1. Your privacy matters to us

This privacy policy aims to provide you with the information you need to understand how the entities of Australian Retirement Trust deal with your personal information. The policy applies to the Australian Retirement Trust entities, being Australian Retirement Trust Pty Ltd and those entities that are ultimately wholly owned by Australian Retirement Trust Pty Ltd as trustee for Australian Retirement Trust including:

  • Australian Retirement Trust Pty Ltd – ABN 88 010 720 840 as trustee of Australian Retirement Trust (ABN 60 905 115 063), and as an employer;
  • Precision Administration Services Pty Ltd (ABN 47 098 977 667) (‘Precision’) as a provider of superannuation administration services, and as an employer;
  • Sunsuper Financial Services Pty Ltd (ABN 50 087 154 818) as a provider of financial advice services;
  • ART Group Services Limited (ABN 50 125 248 286) as a provider of intragroup services;
  • ART Life Insurance Limited (ABN 79 607 345 853) as a life insurer;
  • QInvest Limited (ABN 35 063 511 580) as a provider of financial advice and other services;
  • ART People Services Pty Ltd (ABN 90 601 938 774) as an employer.

References to ‘we’, ‘us’, or ‘our’ in this policy are references to Australian Retirement Trust.

This policy focuses on our members but applies generally to the following individuals:

  • Members and prospective members of Australian Retirement Trust
  • Members who participate in the ‘Rewards for Members’ program (the ‘Rewards Program’)
  • Beneficiaries (including potential beneficiaries), individuals identified on binding death nominations submitted by members, and third parties authorised by members to act on their behalf
  • Contact persons of employers who pay super to us
  • Certain associates of our employees, contractors, directors, and committee members
  • Individuals representing entities dealing with us in a commercial arrangement
  • Our employees, directors, committee members, and contractors
  • Individuals applying for jobs with us.

1.1 What laws we must follow

We are subject to the Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles.

Other laws require or authorise us to collect your personal information, and/or govern how we deal with this information. These laws include:

  • Spam Act 2003
  • Family Law Act 1975
  • Anti-Money Laundering and Counter-Terrorism Financing Act 2006
  • Superannuation (Unclaimed Money and Lost Members) Act 1999
  • Superannuation Industry (Supervision) Act 1993
  • Superannuation Guarantee (Administration) Act 1992
  • Corporations Act 2001
  • Income Tax Assessment Act 1936
  • Income Tax Assessment Act 1997
  • Taxation Administration Act 1953
  • Identity Verification Services Act 2023.

1.2 Updates to this policy

This policy may be updated from time to time. The most recent policy will be made available on our websites. You should view our website for the current Privacy Policy.

This version of our policy was published 30 April 2025.

2. What is personal information?

Under the Privacy Act, personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

Personal information includes sensitive information. Sensitive information is any personal information about your racial or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual orientation or practices; criminal record; or health, genetic, or biometric information.

2.1 Personal information we collect about you

We may collect and hold a variety of personal information and data about you, including:

  • Your name, date of birth, contact details, and gender
  • Your residency and citizenship status
  • Your identification documents
  • Your tax file number (TFN)
  • Your current and former employment details, including occupation and employment arrangement
  • Information about your super benefits, and financial information such as salary, contributions history, banking details, and your applications for benefit payments
  • Information about your spouse, dependants, and/or beneficiaries for death benefit claims
  • Sensitive information, including health and medical information (i.e. in connection with an insurance application or claim), lifestyle information, and any professional or trade association memberships
  • Information about your investments, assets and liabilities, expenses, estate planning, insurances, income, and tax
  • Information about your family commitments and social security eligibility and entitlements
  • Family law information such as financial agreements or court orders.

The types of personal information we collect will depend on the dealings you have with us. We only collect and hold personal information to look after our members and their super, to provide you with benefits and services including advice services, to improve our services and offerings, and to run our super fund. We collect and hold personal information about our employees, contractors, and applicants for the purpose of enabling us to administer your employment or service provider relationship with us and to consider applicants’ suitability for employment with us.

3. For what purposes do we collect your personal information?

We collect, hold, use, and disclose your information to do things like:

  • Set up your account
  • Invest your money
  • Properly identify you, your beneficiaries, or any agents acting on your behalf
  • Provide you with insurance or assess an insurance claim
  • Pay your superannuation or insurance benefits to you or your beneficiaries
  • Comply with the law
  • Provide you with advice
  • Conduct research to improve our products and services
  • Directly market our products and services to you, including through social media and other digital platforms
  • Provide access to and administer the Rewards Program and similar member programs
  • Assess your job application
  • Run our super fund.
We use your personal information for the purposes for which it was collected, to administer the Australian Retirement Trust superannuation fund including your account/s, for related purposes such as providing you with benefits and services including the assessment of insurance applications and claims or financial product advice, in order to comply with the law, or for another purpose with your consent. 

3.1 Direct marketing

We may also collect, hold, use, and disclose your personal information to provide you with information and offers about our products and services, offers about products and services offered by other parties that we believe may be of interest to you (including by way of direct mail, telephone, email, SMS and MMS, our secure portals, and online advertising and marketing), or to request your feedback for research purposes.

We engage third party service providers to assist us with delivering direct marketing via various channels, including through social media and other digital platforms. We take reasonable steps to ensure that your personal information is protected when disclosing information to these third parties. Sometimes, we may de-identify your information before disclosing it to third parties to facilitate our marketing activities.

We may also use your personal details to send you information about super, seminars or events, financial planning, and other products and services we think you might be interested in. If you don’t want to receive promotional material or participate in market research, please update your contact preferences in Member Online or contact us to let us know.

You always have the right to opt out of receiving direct marketing. You may exercise that right by contacting us as set out below in section 8, or by using the relevant opt-out facilities provided with each communication (e.g. an unsubscribe link). To opt out of online targeted advertising through third parties we have engaged, see our Cookie Policy.

3.2 Insights

We may collect, hold, use, or disclose information about you in order to enable the development of consumer insights so that we can serve you better. This includes being able to better understand your preferences and interests, personalise your experience, and enhance the products and services you receive. This may include combining the information that we hold about you with information about you collected from or held by other partners, service providers, or from public sources. We may also use service providers to undertake the process of creating these consumer insights.

3.3 Document Verification Service

Verifying your identity through the Document Verification Service

From time to time we may ask you to provide certain identification information and documentation (‘Identifying Information’) to us for the purposes of verifying your identity through the Document Verification Service (‘DVS’). The DVS is a Commonwealth, State and territory initiative. Its operation and our use of it is governed by applicable laws including the Identity Verification Services Act 2023, the Identity Verification Rules 2024, and the Privacy Act 1988 (Cth).

DVS Participation Agreement

Our access to and to use of the DVS is subject to our ongoing compliance with the Documentation Verification Service “Participation Agreement” (“DVS Agreement”) that we enter into with the Commonwealth of Australia, as represented by the Commonwealth Attorney-General’s Department.

The DVS Agreement contains safeguards for the privacy of individuals whose identification information is used in requesting or providing the services.

We will always ask for your specific consent

Before you are required to provide any Identifying Information for the purposes of DVS verification, we will ask you to provide your express consent. You are not required to provide your Identifying Information, however if you do not, we may not be able to provide certain services to you, for example we may not be able to pay you a benefit claim.

If you prefer not to be verified electronically you must provide document-based proof of identity. Further information on this option can be found on our Proof of Identity factsheet.

How we use the DVS

Subject to you providing your consent, we use the DVS to verify your identity:

  • as required or authorised by applicable laws, such as the Commonwealth Anti-Money Laundering and Counter-Terrorism Financing Act 2006, for example when we are acting on instructions to transfer member funds; and
  • when it is otherwise reasonably necessary for us to verify your identity for the purposes of our activities or functions, for example, when we open a new account.

We will submit your Identifying Information electronically to the DVS. The DVS then checks whether your Identifying Information matches the original records held by the relevant authorities. The result will simply be ‘yes’ or ‘no’. These processes and our access to and use of the DVS may involve the use of third-party systems and services.

More information about the about the DVS is available on the Australian Government’s IDMatch website idmatch.gov.au.

How the rest of this Privacy Policy applies

This Section 3.3 describes how we collect, use and disclose Identifying Information that you provide to us in connection with our verifying your identity using the DVS. The following clauses of this Privacy Policy do not apply to our collection, use or disclosure of Identifying Information:

  • Clause 4 (When we share your personal information);
  • Clause 5 (How we collect your personal information).

If you believe your personal information has not been handled appropriately for the purpose of requesting and provision of the DVS, you may lodge a complaint with us. Section 8 of this policy outlines our complaint process.

4. When we share your personal information

Sometimes we may give your information to other people, including:

  • A person you have authorised to act on your behalf (e.g. your power of attorney, trustee, financial adviser)
  • Between Australian Retirement Trust entities
  • Our service providers and advisers (e.g. our insurers, IT services and support, mail and electronic mail service providers, professional advisers, research and data analysis services, auditors)
  • Direct marketing service providers
  • Third party vendors providing members with goods and services through the Rewards Program (but only where you have provided your express consent to do so, including as part of a registration process)
  • Medical, health, and wellbeing professionals in connection with an insurance claim
  • Legal bodies (e.g. court, police, regulators such as ASIC or AUSTRAC)
  • Government agencies (e.g. Centrelink, WorkCover, ATO, Department of Veterans’ Affairs)
  • International agencies with your consent (e.g. a KiwiSaver fund)
  • Other organisations (e.g. your employer, other super funds where you are transferring into or out of our fund)
  • Any other person where we are required by law (e.g. your spouse, or former spouse subject to an arrangement under the Family Law Act).

We only disclose your personal information if it is necessary for the purpose the information is being used for, if you have consented to it, or if it is authorised by law. See section 6 for more detail on how we hold and protect your personal information.

4.1 Sharing personal information overseas

Some third-party service providers we share your information with may be located or have operations overseas. Overseas countries where we may disclose your personal information include the United States, Ireland, the Netherlands, France, Canada, New Zealand, Malaysia, Singapore, Hong Kong, India, Czech Republic, the United Kingdom, and the Philippines.

5. How we collect your personal information

We will generally collect your personal information directly from you, your authorised representatives, or your employer. We do collect some information from other third parties such as the ATO and publicly available sources. Situations where we collect your information include:

  • When we receive superannuation payment and other mandatory data sent by your employer, another super fund, or the ATO
  • When you (or a third party you have authorised to act on your behalf) visit our website, log in to Member Online, or call us for information or financial advice – and we may record the call and store the information provided in these interactions
  • When you submit forms or applications to us
  • If you make an insurance claim, we collect information from you, and may collect information from health professionals, your employer, and other third parties service providers
  • If you apply for insurance subject to underwriting, we collect information from you, and may collect information from health professionals
  • If you attend an event that we sponsor, your information may be provided to us by the event organisers with your consent for marketing and research purposes
  • In the event you are involved in family law matters, we may receive information and instruction from solicitors or the Federal Circuit and Family Court of Australia.
  • Where you participate in the Rewards Program. 

5.1 Cookies

Our websites use “cookies” to provide a number of services to you. A cookie is a piece of data that a website can send to your browser, which may then be stored on your computer. Cookies generally allow the website to interact more efficiently with your computer.

Generally, you can set your browser to notify you before you receive a cookie, so that you can decide whether to accept it. You may also be able to set your browser to turn off cookies.

However, sometimes not accepting a cookie may affect your use of our website. We sometimes use cookies to monitor which pages on our website you visit in order to improve our service.

Cookies used on our website include the following:

Google Analytics used for Remarketing, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting.

By using the Australian Retirement Trust website, you consent to our use of cookies unless you have opted out in the manner set out in our Cookie Policy. To find out more information about cookies, including how to opt out of online targeted advertising through third parties we have engaged, see our Cookie Policy.

5.2 Do you have to provide your personal information?

Where possible, we may offer you the opportunity to deal with us anonymously or by using a pseudonym. For example, we can provide general information to you about our products or services, or general guidance on how to fill out our forms, without collecting any personal information.

However, it is normally impracticable for us to deal with you anonymously or by using a pseudonym. For example, if you do not provide your personal information to us, we will be unable to properly administer your benefits, notify you about your entitlements, or adequately provide our services.

6. How we hold and protect your personal information

Your personal information may be held on-site at our offices, in secure premises, or in secure information systems (including in the cloud) operated by us or our service providers. Your information is only accessible by authorised staff, authorised service providers who are engaged by us to perform specific functions and, subject to your express consent, to third party suppliers who provide goods and services that are available to members in connection with the Rewards program.

We take reasonable steps to ensure that your personal information is protected from unauthorised access, disclosure, modification, misuse, or loss. These steps include having:

  • Privacy and security training for our staff
  • Building security measures and surveillance
  • System security measures such as access controls, firewalls, virus scanning, and encryption
  • Security assessments of service providers and Rewards Program vendors and suppliers, and contract provisions requiring the protection of personal information and restrictions on its use.

6.1 Notifiable data breaches

We must notify the Office of the Australian Information Commissioner (OAIC) and affected individuals if we become aware that there are reasonable grounds to suspect an eligible data breach has occurred. An eligible data breach is generally a data breach that is likely to result in serious harm to one or more individuals. We have policies and procedures in place to identify and assess data breaches and to notify the OAIC if required.

7. Accessing and changing your information

You may request access to any of the personal information we hold about you by contacting us as set out in section 8. We will provide you with access to your personal information in accordance with the Privacy Act.

We strive to ensure the personal information we hold about you is correct, complete, and up-to-date. If the information we hold about you is incorrect, incomplete or out-of-date, please let us know by contacting us as set out in section 8 so that we may update this. We may ask you to check the information we hold about you from time to time. We may do this with your annual member statement or when you call us.

8. Enquiries and complaints

You can manage your contact preferences through Member Online, by unsubscribing to any electronic marketing you receive, or by contacting us on 1300 360 750.

If you have any queries or if you believe that we have not managed your personal information as set out in this Privacy Policy, or have otherwise not complied with our obligations under the Privacy Act, you may contact us or lodge a complaint with us by the following means: 

Call: 1300 360 750

Email: Contact us online

Mail:
Privacy Enquiries and Complaints
Australian Retirement Trust Pty Ltd
GPO Box 200
Brisbane QLD 4001

If you make a privacy complaint, we will endeavour to investigate, respond, and resolve the issue within a reasonable timeframe, which is generally within 45 days. If we have not responded within this timeframe, or you are not happy with our response to your complaint, you can refer your complaint to the Australian Financial Complaints Authority (AFCA). AFCA provides fair and independent complaint resolution for financial services. Their service is free to use.

Here’s how you can contact AFCA.

Call: 1800 931 678 (free call)

Mail:

Australian Financial Complaints Authority

GPO Box 3, Melbourne VIC 3001

Email: info@afca.org.au

Website: afca.org.au

View full detail about making a complaint to AFCA

Alternatively, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC) by:

Mail:
GPO Box 5288, Sydney NSW 2001

Fax: +61 2 6123 5145

Website form: https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us

Call: 1300 363 992

View full detail about making a complaint to the OAIC.