What information do we collect and how do we use it?
We will ask you for personal information when we assist you with your finance. We use the information you provide to advise about and assist with your credit needs. We only provide your information to the companies with whom you choose to deal (and their representatives).
We also use your information to send you requested product information and to enable us to manage your ongoing relationship with us e.g. invoicing, client surveys etc. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.
We may occasionally notify you about promotions, new services and special offers, events or articles we think will be of interest to you. We may send you regular updates by email or by post. If you would rather not receive this information, email or write to us.
We may also use your information internally to help us improve our services and help resolve any problems.
What if you don’t provide some information to us?
If you don’t provide us with full information, we can’t properly advise or assist you with your credit needs.
How do we hold and protect your information?
We strive to maintain the reliability, accuracy, completeness, and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements We hold the information we collect from you via a secure online platform.
We ensure that your information is safe by password protecting this platform and having this password regularly changed, as well as monitored and scanned.
Will we disclose the information we collect to anyone?
We do not sell, trade, or rent your personal information to others.
We may need to provide your information to our credit licensee e.g. for administration and supervision activities, contractors who supply services to us e.g. to handle mailings on our behalf, or to other companies in the event of a corporate sale, merger, re-organisation, dissolution or similar event. However, we will do our best to ensure that they protect your information in the same way that we do.
We may also provide your information to others if we are required to do so by law or under some unusual other circumstances which the Privacy Act permits
How can you check, update or change the information we are holding?
Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate.
If you wish to access or correct your personal information please write to Prashant Nagarajan at email@example.com.
We do not charge for receiving a request for access to personal information or for complying with a correction request. Further, we do not charge for providing access to personal information.
By asking us to assist with your credit needs, you consent to the collection and use of the information you have provided to us for the purposes described above.
Tell us what you think
We welcome your questions and comments about privacy. If you have any concerns or complaints, please contact Prashant Nagarajan on 0421 713 460 or firstname.lastname@example.org.
Internal Dispute Resolution
If you do have a complaint, please let us know by email, because if we don’t know about it we can’t fix it. You may also contact us by email addressed to; The Complaints Officer at Prashant Nagarajan on 0421 713 460 or email@example.com, please make sure you include as much information as you can.
You should explain the details of your complaint as clearly as you can. You must do this in writing. When we receive a complaint, we will attempt to resolve it promptly.
At Lifespan Financial Planning (Lifespan) we recognise that your privacy is very important. Our business is governed by legislation protecting your personal information, including the Privacy Act 1988 and Australian Privacy Principals (APPs) Privacy Amendment (Enhancing Privacy Protection) Act 2012 which replace the National Privacy Principles established under the Privacy Amendment (Private Sector) Act 2000.
A summary of the Australian Privacy Principles is available by contacting our office.
ANONYMITY AND PSEUDONYMITY
You have the option of not identifying yourself or using a pseudonym when dealing with Lifespan unless it is impracticable for us to deal with you in this manner. If you elect to not identify yourself for a financial service we will inform you if it is impractical in those circumstances.
As a provider of financial services, we are subject to certain legislative and regulatory requirements, which necessitate us obtaining and holding detailed information, which personally identifies you and/or contains information or an opinion about you. In addition, our ability to provide you with a comprehensive financial planning and advice service is dependent on us obtaining certain personal information about you, including:
- employment details and employment history
- details of your financial needs and objectives
- details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, insurance cover and superannuation
- details of your investment preferences and aversion or tolerance to risk
- information about your employment history, employment circumstances, family commitments and social security eligibility and
- health information (required for some types of insurance)
We are required pursuant to the
- Corporations Act 2001,
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006,
- Taxation Administration Act 1953,
- Australian Securities and Investments Commission Act 2001,
- Superannuation Guarantee (Administration) Act 1992,
- Superannuation (Unclaimed Money and lost members) Act 1999
as those acts are amended and any associated regulations and Rules of Professional Conduct of the Financial Planning Association of Australia (FPA) to collect sufficient information to ensure appropriate advice can be given in respect of recommendations made to our clients.
Failure to provide the personal information referred to above may expose you to higher risks in respect of the recommendations made to you and may affect the adequacy or appropriateness of advice we give to you.
Generally, collection of your personal information will be effected in either face to face interviews, over the telephone or by way of an online client engagement form. Additional and/or updated personal information may be collected through one or more of those methods as required.
Information may be received from 3rd parties such as accountants, solicitors or referring entities. This information will usually be information that we determined could have been collected from you directly. However, should we determine otherwise and the information is not contained in a Commonwealth record, we will as soon as practicably possible either destroy or de-identify it as long as it is lawful to do so.
USE AND DISCLOSURE
We will only collect, maintain and use Personal Information about you if it is necessary for us to adequately provide to you the services you have requested including:
- the preparation of your financial plan
- the provision of financial planning advice to you
- making securities and investment recommendations
- reviewing your financial plan
- reviewing securities and investment recommendations
- risk management
We will not use or disclose Personal Information collected by us for any purpose other than:
- the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
- where you have consented to such disclosure; or
- where the Australian Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.
We are required under the Rules of Professional Conduct of the FPA to make certain information available for inspection by the Association on request to ensure ongoing compliance with mandatory professional standards. This may involve the disclosure of your personal information. We are also obliged pursuant to the Corporations Act to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission (ASIC).
We may use the personal information collected from you for the purpose of providing you with direct marketing material such as articles that may be of interest to you, however you may, by contacting us by any of the methods detailed below, request not to receive such information and we will give effect to that request. Please allow 2 weeks for your request to be actioned.
We may disclose your personal information to another financial planner during periods when this office is unmanned or closed so that you can be assured of receiving a continued service.
We may disclose your Personal Information to superannuation fund trustees, insurance providers, and product issuers for the purpose of giving effect to your financial plan and the recommendations made by us.
As part of our service it is likely that we will share your personal information with indivduals overseas as some of our staff and contractors are located in other countries. The countries where this may occur are:
- The Philippines
Your information is stored in Australia and when used overseas is only accessed remotely by individuals that we have provided authorisation and access to.
We may store your information in a cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held.
If we do disclose your personal information to an overseas organisation we will take reasonable steps to ensure that the overseas organisation complies with the APPs or the equivalent legislation in its jurisdiction.
In the event that we propose to sell our business we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Any such disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be mishandled or disclosed by them. In the event that a sale of our business is to take place and depending on the transaction type, the consent of the individuals concerned before the sale is made may be sort, All clients will be advised of the transfer of their personal information to the purchaser of the business.
DOCUMENT SECURITY AND STORAGE
Your personal information is maintained securely and is generally held in your client file. Information may also be held in a computer database. We will seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure.
ACCESS AND CORRECTION
You may at any time, request access to your personal information by contacting your adviser (our Authorised Representative) or Privacy Officer. We will (subject to the following exceptions) provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. We will, prior to providing access in accordance with this policy, require you to provide evidence of your identity.
We will not provide you with access to your personal information if:
- providing access would pose a serious threat to the life or health of a person
- providing access would have an unreasonable impact on the privacy of others
- the request for access is frivolous or vexatious
- the information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings
- providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations
- providing access would be unlawful
- denying access is required or authorised by or under law
- providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security
In the event we refuse access to your personal information, we will provide you with an explanation for that refusal.
We will endeavour to ensure that, at all times, the personal information about you which we hold is up to date and accurate. In the event that you become aware, or believe, that any Personal Information which we hold about you is inaccurate, incomplete or outdated, you may contact us by any of the methods detailed below and provide to us evidence of the inaccuracy or incompleteness and we will, if we agree that the information requires correcting, take all reasonable steps to amend the information.
We will endeavour to respond to any request for document access within 14-30 days depending on the complexity of the information and/or the request. If your request is urgent please indicate this clearly.
Generally, we will not adopt or use an identifier (eg, TFNs, Medicare numbers, etc) that has been assigned by a government agency and may be provided by you to group, sort or identify people. We will only disclose the information to another entity where you authorise that disclosure or where we are required to do so by law (e.g. tax File Numbers to product issuers or trustees of superannuation fund).
INFORMATION COLLECTED ONLINE
While it is not necessary to register your personal details to use our Web site, we do offer a registration service which will enable you to receive product and service updates, newsletters and other information. In the event you do register with us, we will collect personal information from you including your name and e-mail address.
If you have registered with us and you wish to update your registration details or decide, at any time, that you do not wish to receive any further information from us, you can give effect to this by following the instruction on the website or by contacting us directly.
Level 23, 25 Bligh Street, Sydney 2000
PO Box R686, Royal Exchange Sydney 1225
Telephone: (02) 9252 2000
Facsimile: (02) 9252 2330
ADDITIONAL PRIVACY INFORMATION
Further information on privacy in Australia may be obtained by visiting the website of the Australian Information Commissioner at www.oaic.gov.au