This Data Management Policy sets out how Keepada Pty Ltd (ACN [to be added]) and its related entities govern data across our advisory, wealth management, business ventures, and foundation activities. It applies to personal information, client and portfolio data, and operational data handled by Keepada, and operates alongside our Privacy Policy.
Keepada maintains a data governance framework consistent with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Data governance responsibilities are held at leadership level, with day-to-day data handling practices embedded across our Global Advisory, Wealth & Asset Management, and Business Ventures teams.
Data handled by Keepada is classified according to sensitivity and purpose, including:
Access to each category is restricted according to role and need.
We retain personal and client data only for as long as reasonably necessary to fulfil the purpose for which it was collected, or as required by law - including AML/KYC record-keeping obligations under Australian financial services regulation. Data no longer required is securely deleted or de-identified.
Keepada applies technical and organisational safeguards appropriate to the sensitivity of the data held, including access controls, encryption where appropriate, and restricted access to client and investment data on a need-to-know basis.
We take reasonable steps to ensure personal information we hold is accurate, complete, and up to date, including by providing individuals the ability to request corrections (see our Privacy Policy).
Where we engage third-party service providers to process data on our behalf - such as IT, hosting, or professional advisory services - we take reasonable steps to ensure they maintain data handling standards consistent with this Policy and applicable Australian law.
Given Keepada’s global family network and international ventures, data may be transferred to or accessed from outside Australia. Where this occurs, we take reasonable steps consistent with APP 8 to ensure appropriate protections apply to overseas recipients.
Keepada maintains procedures to identify, contain, and respond to data breaches, consistent with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth). Where a breach is likely to result in serious harm, we will notify affected individuals and the OAIC as required by law.
Data governance oversight sits with Keepada’s leadership. All team members handling personal, client, or portfolio data are responsible for complying with this Policy and our related privacy and security practices.
This Policy is reviewed periodically to reflect changes in our operations, technology, and Australian regulatory requirements. The “Last updated” date above reflects the most recent revision.