Privacy Policy

Australian Privacy Principles (APP)

1.       Introduction

Quest  Asset Partners Pty Ltd (Quest) is committed to respecting the privacy of its clients by ensuring that it manages any personal information it collects or holds in accordance with the Australian Privacy Principles (‘APPs’).

This APP Privacy Policy applies from 12 March 2014 and covers Quest’s Wholesale and Sophisticated Investors.

The APP Privacy Policy is available electronically on Quest’s website

2.       Personal information that we collect and hold

Quest will only collect personal information which is necessary to open an account.  Such information may include an individual’s personal contact details and tax file number.  Without this information, Quest would not be able to provide financial services to its clients.

3.       Can an individual remain anonymous when dealing with Quest

Given the nature of Quest’s business it is not practical for Quest to deal with individuals who wish to remain anonymous or would prefer to identify themselves only by way of pseudonym.

4.       How we collect and hold personal information

When collecting, using or disclosing personal information, Quest will ensure, as far as is possible, that the information is accurate, up-to-date and complete.

Quest will only collect personal information in a lawful and fair manner.  Wherever possible, personal information will be collected directly from the individual, unless it is unreasonable or impracticable to do so.  Sensitive information (as defined in the APP) will not be collected.

At or before the time or, if that is not practicable, as soon as practicable after, Quest collects personal information about an individual Quest, will ensure the individual is aware:

(a)     of Quest’s identity and its contact details;

(b)     that the collection of personal information is permitted by Quest  under the Corporations Act 2001 and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006) and/or a particular court/tribunal order;

(c)     of the purpose for which Quest collects the personal information;

(d)     of the main consequences (if any) for the individual if all or some of the personal information is not collected;

(e)     of any other entity (or type of entity) to which Quest generally discloses the personal information it collects;

(f)      that Quest’s APP Privacy Policy contains information about how the individual may:

(i)       access and seek correction of the personal information about the individual that Quest holds; and

(ii)     complain about a breach of the APPs and how Quest will deal with such a complaint; and

(g)     of whether Quest is likely to disclose the personal information to overseas recipients.

Unless permitted by law, Quest will not adopt a government related identifier (e.g. a tax file number) of an individual as its own identifier and it will only disclose such identifiers for the purposes of verifying the identity of the individual, or as permitted by law or as is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

Quest will ensure that in relation to any personal information it holds that it will take such steps as are reasonable in the circumstances to protect the information from:

(a)     misuse, interference and loss; and

(b)     unauthorised access, modification or disclosure.

If there is a suspected or actual data breach which may compromise personal information, Quest will promptly undertake an assessment of the incident.   Where relevant, immediate steps will be taken to contain the breach.  These steps may include limiting any further access or distribution of the affected personal information, or the possible compromise of other personal information.

If the unauthorised access, disclosure or loss of personal information is likely to cause serious harm to one or more individuals and the likely risk of serious harm has not been prevented by remedial action, Quest will notify affected individuals and the Office of the Australian Information Commissioner as soon as practicable.   The notification will include Quest’s identity and contact details, a description of the incident, the kind/s of information concerned and any recommended steps for affected individuals.

Following any data breach incident, Quest will undertake a review process to help prevent future breaches.

If Quest holds information which it no longer needs (for any purpose for which the information may be used or disclosed) or it is no longer required to keep, it will take such steps as are reasonable in the circumstance to destroy the information or to ensure that the information is de-identified.

 Quest does not receive unsolicited information.

5.       The purpose for which Quest  collects, holds, uses and discloses personal information

Quest collects, holds, uses (and discloses) personal information for the purpose of managing our clients’ investment portfolios.

Where Quest collects an individual’s personal information for a particular purpose (i.e. the primary purpose), it will not use that information for another purpose (i.e. a secondary purpose) unless the individual has consented to the use or disclosure of that information or:

(a)     it would be reasonably expected that the information would be disclosed for a secondary purpose which is related to the primary purpose (and in relation to sensitive information for a secondary purpose which is directly related to the primary purpose); or

(b)     the use or disclosure of the information is legally required, specifically authorised by the APPs or reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

Quest will record in writing circumstances where it uses or discloses personal information for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

Quest does not normally disclose personal information about its clients to outside parties, except those contracted to provide services to Quest.  These may include:

(a)     Quest’s contracted service providers – e.g. auditors, lawyers, platform operators, custodian and insurer.

With consent, Quest will disclose personal information to a client’s accountant, financial consultant or other person or organisation they nominate.  Personal information may also be disclosed to the Australian Taxation Office or other government authorities or agencies as required by law.

In the rare situation where Quest uses personal information provided by a source other than the individual for direct marketing purposes, the individual may request Quest to provide details of the source of the information.  Quest will provide this information free of charge and within a reasonable period of time.

If Quest uses the personal information for direct marketing purposes, it will ensure that it complies with the requirements of the Do Not Call Register Act 2006, the Spam Act 2003 and the Corporations Act 2001.

6.       How an individual may access and seek correction of personal information held by Quest

Generally, Quest will provide an individual with access to their personal information in the manner they request and within a reasonable period of time. An individual can request Quest to correct any personal information it holds about that individual.

To apply for access or to request a correction to personal information, contact Quest Asset Partners Pty Ltd:

Telephone:     02 9409 2333

There are no charges for an individual requesting access to personal information.

As set out in the APPs, some exceptions apply.  If Quest relies on one of the exceptions or is unable to provide the personal information in the manner requested by the individual, it will take such steps (if any) as are reasonable in the circumstances to give access in a way that meets the needs of both Quest and the individual and it will provide a written notice setting out:

(a)     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

(b)     the mechanisms available to complain about the refusal; and

(c)     any other relevant matter.

These steps include limiting access to any personal information to a minimum of Quest Staff, deleting any personal information for any ex-clients, holding any personal information insecure storage requiring encryption and two factor access authentication.

Having regard to the purpose for which the personal information is held, if Quest is satisfied that the information is inaccurate, out of date, incomplete, irrelevant or misleading or a request is received from an individual, Quest will take such steps as are necessary to correct that information.  This will be done free of charge within a reasonable period after the request has been made.  If Quest has provided that information to a third party, the individual may request Quest to notify that third party of that correction.

If Quest refuses to correct an individual’s personal information it will provide a written notice to the individual setting out:

(a)     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

(b)     the mechanisms available to complain about the refusal; and

(c)     any other relevant matter.

If Quest refuses to correct an individual’s personal information and the individual requests Quest to associate a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading with that information, Quest must take such steps as are reasonable in the circumstances to associate the statement in such a way that will make the statement apparent to users of the information.  This will be done free of charge within a reasonable period after the request has been made.

7.       How an individual can complain about a breach of the APP’s and how the complaint will be dealt with

An individual may complain to Quest about a breach of the APPs by Quest by contacting the Complaints Officer:

Telephoning:  02 9409 2333

The complaint will be handled in accordance with Quest’s Complaints Policy. An individual can request a copy of the Complaints Policy to be sent to them free of charge.

8.       Is Quest likely to disclosure personal information to overseas recipients?

No, Quest is not likely to disclose personal information about an individual to an overseas recipient.

If at some future time, Quest chooses to disclose personal information about an individual to an overseas recipient, it will either obtain the individual’s informed consent prior to doing so, will be required to do so by Australian law or prior to doing so will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the APPs (other than APP 1) in relation to the information.

Adopted by the Board June 2006
Last amended May 2024