing communications;
      • that Auburn Capital does not use or disclose the individual’s personal information for the purpose of facilitating direct marketing by another organisation;
      • that Auburn Capital provides the source of the personal information.
    • Where Auburn Capital receives a request from an individual under section 17.1, Auburn Capital will:
      • give effect to the request under section 17.1(a) or 17.1(b) within a reasonable period after the request is made and free of charge; and
      • notify the individual of the source of the information, if the individual requests it, unless it is impracticable or unreasonable to do so.
    • This Section G does not apply to the extent that the following laws apply:
      • the Do Not Call Register Act 2006;
      • the Spam Act 2003; or
      • any other Act of the Commonwealth of Australia.
SECTION H – Cross border disclosure of personal information
  1. DISCLOSING PERSONAL INFORMATION TO CROSS BORDER RECIPIENTS
    • Where Auburn Capital discloses personal information about an individual to a recipient who is not in Australia and who is not Auburn Capital or the individual, Auburn Capital must ensure that the overseas recipient does not breach the Australian Privacy Principles (with the exception of APP1).
    • The countries we may disclose an individual’s personal information to include:
      • United States of America;
      • United Kingdom and other Europeans countries;
      • Japan;
      • Singapore;
      • Hong Kong;
      • People’s Republic of China.
    • Section 18.1 does not apply where:
      • Auburn Capital reasonably believes that:
    • information is subject to a law or binding scheme that has the effect of protecting the information in a way that is at least substantially similar to the way in which the Australian Privacy Principles protect the information; and
    • there are mechanisms that the individual can access to take action to enforce that protection of the law or binding scheme; or
      • both of the following apply:
    • Auburn Capital has informed the individual that if they consent to the disclosure of information Auburn Capital will take reasonable steps to ensure the overseas recipient does not breach the Australian Privacy Principles; and
    • after being so informed, the individual consents to disclosure;
      • the disclosure of the information is required or authorised by or under an Australian law or a Court/Tribunal order; or
      • a permitted general situation (other than the situation referred to in item 4 or 5 of the table in subsection 16A (1) Privacy Act) exists in relation to the disclosure of the information by Auburn Capital.
SECTION I – Adoption, use or disclosure of government identifiers
  1. ADOPTION OF GOVERNMENT RELATED IDENTIFIERS
    • Auburn Capital must not adopt a government related identifier of an individual as its own identifier unless:
      • Auburn Capital is required or authorised by or under an Australian law or a Court/Tribunal order to do so; or
      • the identifier, Auburn Capital and the circumstances of the adoption are prescribed by regulations.
  1. USE OR DISCLOSURE OF GOVERNMENT RELATED IDENTIFIERS
    • Before using or disclosing a government related identifier of an individual, Auburn Capital must ensure that such use or disclosure is:
      • reasonably necessary for Auburn Capital to verify the identity of the individual for the purposes of the organisation’s activities or functions; or
      • reasonably necessary for the organisation to fulfil its obligations to an agency or a State or Territory authority; or
      • required or authorised by or under an Australian law or a Court/Tribunal order; or
      • within a permitted general situation (other than the situation referred to in item 4 or 5 of the table in subsection 16A (1) Privacy Act; or
      • reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
      • the identifier, Auburn Capital and the circumstances of the adoption are prescribed by regulations.
SECTION J – Integrity of personal information
  1. QUALITY OF PERSONAL INFORMATION
    • Auburn Capital will ensure that the personal information it collects and the personal information it uses or discloses is, having regard to the purpose of the use or disclosure, accurate, up to date, complete and relevant.
  2. SECURITY OF PERSONAL INFORMATION
    • Auburn Capital will ensure that it protects any personal information it holds from misuse, interference, loss, unauthorised access, modification and disclosure.
    • Auburn Capital will take reasonable steps to destroy or de-identify any personal information it holds where:
      • Auburn Capital no longer needs the personal information for any purpose for which the information may be used or disclosed by Auburn Capital;
      • the information is not contained in a Commonwealth record;
      • Auburn Capital is not required to retain that information under an Australian law, or a Court/Tribunal order.
  1. STORAGE OF PERSONAL INFORMATION
    • Auburn Capital stores personal information in different ways, including:
      • hard copy on site at Auburn Capital’s offices;
      • electronically secure data centres which are located in Australia and owned by either Auburn Capital or external service providers;
      • electronically on personal phones and computers.
    • In order to ensure Auburn Capital protects any personal information it holds from misuse, interference, loss, unauthorised access, modification and disclosure, Auburn Capital implements the following procedure/system:
      • access to information systems is controlled through identity and access management;
      • employees are bound by internal information securities policies and are required to keep information secure;
      • all employees are required to complete training about information security;
      • Auburn Capital regularly monitors and reviews its compliance with internal policies and industry best practice.
SECTION K – Access to, and correction of, personal information
  1. ACCESS
    • Auburn Capital must give an individual access to the personal information it holds about the individual if so requested by the individual.
    • Auburn Capital must respond to any request for access to personal information within a reasonable period after the request is made.
    • Auburn Capital must give access to the information in the manner requested by the individual, if it is reasonable and practicable to do so and must take such steps as are reasonable in the circumstances to give access in a way that meets the needs of Auburn Capital and the individual.
    • Auburn Capital must not charge an individual for making a request and must not impose excessive charges for the individual to access their personal information.
  2. EXCEPTIONS
    • Auburn Capital is not required to give an individual access to their personal information if:
      • Auburn Capital reasonably believes that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or
      • giving access would have an unreasonable impact on the privacy of other individuals; or
      • the request for access if frivolous or vexatious; or
      • the information relates to existing or anticipated legal proceedings between Auburn Capital and the individual, and would not be accessible by the process of discovery in those proceedings; or
      • giving access would reveal intentions of Auburn Capital in relation to negotiations with the individual in such a way as to prejudice those negotiations; or
      • giving access would be unlawful; or
      • denying access is required or authorised by or under an Australian law or a Court/Tribunal order; or
      • Auburn Capital has reason that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been, or may be engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or
      • giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
      • giving access would reveal evaluative information generated within Auburn Capital in connection with a commercially sensitive decision-making process.
  1. REFUSAL TO GIVE ACCESS
    • If Auburn Capital refuses to give access in accordance with section 24 or to give access in the manner requested by the individual, Auburn Capital will give the individual a written notice that sets out:
      • the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so; and
      • the mechanisms available to complain about the refusal; and
      • any other matter prescribed by the regulations.
    • Where Auburn Capital refuses to give access under section 25.1(j) Auburn Capital may include an explanation of the commercially sensitive decision in its written notice of the reasons for denial.
SECTION L – Correction of personal information
  1. CORRECTION OF INFORMATION
    • Auburn Capital must take reasonable steps to correct all personal information, having regard to the purpose for which the information is held where:
      • Auburn Capital is satisfied the information is inaccurate, out of date, incomplete, irrelevant or misleading; or
      • the individual requests Auburn Capital corrects the information.
    • Where Auburn Capital corrects personal information about an individual that Auburn Capital previously disclosed to another APP entity and the individual requests Auburn Capital to notify the other APP entity of the correction, Auburn Capital must take reasonable steps to give that notification, unless it is impracticable or unlawful to do so.
  2. REFUSAL TO CORRECT INFORMATION
    • If Auburn Capital refuses to correct personal information as requested by the individual, Auburn Capital will give the individual a written notice that sets out:
      • the reasons for the refusal except to the extent that it would be unreasonable to do so; and
      • the mechanisms available to complain about the refusal; and
      • any other matter prescribed by the regulations.
  1. REQUEST FROM A CLIENT TO ASSOCIATE A STATEMENT WITH THEIR INFORMATION
    • If:
      • Auburn Capital refuses to correct personal information as requested by the individual; and
      • the individual requests that Auburn Capital associate a statement noting that the information is inaccurate, out of date, incomplete, irrelevant or misleading, with the individual’s information,

Auburn Capital must take such steps as are reasonable in the circumstances to associate the statement (as described in section 29.1(b)) with the individual’s personal information. The statement should be associated with the information in such a way that will make the statement apparent to users of the information.

  1. DEALING WITH REQUESTS
    • Auburn Capital must:
      • respond to requests under this Section L within a reasonable period after the request is made; and
      • must not charge the individual for the making of the request, for correcting the personal information or for associating the statement with the personal information.
SECTION M – MAKING A PRIVACY COMPLAINT
  1. COMPLAINTS
    • Auburn Capital offers a free internal complaint resolution scheme to all customers. Should a client have a privacy complaint, they are to contact Auburn Capital to discuss their concerns using the following contact details:
  • Email: [email protected]
  • Post: PO Box 302, Hawthorn VIC 3122.
    • To assist Auburn Capital in helping customers, Auburn Capital asks customers to follow a simple three-step process:
  • gather all supporting documents relating to the complaint;
  • contact Auburn Capital to review your situation and if possible, resolve your complaint immediately; and
  • if the matter is not resolved to the customer’s satisfaction, customers are encouraged to contact Auburn Capital’s Complaints Officer at [email protected] or put their complaint in writing and send it to PO Box 302, Hawthorn VIC 3122.
    • Auburn Capital will rectify any breach if the complaint is justified and takes necessary steps to resolve the issue.
    • In certain situations, to deal with a complaint it may be necessary to consult with third parties. However, any disclosure of Personal Information to third parties will be provided with the customer’s authority and consent.
    • After a complaint has been received, Auburn Capital sends the customer a written notice of acknowledgement setting out the process. The complaint is investigated, and the decision sent to the customer within thirty (30) days unless the customer has agreed to a longer time. If a complaint cannot be resolved within the agreed time frame or a decision could not be made within thirty (30) days of receipt, a notification will be sent to the customer setting out the reasons and specifying a new date when the customer can expect a decision or resolution.
    • If the customer is not satisfied with Auburn Capital’s internal privacy practices or the outcome in respect to complaint, the customer may approach the OAIC with their complaint:

Office of the Australian Information Commissioner

Address: GPO Box 5218, Sydney NSW 2001

Phone: 1300 363 992

Email: [email protected]

Website: oaic.gov.au

SECTION N – MISCELLANEOUS
  1. NOTIFIABLE DATA BREACHES SCHEME
    • Under the Privacy Amendment (Notifiable Data Breaches) Act 2017 (“Privacy Amendment Act”) Auburn Capital is required to notify the Office of the Australian Information Commissioner (“OAIC”) in relation to all eligible data breaches.
    • Auburn Capital must notify the OAIC by lodging a Notifiable Data Breach Form soon as practicable. The Notifiable Data Breach Form is available at the following link: https://forms.business.gov.au/smartforms/landing.htm?formCode=OAIC-NDB.
    • Under the Privacy Amendment Act, Auburn Capital must also promptly inform clients whose personal information has been compromised by the eligible data breach that a breach of their personal information has occurred.
  2. POLICY BREACHES
    • Breaches of this Policy may lead to disciplinary action being taken against the relevant party, including dismissal in serious cases and may also result in prosecution under the law where that act is illegal. This may include re-assessment of bonus qualification, termination of employment and/or fines (in accordance with the Privacy Act).
    • Staff are trained internally on compliance and their regulatory obligation to Auburn Capital. They are encouraged to respond appropriately to and report all breaches of the law and other incidents of non-compliance, including Auburn Capital’s policies, and seek guidance if they are unsure.
    • Staff must report breaches of this Policy directly to the Compliance Officer.
  3. RETENTION OF NOTIFIABLE DATA BREACH FORMS
    • The Compliance Officer will retain the completed Notifiable Data Breach Forms for seven (7) years in accordance with Auburn Capital’s Document Retention Policy. The completed forms are retained for future reference and review.
    • As part of their training, all staff are made aware of the need to practice thorough and up to date record keeping, not only as a way of meeting Auburn Capital’s compliance obligations, but as a way of minimising risk.
  4. POLICY REVIEW
    • Auburn Capital’s Privacy Policy will be reviewed on at least an annual basis by the Compliance Officer of Auburn Capital, having regard to the changing circumstances of Auburn Capital. The Compliance Officer will then report to the Director on compliance with this Policy.