Privacy Policy
This Privacy Policy (Policy) applies to personal information collected by Atrium Investment Management Pty Ltd (ABN 17 137 088 745) (Atrium). At Atrium, we are committed to ensuring the confidentiality and security of your personal information. This Policy outlines why we need to collect personal information and how we manage the personal information we collect, hold, use and disclose about individuals, including customers and potential customers.
‘Atrium’, ‘we’, ‘us’ or ‘our’ refers to Atrium and their representatives. Atrium is a wholly owned entity within the Fitzpatricks Group of companies.
Australian Privacy Principles
Atrium maintains all personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APP). Your privacy is important to us and we respect the confidentiality of the personal information that you provide. We are committed to being open with you about how we use your personal information.
Why do we collect and hold your personal information
Atrium will collect, hold, use and disclose personal information that is reasonably necessary for us to provide financial products and services to you (including investment management services). It may also be used to keep you informed about the range of products and services offered by the Fitzpatricks Group of companies. We may also collect, hold, use and disclose your personal information for related purposes for which your personal information was originally collected or you have consented, such as:
- verify your identity and process your application and/or redemptions;
- administering and managing our products and services;
- helping us improve the products and services offered to our customers;
- we may use de-identified and aggregated information for analytical, reporting and system improvement purposes, including to understand customer trends and improve our services.
- complying with our legal obligations (e.g. for taxation, anti-money laundering and counter-terrorism financing purposes);
- assisting with your questions and / or complaints;
- arranging services to be provided by third parties;
- for enforcement related activities conducted by, or on behalf of, an enforcement body;
- which is authorised or required by a court/tribunal order or an Australian law;
- assisting with our internal operations (e.g. record keeping, data analytics, auditing or training purposes); or
- promoting other products and services that may be of interest to you, including inviting you to social events (provided you have opted in to receive this information).
You can opt out of receiving marketing information from us at any time (refer to the ‘Queries and Complaints’ section below).
The information we may collect
As a provider of financial services, we are subject to legislative and regulatory requirements which require us to obtain and hold detailed information which personally identifies you. Accordingly, we may ask you for a range of personal information to assist us in providing you with relevant products and services.
The type of personal information we may collect from you can include, but is not limited to, your:
- name and address;
- date of birth;
- contact details;
- financial information (e.g. bank account details);
- employment details;
- tax file numbers;
- residency status; and
- citizenship status.
We may also need to collect other personal information relating to your finances, assets and liabilities, current investments, income, marital status and gender to assist us in the provision of our services to you.
In certain situations, the personal information we collect may (where appropriate and where it is permitted by law) include sensitive information (for example, to comply with anti-money laundering laws we may collect information about an individual’s political connections and/or whether they have a criminal record).
Source of information
Wherever practicable, we will collect information from you personally. We may also collect your personal information from external sources, for example, from other professional advisers, or our service providers.
Disclosure of Collected Information
The personal information we collect and hold will be used for the provision of financial products and services to you, including financial product advice and investment management services. This may involve disclosure to related parties within the Fitzpatricks Group of companies. In some instances, it may be necessary for us to disclose your personal information to third parties outside the Fitzpatricks Group. Unless you consent to this disclosure, we will not be able to provide you with our services.
The types of organisations to whom we may disclose your personal information include, but are not limited to:
- regulators, such as the Australian Transaction Reports and Analysis Centre (AUSTRAC), the Australian Securities and Investments Commission (ASIC), the Australian Tax Office (ATO) and the Australian Prudential Regulation Authority (APRA);
- financial institutions for the provision of financial products such as investments, superannuation, and life insurance;
- organisations providing mailing services, maintenance of information technology services and printing standard documents and correspondence;
- organisations providing research, technical (tax, legal, etc) or paraplanning services;
- your adviser(s);
- companies within the Fitzpatricks Group;
- organisations we may contract with to provide us with a service (such as software providers);
- any party acquiring an interest in our business; and
- where the law requires or permits us to do so.
From time to time, we may also use your personal contact details to send you information that we think may be of interest to you. You may instruct us not to send this information to you by contacting us either by phone or in writing (refer to the ‘Queries and Complaints’ section below). For analytical and product development purposes, we will de-identify your data.
Data Quality
It is our aim to ensure the information we hold about you is accurate, complete and up to date. If you believe at any stage that the information we hold is inaccurate, or incomplete in any way, please contact us and provide evidence of the inaccuracy. If the information we hold is wrong, we will correct it.
Accessing Collected Information
If you wish to access the personal information we hold about you, please contact us. Atrium will always ask you to identify yourself to our satisfaction and provide us with a reason for requesting the information. We will facilitate access to the information by discussing with you how you would like to receive access to the information and what manner would be most appropriate. You may ask us to correct any information we have to your satisfaction.
Data Security
The security of your personal information is important to us. We take reasonable steps to protect the personal information we hold from loss, interference, destruction, unauthorised access,
modification or disclosure using both physical and electronic security measures. We maintain strong governance over outsourced providers to ensure that contractual and regulatory obligations are met. Your personal information is held in a combination of secure computer-based storage facilities and lockable filing cabinets, or in a secure filing room. We use security procedures and update our technology to protect your personal information. The people within our organisation who handle your personal information are only those who have the need to access it and they have the training and skills to protect your personal information from unauthorised access or misuse.
If our service providers have access to your personal information, we require them to have appropriate privacy policies and procedures to adequately protect your information.
We are required by law to keep your personal information for a certain period of time. When we no longer require the information for any purpose, we will destroy by secure means or permanently de–identify the information.
Identifiers
We will not adopt as our own any identifiers that you may provide to us such as Tax File Numbers, or Medicare numbers.
Anonymity
The nature of financial services does not lend itself to treating clients with anonymity. For us to provide you with a financial service, we require personal information about the individual for whom the service is provided.
Data Breach Management
Despite all efforts, in the event there is a privacy incident or breach, Atrium will assess, investigate and remediate the incident or breach in accordance with its Data Breach Plan. This may include (but not limited to):
- containment measures to prevent further exposure; and/or
- suspending affected processes or systems; and/or
- applying secure deletion; and/or
- de-identification where required; and/or
- notification to affected individuals. If the breach meets the criteria for a Notifiable Data Breach under Australian law, Atrium will notify the Office of the Australian Information Commissioner and impacted individuals promptly, providing clear guidance on steps they should take to protect themselves.
Where required by applicable privacy laws, Atrium will notify relevant regulators and affected individuals of an eligible data breach.
Transborder Data Flows
Atrium will not send any personal information about you overseas unless you consent, or Atrium believes that the other country has privacy laws substantially like our own, or Atrium provides the information in other circumstances giving like protection. Atrium may also store your personal information on servers based overseas or in the “cloud”, or other types of networked or electronic storage.
Some of the entities we share your information with may be, or have operations, outside Australia. Your information may be stored or accessed by parties in jurisdictions, including: India, Malaysia, New Zealand, Philippines, United Kingdom and the United States of America. When we disclose your personal information overseas, we will take reasonable measures to ensure that your information is held, managed and accessed in accordance with the standards that apply in Australia, including the Australian Privacy Principles.
Cookies
When you visit our website, details may be recorded about your visit, such as the time and date, server address, pages accessed, time spent and type of browser. This information is used in an anonymous form for statistical purposes and, as such, cannot identify you individually.
We may use cookies to identify your browser so that the next time you visit our website, we remember your log in details. A cookie is a small file which remains on your computer and contains information enabling Atrium’ website to recognise your browser. If you do not wish to permit the use of cookies, you can adjust the settings on your browser to reject cookies or notify you when they are being used.
Links to Third Party Websites
Atrium’s website may have links to external third-party websites that may benefit the user. External websites should contain their own privacy statements, and we recommend that you review them when using their websites. Please note that third party websites are not covered by our Policy, nor are they subject to our privacy standards and procedures.
Contact us about privacy
We are committed to ensuring that the personal information we collect, hold, use and disclose is relevant, accurate, complete and up-to-date.
We encourage you to contact us to update any personal information we hold about you. We may seek to verify your identity before we process any correction requests to make sure that the personal information we hold about you is sufficiently protected.
Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We will not charge you for correcting the information.
Queries and Complaints
If you require further information about our Policy or wish to make a complaint about possible breaches of your privacy, you should direct your complaint to the attention of the Privacy Officer via email at legalriskcompliance@atriuminvest.com.au.
Alternatively, you may contact us by phone on (02) 9248 8090 or investors@atriuminvest.com.au
It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you are entitled to contact the OAIC (enquiries@oaic.gov.au) who may investigate the complaint further.
Policy Review
From time to time, Atrium will review this Policy. Atrium reserves the right to change this Policy at any time without notification.
Last updated on 12 February 2026