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Back to Stepping Stones


PRIVACY POLICY 

1. Introduction – AustralianSuper respects your privacy

The following is information about AustralianSuper’s Privacy Policy and the way
in which AustralianSuper has implemented the requirements of the Privacy Act
1988.

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.

References throughout this Privacy Policy to “members” may in some situations
mean non-members, for instance, when you are browsing our website, applying to
become a member, entering a competition on one of our social media platforms or
applying for a job at AustralianSuper.

In certain circumstances, none of which relate to the personal information of
members of AustralianSuper, AustralianSuper is also obliged to comply with the
UK's General Data Protection Regulation (UK GDPR), the EEA's General Data
Protection Regulation (GDPR) and the UK Data Protection Act 2018 (DPA), the PRC
Personal Information Protection Law (PIPL) and its related laws and
regulations.  Information regarding this is set out in the “Non-Member UK & EEA
Specific Addendum” to this Privacy Policy. The Non-Member UK & EEA Specific
Addendum and Non-Member PRC Specific Addendum do not apply to members of
AustralianSuper.

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.

In some instances, you will provide us with the personal information of other
individuals (such as your nominated beneficiaries). If this happens, it is your
responsibility to: (a) tell these individuals that you have provided their
details to AustralianSuper and (b) provide them with a copy of AustralianSuper’s
Privacy Collection Statement and Privacy Policy.

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.

Personal information including health information is held and stored by us
and/or our administrator. Our insurers will also hold and store personal and
health information in accordance with their own privacy policy.

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 retirement accounts, including any
   insurance entitlements, and keep you informed about your accounts and
   entitlements 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 and enable you to receive financial advice
 * 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.
 * send you offers that could benefit you through our trusted partners where you
   have opted in to receive “Other Member Benefits” in our Communication
   Preferences Centre.

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
 * with financial advisers (and their third party service providers) for the
   purpose of enabling you to receive financial advice
 * 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 (including trusted
   partners) 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 retirement accounts, including any insurance
entitlements, 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 FNZ (Australia) Pty Ltd out of New Zealand
 * where, following an interaction that you have had with us, we send you a text
   message or email asking 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.

Some financial advisers may have offshore staff or use service providers, which
may be based offshore or have offshore operations, to assist them with member
administration activities in the context of providing financial services to you.

Our staff in our UK or US offices may also access your personal information for
the purposes described in section 4 above.

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.

The secure pages of the AustralianSuper website and mobile App (where you
log-in) use cookies to provide secure, personalised services. A cookie is a
small text file sent to the user’s browser that allows the web page server to
retrieve information from the computer. Cookies can either be temporary session
cookies, or stored permanently on a computer. They are used for a range of
purposes, including security and personalising services.

AustralianSuper uses cookies on the unsecured pages of the website (where
log-ins are not required) to obtain information regarding the use of the website
and to deliver relevant information to you. By using the website you agree to
AustralianSuper’s use of technology of this type. You can configure your
preferences and options in your browser to reject all cookies, however this
means you may be unable to view secure pages of the website.

AustralianSuper also uses 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 and logs into the secure
pages of the website or mobile App an identification number is collected for
internal analytical purposes only.

Cookies also used on our website, include the following:

“first party cookies”, which are created by a website when you visit it,
including:  Google Analytics; Google Optimize; Marketo; Akamai; Microsoft Azure;
Microsoft Clarity; Dynatrace Real User Monitoring; Sitecore Content Management
System; and

“third party cookies”, which are used to track delivery of advertisements and
which advertisements have been displayed to a particular user, including by:
YouTube.com; LivePerson; and Vix Verify.

AustralianSuper’s website has links to other internet sites. Once you leave our
website, the guidelines of this privacy policy no longer apply. Please read
carefully the relevant privacy policies or terms and conditions governing these
linked sites to ensure your privacy is protected.

Our website may also contain links to the websites of our third-party providers
of online advice tools. These third-party websites may collect information about
you, to which AustralianSuper may have access. For more details you need to
check the relevant privacy policy of the third-party service provider.

10. How will AustralianSuper communicate changes to its Privacy Policy or
Privacy Collection Statement?

AustralianSuper may change its privacy policy and privacy collection statement
from time to time. We will post any changes on the relevant pages of the
AustralianSuper website (www.australiansuper.com).

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
130 Lonsdale Street
Melbourne Vic 3000
or email us at: privacy@australiansuper.com

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 UK & EEA SPECIFIC ADDENDUM

In addition to the Privacy Policy, the following information applies to the
collection and use of personal information from people who are not members of
AustralianSuper, and who are domiciled in the United Kingdom or European
Economic Area (“EEA”), with such personal information referred to in this
addendum as “Personal Data”.

1. LEGAL BASIS FOR COLLECTION

In accordance with the UK & EEA GDPR, we have a legitimate interest in
collecting and using Personal Data, 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

References at section 7 of the Privacy Policy to transfers of data “overseas”
mean transfers out of Australia of personal information that is not UK or EEA
Personal Data. For the purposes of this addendum, the information at section 7
of the Privacy Policy applies to UK or EEA Personal Data, but “overseas” is
taken to mean transfers outside the UK or EEA. In addition to transfers outside
the UK or EEA, we may also transfer UK or EEA Personal Data within
AustralianSuper which requires transfer of the Personal Data to Australia and
the United States. When we share your Personal Data within AustralianSuper or
outside the UK or EEA, the Personal Data is shared in accordance with our
Privacy Policy including this addendum.

Whenever we transfer Personal Data out of the UK or EEA, we ensure a suitable
degree of protection is afforded to it. Where a transfer is within
AustralianSuper, we ensure that access to Personal Data is restricted to
AustralianSuper staff who require the information to complete the purpose
described at item 1 of this Addendum and at section 4 of the Privacy Policy. A
system of passwords and different levels of access is used to protect the
Personal Data that is held on our system. Where a transfer is to third parties
(including as listed at section 6 of the Privacy Policy), access is only
provided to the extent required for the third party to assist us to complete the
purpose described at item 1 of this Addendum and at section 4 of the Privacy
Policy.

3. RETENTION PERIOD

Personal data will only be retained for a period of 7 years following the date
on which AustralianSuper last had activity associated with that Personal Data.

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 the UK and EEA GDPR, all data subjects have a right to
request from AustralianSuper:

 * access to and rectification or erasure of any Personal Data;
 * a restriction on our processing of the Personal Data; and
 * a cessation to processing or portability of the Personal Data.

If you wish to make any of these requests; or have any other concerns regarding
our collection or use of your Personal Data, you should contact us directly via
the contact details at section 11 of the Privacy Policy. If you have any
concerns regarding our collection or use of your Personal Data and you do not
wish to contact us directly, or if we do not resolve your concerns or complaints
to your satisfaction, you may seek further recourse by contacting your local
courts or data protection authority.

5. FAILURE TO PROVIDE PERSONAL DATA TO US

Provision of Personal Data to us is not mandatory, however where we need to
collect your Personal Data:

 * under the terms of a contract we have with you (if any), and you fail to
   provide that Personal Data 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 Personal Data when requested, we may not be able to involve you
   in those activities.

Document last updated on: 27 June 2023.

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