Our
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Privacy Policy


This Policy was last updated in august 2026.

Privacy Policy (“Policy”)

Daniel Allison & Associates Pty Ltd ACN 146 014 039 and its related entities (“we”, “our” or “us”) is committed to protecting the personal and credit related personal information (“credit information”) that we may collect and hold about you.  This Policy sets out our policies relating to management of your personal information and credit information.  These policies are based on our obligations under the Privacy Act 1988 (Cth) (“Act”) (including Australian Privacy Principles (“APPs”) and Part IIIA (Credit reporting).

By voluntarily supplying us with your personal or credit information, you are agreeing to be bound by this Policy.

Any amendments to this Policy will be notified to you by posting an updated version on our website.

Please note that our website contains links to other websites.  When a user has clicked on a link to another site, they leave our site and are no longer protected by this Policy.



Collection of personal information

We gather personal information that is required for operating our business, evaluating and addressing the needs of our clients and prospective clients, promoting our services, satisfying our legal obligations, and delivering our services. The specific purpose for which we typically gather and utilise personal information is determined by the nature of your dealings with us.

When you make an enquiry regarding our services or enter into a client relationship, a record is created containing any personal information you have supplied to us at that time. The personal information we may collect and hold about you may differ based on the circumstances and the particular services you seek from us, but will generally include:

  • contact information such as your name and address, telephone numbers and email address along with additional contact details;

  • your tax file number;

  • superannuation and insurance information;

  • employment details;

  • details regarding your interactions with us and any of our other clients;

  • financial information including investments, shareholdings, bank account details and credit card details;

  • business details, including Australian Business Number (“ABN”);

  • identification documents including passport and drivers licence details, identifiers and identity documents issued by Australian government bodies, and identifiers and identity documents issued by foreign governments; and

  • any further personal information that you supply to us, or permit us to gather, in connection with your relationship or dealings with us.

Where it is pertinent to the services we deliver to you or to our broader relationship with you as a client, we may additionally gather and retain personal information about you that constitutes sensitive information as defined by the Privacy Act.

Sensitive information encompasses any details concerning an individual’s racial or ethnic background, political views, affiliation with a political organisation, religious convictions or associations, philosophical beliefs, membership of a professional or trade body, trade union membership, sexual orientation or conduct, criminal history, health-related information, and particular genetic or biometric data.

We will not request that you reveal sensitive information unless doing so is required to deliver our services to you, for staff recruitment, or where it is otherwise necessary in the circumstances. Should you choose to volunteer sensitive information without being asked, it may be recorded and retained where it is reasonably necessary for our functions or activities (or where otherwise authorised by law).



Credit Information

In addition, we may collect and hold credit information about you while delivering our services. The categories of credit information that we may gather and retain include:

  • type and amount of credit sought;

  • information concerning defaults;

  • details relating to court proceedings;

  • particulars of your obligations in relation to consumer credit; and

  • trade references – name of entity, ABN, contact name, telephone number, fax number, email, years trading with you.

Where we gather or retain credit information, we do so for the purpose of assisting in credit management. You may request access to any credit information we hold about you, seek amendment of that information, or enquire as to how your credit information has been used, by contacting us via the details set out below.

Personal information collected for Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) compliance

We are classified as a reporting entity pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act). The AML/CTF Act imposes a legal obligation on us to collect and verify certain personal information, and we may be prevented from providing certain services if we are unable to fulfil this requirement.

Where required for compliance with the AML/CTF Act and the associated Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Rules), we may collect, store, use, and disclose personal information for purposes such as customer due diligence, continuous customer monitoring, risk evaluation, reporting to regulatory bodies, and maintaining records. In particular, we may collect Know Your Customer (KYC) Information as required under the AML/CTF Act, including:

  • the identity of our customer (as that term is defined in the AML/CTF Act) together with their contact information;

  • any information that supports verifying a person’s identity (including details extracted from government-issued identification documents, copies of identification documents, facial photographs, liveness data, biometric data, and verification metadata);

  • the identity of any individual on whose behalf our customer is acquiring the service;

  • the identity of any individual acting as a representative of the customer, including evidence of their authority to do so;

  • where the customer is not a natural person, the identity of any beneficial owners;

  • whether the customer, a beneficial owner, or any person acting on their behalf is a politically exposed person or a person subject to targeted financial sanctions;

  • information concerning the source of wealth and the source of funds;

  • the nature and purpose of the business relationship or transaction; and

  • information relating to any other matter prescribed by the Rules.

Personal information (including sensitive information) for AML/CTF purposes is collected only where it is reasonably necessary to satisfy our legal obligations and solely in relation to matters where a designated service is being, or is reasonably expected to be, provided. Not all legal engagements necessitate the collection of personal information for AML/CTF purposes.

Where we utilise electronic or biometric identity verification methods, we may also engage external verification service providers to confirm identity information, assess whether an individual corresponds to an identity document, conduct liveness or fraud assessments, and produce verification results.

Where required by law, or where it is reasonably necessary having regard to ongoing risks connected with AML/CTF purposes, the verification method used, audit requirements, fraud risk, disputes, regulatory inquiries, enhanced due diligence, suspicious matter evaluation, or continuing customer due diligence, we may keep limited copies or images of identity documents, facial photographs, or associated verification materials to maintain compliance with the AML/CTF Act and related Rules.

When personal information is collected for AML/CTF purposes, we do not retain full copies of identity documents (for example, passports or driver licences). We only keep the specific information required by law, such as pertinent identification particulars, the type of document used for verification, verification results, and AML/CTF risk assessments.

As a general rule, we aim to collect personal information directly from the relevant individual. Where this is not practicable, we may obtain personal information about individuals from third parties, including publicly available sources. In those circumstances, we will take reasonable steps to notify the affected individuals about the collection of their information.

If you are among our ‘business contacts’ (for example, a person employed by one of our clients or suppliers, or within a government agency or other organisation with which we engage when you communicate with one of our employees or partners, or a contact person at one of our vendors, or in a government agency or organisation with which we interact), we may automatically collect basic business contact information from you (such as your name, title, and work contact details) using the information contained in your email signature.

In connection with the AML/CTF Act, we may collect sensitive information, including biometric data, for the purpose of conducting identity verification. We will seek your consent and issue a notification via our verification provider prior to the biometric verification process commencing, unless a particular legal exception applies. Apart from the circumstances described above, we may collect sensitive information without consent where doing so is required or permitted under the AML/CTF Act. This may encompass information relevant to ascertaining whether an individual is a politically exposed person or is subject to sanctions.

Cookies

We may use “cookies” or similar technologies to collect data.  A cookie is a small file, typically of letters and numbers, downloaded on to a device when you access our website.  Our website may collect the following information from users:

  • your server address;

  • your top level domain name (for example, .com, .gov, .au etc);

  • the date and time of your visit to the site;

  • the pages you accessed;

  • the previous site you have visited; and

  • the type of browser you are using.

Means of collection of personal and credit information

Your personal and credit information may be collected in a number of ways, including:

  • directly from you, or from the entity for which you serve as an employee, director or principal by our staff when you seek, or enquire about, our services; or

  • when you use our website or complete a form on our website.

In some circumstances, where it is unreasonable or impracticable to collect information from you, we may collect information about you from a third party source.  For example, we may collect information from government bodies, law enforcement agencies, your business associates, your professional advisers, commercial counterparties, search providers, service providers, your employer, parties to whom you direct us, or from publicly accessible sources (including public registers, social media platforms, and online searches).

You need not provide all the information requested by us, but this may prevent us from providing some or all of our services to you.

Use, disclosure & purpose

We collect, hold and disclose your personal and credit information for the following purposes:

  • as a necessary part of providing our services to you;

  • managing invoicing, payments, and the recovery of outstanding debts;

  • to promote and market our services to you or provide you with information that we believe may be of interest to you (unless as directed otherwise);

  • to help us research the needs of our customers and to market our services with a better understanding of your needs and the needs of customers generally;

  • meeting our legal and regulatory requirements; and

  • other purposes related to any of the above.

We will only use your information for the purposes for which it was collected (“primary purposes”) or a purpose related to the primary purpose, if this use would be reasonably expected by you, or otherwise, with your consent.

We may disclose your information to necessary third parties, such as SMSF software providers and document storage provider (for example, Microsoft and Dropbox) who assist us to provide, manage and administer our services.  Information provided to third parties will be dealt with in accordance with that entity’s privacy policy.

We utilise your personal information to satisfy our obligations under the AML/CTF Act and AML/CTF Rules, including for the purposes of customer due diligence, monitoring, reporting, and maintaining records, and to disclose information to regulators such as AUSTRAC where required or permitted by law.

We may also use and disclose your personal information for additional purposes communicated to you at the point of collection, or as otherwise described in this Privacy Policy.

Disclosure to Recipients Outside Australia

We may disclose personal information outside of Australia to business and accounting software providers and file sharing and storage service providers located in the United States of America.

When acting on behalf of certain clients, it may be necessary or appropriate to disclose personal information to recipients located overseas. The jurisdictions in which such overseas recipients are situated will depend on the particular circumstances of the client's matter, and it is not feasible to identify them in this Privacy Policy.

Quality, access to & correction of information

You are entitled to have access to and seek correction of any personal information that we may hold about you.  We require that requests for access to or to update or correct your personal information to be in writing outlining the details of your request.  Such requests should be addressed to the Privacy Officer via the details provided in this Policy.

We will take appropriate steps to verify your identity (or verify that you act as an authorised agent of the individual concerned) before granting a request to access your personal information.

We will respond to your request for access to your personal information within a reasonable time after you make the request and if access is granted, access will be provided within 30 days from your request.  We will, on request, provide you with access to your personal information or update or correct your personal information, unless we are lawfully excluded from granting your request, including if:

  • giving access would be unlawful;

  • we are required or authorised by law or a court/tribunal order to deny access; or

  • giving access is likely to prejudice one or more enforcement related activities conducted by an enforcement body.

Where your request for access is accepted, we will provide you with access to your personal information in a manner, as requested by you, providing it is reasonable to do so.

Your request for correction will be dealt with within 30 days, or such longer period as agreed by you.  If we deny your request, we will provide you with a written notice detailing reasons for the refusal and the process for making a complaint about the refusal to grant your request.

We will accept your request for correction of your credit information where we are satisfied that it is inaccurate, out-of-date, incomplete, irrelevant or misleading.

Upon accepting a request for correction of your personal information, we will take all steps that are reasonable in the circumstances, having regard to the purpose for which your information is held, to correct your personal information.

If your request for correction of credit information is accepted we will provide written notice of this correction to any entity to which we have disclosed this information previously, to the extent that this is practicable.

Storage and Security

Your personal and credit information will be stored as physical files in a secured area, on our electronic data base system and on computers with appropriate back up and security systems.  Any personal or credit information which is held on our computer systems, is protected by safeguards including physical, technical (including firewalls and SSL encryption) and procedural methods.

We take reasonable steps to hold information securely in electronic or physical form.  We are committed to keeping secure the data you provide to us and we will take all reasonable precautions to protect your personally identifiable information from loss, misuse, interference, unauthorised access or alteration.

Personal information collected for AML/CTF purposes, including KYC information, is kept only for the period required by law. When it is no longer necessary for AML/CTF or other authorised purposes, personal information is securely disposed of or de-identified in accordance with relevant legal requirements.

We aim to achieve this through:

  • imposing confidentiality requirements on our employees;

  • implementing policies in relation to document storage security;

  • implementing security measures to govern access to our systems;

  • only providing access to personal information once proper identification has been given;

  • controlling access to our premises; and

  • implementing website protection measures.

Dealing with us anonymously

Where lawful and practicable to do so, you can deal with us anonymously or using a pseudonym.  You can deal with us anonymously or using a pseudonym when making a general enquiry about the services that we can offer to you including via telephone or our website.

At the time you engage our services, it is no longer practicable for you to deal with us anonymously or using a pseudonym.

Credit Information Notifiable Matters

We do not disclose your credit information to any credit reporting bodies.  Any credit information we collect and/or hold about you will be dealt with in accordance with this Policy.

Complaints

If you believe that we have breached a term of this Policy or the Act you may submit a written complaint.  The written complaint can be emailed or posted to us using the contact details set out below.  You must include contact details for us to contact you regarding your complaint.

Our Privacy Officer will consider your complaint and respond as soon as reasonably possible, but not more than 30 days from receiving the complaint.

If you are unsatisfied with the outcome of your complaint you may refer your complaint to the Office of the Australian Information Commissioner to be resolved.

Contact us

If you wish to:

  • gain access to your personal information;

  • make a complaint about a breach of your privacy;

  • contact us with a query about how your information is collected or used;

  • contact us regarding any other matter concerning this Policy,

you can speak directly with our staff who will do their best to try to resolve your issue as simply as possible. Alternatively, you can write to us or send us an email so that our Privacy Officer can consider the matter. We will respond to you as soon as reasonably possible.

If you do not wish to receive direct marketing from us, please contact our Privacy Officer via the details below.
Our contact details are as follows:

Phone:  03 9006 5400
Postal address: PO Box 282, South Melbourne VIC 3205 ‍

For more information on privacy see the Office of the Australian Information Commissioner’s website at: http://www.oaic.gov.au.

Liability limited by a Scheme approved under Professional Standards Legislation.

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Privacy Collection Notice


This privacy collection notice from Daniel Allison & Associates Pty Ltd ACN 146 014 039, Daniel Allison & Associates Legal Pty Ltd ACN 146 431 665 and their related entities (we) explains why we collect your personal information, what we collect, how we collect it and who we share it with.



WHY WE NEED TO COLLECT YOUR INFORMATION

We collect your personal information to comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), including to:

  • establish and verify your identity before providing certain services to you or the person on whose behalf you are instructing us

  • continuously assess and manage potential money laundering, terrorism financing, proliferation financing risks or related compliance risks

  • make reports and comply with record keeping obligations required under the AML/CTF Act

  • share information with regulators (such as AUSTRAC) where we are mandated or authorised by law to do so

WHAT PERSONAL INFORMATION WE COLLECT

We collect the following types of personal information:

  • your full name, date of birth, residential address

  • photo ID and unique identifier, such as a passport or driver’s licence number

  • information about whether you are an individual subject to targeted financial sanctions

We may also collect the following sensitive information:

  • whether you are a member of any political association or a politically exposed person

  • facial biometric data

  • criminal history checks

In some circumstances we may also be required to collect information about source of funds and/or source of wealth, which may be obtained from a range of sources including information about your salary and wages, dividends, investments, inheritance, gifts, assets and any other sources of income or wealth.

When personal information is collected for AML/CTF purposes, we do not keep copies of complete identity documents (such as passports or driver licences). We retain only the particular information required by law, such as relevant identification details, the category of document relied upon, verification outcomes, and AML/CTF risk assessments.

Where we collect sensitive information, including your biometric data, to carry out identity verification, we will obtain your consent and provide notification through our verification provider before the biometric verification process takes place, unless a specific legal exception applies. We may collect sensitive information without consent where this is required or authorised under the AML/CTF Act. This may include information relevant to determining whether an individual is a politically exposed person or subject to sanctions.

HOW WE COLLECT YOUR INFORMATION

We will generally collect your personal information:

  • directly from you; and/or

  • using a third-party search and identity verification service provider

We may also collect personal information about you from third parties such as:

  • registers of companies (e.g. the Australian Securities and Investments Commission)

  • registers of trusts and businesses (i.e. the Australian Business Register)

  • search engines (e.g. Google)

  • court registries

  • regulatory bodies, revenue offices, land registries, councils

  • financial institutions

  • professional intermediaries

  • other publicly available sources

The third party service providers we currently use to verify your identity and to search other records and/or registries is GBG CloudCheck and/or BGL ID.

WHO WE MAY SHARE YOUR INFORMATION WITH

When we collect your personal information in the context of our AML/CTF obligations, we will only share or disclose your personal information where required by law or where you have authorised us to do so.

You agree that we may provide information collected from you to third parties as necessary to conduct searches and verify your information.

You agree that we may also share your personal information with the Australian Transaction Reports and Analysis Centre (AUSTRAC) to meet our legal and regulatory obligations under the AML/CTF Act or the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025.

WHAT HAPPENS IF WE CANNOT COLLECT YOUR INFORMATION

If you do not provide us with your personal information and other information we request from you, we may not be able to verify your identity and provide you (or the person on whose behalf you are instructing us) with the services you have requested.

YOUR PRIVACY RIGHTS AND OUR PRIVACY POLICY

Our Privacy Policy contains further information about how we handle your personal information, including whether your personal information may be disclosed overseas and how you can access and correct your personal information. It also explains how to lodge a complaint and how that complaint will be managed if you are concerned about how we have handled your information. Our privacy policy can be accessed via our website.

HOW TO CONTACT US ABOUT YOUR PRIVACY‍ ‍

Email: 
compliance@daassociates.com.au

Post: 
Attention: Privacy Of
ficer
Daniel Allison and Associates
PO Box 282
South Melbourne VIC 3205


Telephone: 
+61 3 9006 5400

‍ ‍

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CPD Policy

Daniel Allison & Associates Superannuation Pty Ltd [AFSL No. 487858] (we, us)

Overview

Continuing Professional Development (CPD) encompasses the wide variety of learning activities undertaken by professionals on an ongoing basis to maintain their technical knowledge and skills and to continually develop such competencies in existing and emerging areas. We consider CPD and the quality of advice and services to be directly correlated. For this reason, CPD plays an important part in our advisers’ professional and personal development within our business. Our advisers means our employees and directors and any employees and directors of our related bodies corporate who provide financial advice on our behalf.

We are required to have a CPD policy which sets out our processes for ensuring our financial advisers who are our accountants which are authorised to provide advice under our Limited AFSL undertake CPD required to comply with the CPD legislative framework and ensure they are providing services to a competent and professional standard.  This policy is published on our website and is also available internally to all staff.



What is the legislative framework?

CPD requirements are prescribed by the Corporations Act, the Corporations (Relevant Providers Continuing Professional Development Standard) Determination 2018 (Determination) and Financial Adviser Standards and Ethics Authority (FASEA). FASEA is the governing body that regulates training and education standards for advisers.

Advisers are required to undertake CPD every CPD year to improve their knowledge and competencies within broader CPD categories. A minimum number of hours have to be completed in each CPD category, but the CPD in total must meet the minimum hour requirements for each CPD year. Our CPD year is a calendar year.

Full-time advisers are required to complete at least 40 hours of ‘qualifying CPD’ each CPD year and ensure that they have met the minimum hour requirements in each CPD category. Part-time advisers can apply to us to reduce their total CPD load to 36 hours of qualifying CPD, although that is subject to our written approval which we will only provide if we are reasonably satisfied that the reduced load will not compromise the adviser’s skills and competence.

What comprises ‘qualifying CPD’ is set out in the Determination. Qualifying CPD must:

– be based on content relevant to a CPD category;

– have sufficient intellectual or practical content;

– primarily deal with matters related to the provision of financial product advice, financial advice services and financial advice businesses;

– be conducted by 1 or more persons who are appropriate and have sufficient standing, expertise, academic qualifications and/or practical experience; and

– be designed to enhance advisers’ knowledge and skills in areas that are relevant to the provision of financial product advice and financial advice services.

– 70% of the qualifying CPD undertaken by our advisers must be approved by us. Qualifying CPD will usually take the form of courses, presentations or other educational material that meets the criteria set out above. It may also constitute professional or technical reading (maximum of 4 hours) and formal education (maximum of 30 hours).


How we ensure compliance? 

It is our responsibility to promote a culture of professional learning and development. Our role in ensuring advisers comply with their CPD obligations can be summarised in four separate components:

  • Approving CPD. We are responsible for approving activities as qualifying CPD. This requires us to ensure the CPD activity meets the requirements set out above. We will only approve the CPD activity as a qualifying CPD activity for the period of time in which the activity meets the requirements. This provides us with flexibility to pro-rate CPD where a portion of it met the requirements, but another portion of it did not. We will maintain a list of CPD which we have approved as a qualifying CPD activity along with the time period that can be attributed to that activity. Qualifying CPD may include seminars, presentations (whether provided internally or external) online education courses, conferences and reading material. We are required to approve a sufficient number of qualifying CPD activities to enable advisers to meet their CPD requirements.

  • Training Plans. This is the document that identifies areas where the adviser can improve their competence, knowledge and skills and describes the types of qualifying CPD activities the adviser will complete during the CPD year to achieve those improvements. We will work with the adviser to formulate a training plan which meets these objectives and our overall business strategy. We don’t approve training plans, unless the adviser is returning to work from a career-break.

  • Supervision. We are responsible for ensuring advisers undertake qualifying CPD they are required to complete in accordance with their training plans. Their progress will be monitored throughout the CPD year, which may be in the form of regular catch-ups or reminders. Advisers are responsible for updating our training register promptly upon completing a qualifying CPD activity.

  • Compliance with training plans is a key performance indicator for our advisers. We will provide them with all the assistance we can reasonably provide to ensure our advisers comply with their training plans. Where an adviser does not comply with their plan, this will affect their performance scorecard and may also lead to us restricting or revoking the adviser’s authority to provide financial advice. We will also comply with our legal obligations with respect to such failure, including reporting it on ASIC’s financial adviser register.

  • Career Breaks. We are responsible for approving training plans for advisers who are returning to work after a continuous period of absence of least 2 years. These advisers cannot resume practice until we have approved their training plan. Approval of the training plan is at our absolute discretion, but at a minimum, we will need comfort that the training plan is appropriate in addressing all gaps in the adviser’s competence, knowledge and skills which have arisen as a result of their absence from practice.



Training records

Advisers are required to obtain records of qualifying CPD they undertake and must promptly provide those to us so we can substantiate their attendance/completion of CPD. Completion of qualifying CPD will be recorded on the training register, which we maintain for this purpose. We will keep these records for a period of 7 years or as otherwise required by our document retention procedures.



Monitoring and review

We will continually monitor the effectiveness of the procedures set out in this policy. We may amend it from time to time by uploading the updated policy to our website.

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Complaints Handling Policy


How to make a complaint

We want to give our clients the best experience, so if you’re unsatisfied in any way we’d like you to tell us about it.

We’ll take your feedback seriously and aim to resolve your complaint in a respectful, fair and reasonable way as quickly as we can. We ask that you treat us with respect also and provide us with reasonable assistance during the process.

Our complaints process

1. Collect any documents or records that relate to your complaint, including information on any relevant times, dates and names that could assist our investigation.

2. Get in touch with us and tell us about your complaint, including what happened and how you think it could be fairly resolved. You may need to provide us with some personal information, including your name and contact details which we will collect in accordance with our privacy statement.

The best way to contact us is by telephone at 03 9006 5400 or email at superannuation@daassociates.com.au.

You can also make an anonymous complaint, but it will likely make it more difficult for us to investigate and resolve your complaint. If you prefer, you can authorise someone else to talk to us on your behalf, for example, a friend or family member, a legal representative or financial counsellor.

3. We will acknowledge your complaint and try to resolve it as quickly as possible, if not straight away.


How long will the process take?

We aim to resolve all complaints as quickly as possible. If we can’t give you an answer immediately, we’ll aim to get back to you within 5 business days.

Some complaints require more investigation. If this happens with your complaint, we’ll give you a written response within 30 days of receiving your complaint. We’ll also keep you informed of our progress.

If we can’t resolve your complaint within 30 business days, we’ll get in touch to explain why and let you know how to contact the Australian Financial Complaints Authority (“AFCA”).



What happens if you’re not happy with our response?

We provide financial services under the licence held by Daniel Allison & Associates Superannuation Pty Ltd. As a financial services business, Daniel Allison & Associates Superannuation Pty Ltd is required to be a member of AFCA, which provides free external dispute resolution services to consumers. If you’re not happy with our response, you can refer your complaint to AFCA.

Australian Financial Complaints Authority (AFCA)
GPO Box 3
Melbourne VIC 3001


Phone: 1800 931 678
www.afca.org.au

Email: info@afca.org.au

If your complaint is about privacy, you should contact The Office of the Australian Information Commissioner.

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001

Phone: 1300 363 992
oaic.gov.au

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