SECTION A – INTRODUCTION
- INTRODUCTION
- As part of Capital & Centric Funding Pty Ltd’s (“Capital & Centric Funding Pty Ltd”) process to ensure that it continues to maintain the highest levels of professional integrity and ethical conduct, Capital & Centric Funding Pty Ltd has adopted this Privacy Policy (“Policy”) to manage personal information in an open and transparent manner.
- The provisions of this Policy will assist Capital & Centric Funding Pty Ltd in complying with the requirements of the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles in protecting the personal information Capital & Centric Funding Pty Ltd holds about its clients.
- WHEN DOES THIS POLICY APPLY?
- This Policy applies to all representatives and employees of Capital & Centric Funding Pty Ltd at all times and the requirements remain in force on an ongoing basis.
- GLOSSARY
TERM |
DEFINITION |
APP entity |
means an agency or organisation as defined in section 6 of the Privacy Act. |
Australian law |
means
|
Collects |
Capital & Centric Funding Pty Ltd collects personal information only if Capital & Centric Funding Pty Ltd 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:
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:
|
Holds |
Capital & Centric Funding Pty Ltd 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:
|
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
that is also personal information; or
|
SECTION B – Consideration of personal information privacy
- PRIVACY STATEMENT
- Capital & Centric Funding Pty Ltd’s Compliance Officer must ensure that at all times the provisions of this policy are implemented in the day to day running of Capital & Centric Funding Pty Ltd.
- 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 Capital & Centric Funding Pty Ltd collects and holds;
- how Capital & Centric Funding Pty Ltd collects and holds personal information;
- the purposes for which Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd, and how Capital & Centric Funding Pty Ltd will deal with such a complaint;
- whether Capital & Centric Funding Pty Ltd is likely to disclose personal information to overseas recipients;
- if Capital & Centric Funding Pty Ltd 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.
- Capital & Centric Funding Pty Ltd must ensure that the Capital & Centric Funding Pty Ltd’s Privacy Statement is available free of charge and in such form as appropriate. Capital & Centric Funding Pty Ltd will make the Privacy Statement available on its website.
- If the Privacy Statement is requested in a particular form, Capital & Centric Funding Pty Ltd 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)
- PERSONAL INFORMATION (OTHER THAN SENSITIVE INFORMATION)
- This Section C applies to the collection of personal information that is solicited by Capital & Centric Funding Pty Ltd.
- Capital & Centric Funding Pty Ltd must not collect personal information (other than sensitive information) unless the information is reasonably necessary for one or more of Capital & Centric Funding Pty Ltd’s functions or activities.
- Capital & Centric Funding Pty Ltd’s functions or activities include:
- Litigation Funding
- Litigation Disbursements
- Unsecured Finance
- Secured Finance
- SENSITIVE INFORMATION
- Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd’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 Capital & Centric Funding Pty Ltd; or
- a permitted health situation exists in relation to the collection of the information by Capital & Centric Funding Pty Ltd.
- MEANS OF COLLECTION
- Capital & Centric Funding Pty Ltd must only collect personal information by lawful and fair means.
- Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd to liaise with someone else.
- Capital & Centric Funding Pty Ltd will collect personal information from an individual when:
- Capital & Centric Funding Pty Ltd’s Application Form is completed;
- a Client provides the information to Capital & Centric Funding Pty Ltd’s representatives over the telephone or via email;
- a Client provides the information to Capital & Centric Funding Pty Ltd on the website;
- Submitted via Share Chain application.
- INFORMATION COLLECTED BY Capital & Centric Funding Pty Ltd
- The information Capital & Centric Funding Pty Ltd collects may include the following:
- name;
- date of birth;
- postal or email address; or
- phone numbers;
- other information Capital & Centric Funding Pty Ltd considers necessary to their functions and activities.
- PURPOSE OF COLLECTION
- If an individual is acquiring or has acquired a product or service from Capital & Centric Funding Pty Ltd, the individual’s personal information will be collected and held for the purposes of:
- checking whether an individual is eligible for Capital & Centric Funding Pty Ltd’s product or service;
- providing the individual with Capital & Centric Funding Pty Ltd’s product or service;
- managing and administering Capital & Centric Funding Pty Ltd’s product or service;
- protecting against fraud, crime or other activity which may cause harm in relation to Capital & Centric Funding Pty Ltd’s products or services;
- complying with legislative and regulatory requirements in any jurisdiction;
- to assist Capital & Centric Funding Pty Ltd in the running of its business.
- Capital & Centric Funding Pty Ltd 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)
- DEALING WITH UNSOLICITED PERSONAL INFORMATION
- If Capital & Centric Funding Pty Ltd:
- receives personal information about an individual; and
- the information is not solicited by Capital & Centric Funding Pty Ltd
Capital & Centric Funding Pty Ltd must, within a reasonable period after receiving the information, determine whether or not it was permitted to collect the information under Section C above.
- Capital & Centric Funding Pty Ltd may use or disclose the personal information for the purposes of making the determination under paragraph 10.1.
- If Capital & Centric Funding Pty Ltd:
- determines that it could not have collected the personal information; and
- the information is not contained in a Commonwealth record,
Capital & Centric Funding Pty Ltd 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
- NOTIFICATION OF COLLECTION
- This section 11 applies to:
- solicited information; and
- unsolicited information to which section 10 does not apply.
- Capital & Centric Funding Pty Ltd must notify the individual of the following matters in the Privacy Statement:
- Capital & Centric Funding Pty Ltd’s identity and contact details;
- if Capital & Centric Funding Pty Ltd collects the personal information from a third party or the individual is not aware that Capital & Centric Funding Pty Ltd has collected the personal information, the fact that Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd collects the personal information;
- the main consequences (if any) for the individual if the information is not collected by Capital & Centric Funding Pty Ltd;
- any other entities to which Capital & Centric Funding Pty Ltd usually discloses personal information of the kind collected by Capital & Centric Funding Pty Ltd;
- that Capital & Centric Funding Pty Ltd’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 Capital & Centric Funding Pty Ltd and seek correction of such information;
- that Capital & Centric Funding Pty Ltd’s Privacy Statement contains information about how the individual may complain about a breach of the Australian Privacy Principles and how Capital & Centric Funding Pty Ltd will deal with such a complaint;
- whether Capital & Centric Funding Pty Ltd will disclose the personal information to overseas recipients; and
- if Capital & Centric Funding Pty Ltd 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
- USE OR DISCLOSURE
- Where Capital & Centric Funding Pty Ltd holds personal information about an individual that was collected for a particular purpose (“the primary purpose”), Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd; or
- Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd uses or discloses personal information in accordance with section 12.1(e), Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd collects personal information from a related body corporate, this section 12 applies as if Capital & Centric Funding Pty Ltd’s primary purpose for the collection was the primary purpose for which the related body corporate collected the information.
- WHO DOES Capital & Centric Funding Pty Ltd DISLCOSE PERSONAL INFORMATION TO?
- Capital & Centric Funding Pty Ltd may disclose personal information collected from clients and prospective clients to the following:
- organisations involved in providing, managing or administering Capital & Centric Funding Pty Ltd’s product or service such as third-party suppliers, e.g. printers, posting services, and our advisers;
- organisations involved in maintaining, reviewing and developing Capital & Centric Funding Pty Ltd’s business systems, procedures and infrastructure, including testing or upgrading Capital & Centric Funding Pty Ltd’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 Capital & Centric Funding Pty Ltd’s, provide its products or services;
- authorised representatives who provide Capital & Centric Funding Pty Ltd’s products or services on its behalf;
- the individual’s representatives, including your legal advisers;
- debt collectors;
- Capital & Centric Funding Pty Ltd’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
- DIRECT MARKETING
- Capital & Centric Funding Pty Ltd must not use or disclose the personal information it holds about an individual for the purpose of direct marketing.
- EXCEPTION – PERSONAL INFORMATION OTHER THAN SENSITIVE INFORMATION
- Capital & Centric Funding Pty Ltd may use or disclose personal information (other than sensitive information) about an individual for the purposes of direct marketing if:
- Capital & Centric Funding Pty Ltd collected the information from the individual; and the individual would reasonably expect Capital & Centric Funding Pty Ltd to use or disclose the information for that purpose; or
- Capital & Centric Funding Pty Ltd has collected the information from a third party; and either:
- Capital & Centric Funding Pty Ltd has obtained the individual’s consent to the use or disclose the information for the purpose of direct marketing; or
- it is impracticable for Capital & Centric Funding Pty Ltd to obtain the individual’s consent; and
- Capital & Centric Funding Pty Ltd provides a simple way for the individual to opt out of receiving direct marketing communications from Capital & Centric Funding Pty Ltd;
- each direct marketing communication with the individual Capital & Centric Funding Pty Ltd:
- 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.
- EXCEPTION – SENSITIVE INFORMATION
- Capital & Centric Funding Pty Ltd 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.
- REQUESTS TO STOP DIRECT MARKETING
- Where Capital & Centric Funding Pty Ltd uses or discloses personal information about an individual for the purposes of direct marketing by Capital & Centric Funding Pty Ltd or facilitating direct marketing by another organisation, the individual may request:
- that Capital & Centric Funding Pty Ltd no longer provide them with direct marketing communications;
- that Capital & Centric Funding Pty Ltd does not use or disclose the individual’s personal information for the purpose of facilitating direct marketing by another organisation;
- that Capital & Centric Funding Pty Ltd provides the source of the personal information.
- Where Capital & Centric Funding Pty Ltd receives a request from an individual under section 17.1, Capital & Centric Funding Pty Ltd 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
- DISCLOSING PERSONAL INFORMATION TO CROSS BORDER RECIPIENTS
- Where Capital & Centric Funding Pty Ltd discloses personal information about an individual to a recipient who is not in Australia and who is not Capital & Centric Funding Pty Ltd or the individual, Capital & Centric Funding Pty Ltd 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:
- Australia;
- New Zealand;
- Canada;
- the United Kingdom;
- America.
- Section 18.1 does not apply where:
- Capital & Centric Funding Pty Ltd 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:
- Capital & Centric Funding Pty Ltd has informed the individual that if they consent to the disclosure of information Capital & Centric Funding Pty Ltd will not 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 Capital & Centric Funding Pty Ltd.
SECTION I – Adoption, use or disclosure of government identifiers
- ADOPTION OF GOVERNMENT RELATED IDENTIFIERS
- Capital & Centric Funding Pty Ltd must not adopt a government related identifier of an individual as its own identifier unless:
- Capital & Centric Funding Pty Ltd is required or authorised by or under an Australian law or a Court/Tribunal order to do so; or
- the identifier, Capital & Centric Funding Pty Ltd and the circumstances of the adoption are prescribed by regulations.
- USE OR DISCLOSURE OF GOVERNMENT RELATED IDENTIFIERS
- Before using or disclosing a government related identifier of an individual, Capital & Centric Funding Pty Ltd must ensure that such use or disclosure is:
- reasonably necessary for Capital & Centric Funding Pty Ltd 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, Capital & Centric Funding Pty Ltd and the circumstances of the adoption are prescribed by regulations.
SECTION J – integrity of personal information
- QUALITY OF PERSONAL INFORMATION
- Capital & Centric Funding Pty Ltd 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.
- SECURITY OF PERSONAL INFORMATION
- Capital & Centric Funding Pty Ltd will ensure that it protects any personal information it holds from misuse, interference, loss, unauthorised access, modification and disclosure.
- Capital & Centric Funding Pty Ltd will take reasonable steps to destroy or de-identify any personal information it holds where:
- Capital & Centric Funding Pty Ltd no longer needs the personal information for any purpose for which the information may be used or disclosed by Capital & Centric Funding Pty Ltd;
- the information is not contained in a Commonwealth record;
- Capital & Centric Funding Pty Ltd is not required to retain that information under an Australian law, or a Court/Tribunal order.
- STORAGE OF PERSONAL INFORMATION
- Capital & Centric Funding Pty Ltd stores personal information in different ways, including:
- hard copy on site at Capital & Centric Funding Pty Ltds head office;
- electronically secure data centres which are located in Australia and owned by either Capital & Centric Funding Pty Ltd or external service providers;
- In order to ensure Capital & Centric Funding Pty Ltd protects any personal information it holds from misuse, interference, loss, unauthorised access, modification and disclosure, Capital & Centric Funding Pty Ltd 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;
- Capital & Centric Funding Pty Ltd regularly monitors and reviews its compliance with internal policies and industry best practice.
SECTION K – Access to, and correction of, pesronal information
- ACCESS
- Capital & Centric Funding Pty Ltd must give an individual access to the personal information it holds about the individual if so requested by the individual.
- Capital & Centric Funding Pty Ltd must respond to any request for access to personal information within a reasonable period after the request is made.
- Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd and the individual.
- Capital & Centric Funding Pty Ltd must not charge an individual for making a request and must not impose excessive charges for the individual to access their personal information.
- EXCEPTIONS
- Capital & Centric Funding Pty Ltd is not required to give an individual access to their personal information if:
- Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd and the individual, and would not be accessible by the process of discovery in those proceedings; or
- giving access would reveal intentions of Capital & Centric Funding Pty Ltd 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
- Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd in connection with a commercially sensitive decision-making process.
- REFUSAL TO GIVE ACCESS
- If Capital & Centric Funding Pty Ltd refuses to give access in accordance with section 24 or to give access in the manner requested by the individual, Capital & Centric Funding Pty Ltd 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 Capital & Centric Funding Pty Ltd refuses to give access under section 25.1(j) Capital & Centric Funding Pty Ltd may include an explanation of the commercially sensitive decision in its written notice of the reasons for denial.
SECTION L – Correction of personal information
- CORRECTION OF INFORMATION
- Capital & Centric Funding Pty Ltd must take reasonable steps to correct all personal information, having regard to the purpose for which the information is held where:
- Capital & Centric Funding Pty Ltd is satisfied the information is inaccurate, out of date, incomplete, irrelevant or misleading; or
- the individual requests Capital & Centric Funding Pty Ltd corrects the information.
- Where Capital & Centric Funding Pty Ltd corrects personal information about an individual that Capital & Centric Funding Pty Ltd previously disclosed to another APP entity and the individual requests Capital & Centric Funding Pty Ltd to notify the other APP entity of the correction, Capital & Centric Funding Pty Ltd must take reasonable steps to give that notification, unless it is impracticable or unlawful to do so.
- REFUSAL TO CORRECT INFORMATION
- If Capital & Centric Funding Pty Ltd refuses to correct personal information as requested by the individual, Capital & Centric Funding Pty Ltd 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.
- REQUEST FROM A CLIENT TO ASSOCIATE A STATEMENT WITH THEIR INFORMATION
- If:
- Capital & Centric Funding Pty Ltd refuses to correct personal information as requested by the individual; and
- the individual requests that Capital & Centric Funding Pty Ltd associate a statement noting that the information is inaccurate, out of date, incomplete, irrelevant or misleading, with the individual’s information,
Capital & Centric Funding Pty Ltd must take such steps as are reasonable in the circumstances to associate the statement (as described in section 30.1(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.
- DEALING WITH REQUESTS
- Capital & Centric Funding Pty Ltd 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 – MISCELLANEOUS
- NOTIFIABLE DATA BREACHES SCHEME
- Under the Privacy Amendment (Notifiable Data Breaches) Act 2017 (“Privacy Amendment Act”) Capital & Centric Funding Pty Ltd is required to notify the Office of the Australian Information Commissioner (“OAIC”) in relation to all eligible data breaches.
- Capital & Centric Funding Pty Ltd 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, Capital & Centric Funding Pty Ltd 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.
- Capital & Centric Funding Pty Ltd has also developed a Data Breach Response Plan in accordance with the OAIC’s guidelines to ensure the timely notification of all clients affected by any eligible data breach.
- 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 Capital & Centric Funding Pty Ltd. They are encouraged to respond appropriately to and report all breaches of the law and other incidents of non-compliance, including Capital & Centric Funding Pty Ltd’s policies, and seek guidance if they are unsure.
- Staff must report breaches of this Policy directly to the Director.
- RETENTION OF FORMS
- The Compliance Officer will retain the completed forms for seven (7) years in accordance with Capital & Centric Funding Pty Ltd’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 Capital & Centric Funding Pty Ltd’s compliance obligations, but as a way of minimising risk.
- POLICY REVIEW
- Capital & Centric Funding Pty Ltd’s Privacy Policy will be reviewed on at least an annual basis by the Compliance Officer of Capital & Centric Funding Pty Ltd, having regard to the changing circumstances of Capital & Centric Funding Pty Ltd. The Compliance Officer will then report to the Director on compliance with this Policy.