At Totally Integrated Financial Planning, we understand that the privacy of your information is important to you and we respect the confidentiality of the information that you provide to us. Protecting your information is an important part of maintaining trust between us and our clients and by handling information in a secure manner we build strong business relationships.
This information provides details about how we manage the personal information that we collect, hold, use and disclose about individuals.
Why we collect and use personal information
As a financial planning organisation, we are subject to certain legislative and regulatory requirements (including but not limited to the Corporations Act 2001, Tax Agent Services Act 2009, Anti-Money Laundering and Counter-Terrorism Financing Act 2006, Financial Adviser Standards and Ethics Authority) which necessitate us obtaining and holding detailed information, which personally identifies a client and/or contains information or an opinion about a client (“personal information”).
We collect, hold, use and disclose personal information so we can provide you with financial products, advice and services relevant to your needs. We may also collect, use and disclose your information for related purposes such as:
- Complying with our legal obligations, such as verifying your identity
- Assisting with your questions and complaints
- Arranging for services to be provided by third parties
- Internal operations, such as record keeping, data analytics, auditing or training
- Promotion of other products and services that may be of interest to you
We collect, use, hold and sometimes disclose personal information about financial advisers and other people who we do business with (including employees) in order to administer and manage our business operations. This information is afforded the same standard of care as that of our clients.
What personal information we collect
We ask people for a range of personal information to assist us in providing relevant advice, products and services. The information we collect could include (but is not limited to) your name, date of birth, contact details, financial information, employment details, residency and citizenship status. We may also collect the personal information of your family members where it is relevant to the advice being provided.
We may also collect sensitive information about your medical history and your health and lifestyle to provide financial advice about life insurance products. In most instances, we collect personal information directly from you when you:
- complete a financial product application form
- complete an identification form
- complete data collection documentation
- interact with an interactive tool, such as a budget planner
- provide documentation to us
- when you communicate with us in person, over the telephone, fax, email, internet or by using other electronic devices
Situations where we may collect personal information about you from other people and organisations, with your consent include (but are not limited to):
- a financial adviser
- other professionals who act on your behalf, such as a lawyer or accountant
- health professionals
- indirectly from other organisations, who jointly with us, provide products or services to you e.g. fund managers, superannuation funds, life
- insurance companies and other product issuers once you have authorised us to obtain such information or authorised these other parties to
- provide us with this information
- social media and publicly available sites
It is your choice whether to provide your personal information. You have the right to not provide personal information, including about your identity. However, in this case, your adviser will warn you about the possible consequences and how this may impact on the quality of the advice provided. Your adviser may also decline to provide advice if they feel they have insufficient information to proceed. In some instances, we will decline to provide services or advice if we feel we have insufficient information for the scope of the service or advice requested.
Further, in some circumstances the law requires us to obtain and verify details of photographic and non-photographic identification documents.
Cookies and other web technologies
Some personal information may be collected automatically, without your knowledge, whilst navigating through and interacting with the content of our website. The electronic methods of collection we may use include cookies, log files and web beacons.
Web beacons are small pixel files that help us better manage content on our website by allowing us to understand usage patterns, fix issues, and improve the products and services offered to you on our website. Log files may contain information about the devices and browsers used to access our website and help us to diagnose problems, analyse trends, administer the site or mobile application.
The information we collect by these electronic means is generally not stored for long – they are temporary records – and can include device-specific data or log data such as your IP address, device screen size, device type, browser information, referring domain, pages visited, the date and time website pages were visited, and geographic location (country only).
Accessing and updating personal information
You are entitled to request access to your file for the purpose of reviewing and correcting the information held.
The documents that may be contained in your client file may include, but are not limited to: data collection forms; written communications (such as letters and emails); Statements of Advice (SoAs), Records of Advice (RoAs); tax returns; transaction letters; signed authorities; investment, superannuation and personal insurance applications or statements produced by the issuers of financial products, and fee invoices.
There may be circumstances where we refuse to provide you with the information you request, for example when the information is commercially sensitive. In accordance with the Australian Privacy Principles, we may 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 or the health and safety of the public;
- 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 Australian law or by court/tribunal order;
- Totally Integrated Financial Planning has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to its functions or activities has been, is being, or may be engaged in, and giving access would be likely to prejudice the taking of appropriate action in relation to the matter;
- providing access is likely to prejudice actions being conducted by an enforcement agency; or
providing access would reveal evaluative information generated within Totally Integrated Financial Planning in conjunction with a commercially sensitive decision-making process.
In the event we refuse your request to access to your personal information; we will provide you with a written explanation for that refusal.
We will endeavour to respond to any request for 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.
We will update your personal information if you contact us. In most cases, you can update your personal information over the phone, or electronically via email to us or to your adviser.
Who we share personal information with
From time to time, with your permission, we may share your personal information with other entities both within and outside Totally Integrated Financial Planning. This will vary according to the product or service involved, but could include:
- any person acting on your behalf, including your financial adviser, solicitor, accountant, executor, administrator, trustee, guardian or attorney
- financial product and service providers, including financial planning software providers and paraplanners
- for corporate superannuation members, your employer or your employer’s financial adviser
- medical practitioners and health service providers, such as pathology services
- companies involved in the payments system including financial institutions, merchants and payment organisations
- organisations who assist us with certain business functions, such as auditors, compliance consultants, direct marketing, client experience surveys, debt recovery and information and communication technology support
- our solicitors, our insurers, courts, tribunals and dispute resolution organisations
- other organisations who provide us with products and services so that they may provide their products and services to you or contact you on our behalf, and/or
- anyone to whom we, or our service providers, are required or authorised by law to disclose your personal information to (for example, law enforcement agencies, Australian and international government and regulatory authorities).
We may also disclose your information to a third party where you have given your consent or where you would reasonably expect us to disclose your information to that third party.
We may also disclose the personal information we hold about our financial advisers to professional organisations, companies and consultants that we work with.
The only circumstances in which we would collect, use or disclose your government related identifiers is where we are required or authorised by law to do so. For example, we may be required to disclose your Tax File Number (TFN) to the Australian Taxation Office, a superannuation or retirement income product provider. A copy of your Drivers licence and/or passport may also be collected when we are required to verify your identity.
Personal information collected may also be used for direct marketing purposes to promote events, products or services that may be of relevance to you. Please contact us should you wish not to receive direct marketing.
How we protect personal information
We strive to ensure that the personal information you provide to us is stored safely and securely. We take numerous precautions to protect the personal information we hold about you from misuse, interference and loss, and from unauthorised access, modification or disclosure.
Australian Privacy Principles apply to the collection of personal or sensitive information. This means information provided by you in the course of receiving financial planning services must only be used:
- To provide you with information, products or services you might reasonably expect or request
- To fully understand or anticipate your needs during our relationship
- To manage rights and obligations under any laws applying to the services provided, or
- To conduct research, or planning and marketing, which includes direct marketing, although you do have the right to specifically instruct your details aren’t used for these purposes.
We have a range of practices and policies in place to protect personal information we hold, including:
- educating our staff and representatives about how to protect your personal information and updating them about cybersecurity developments, threats and scams
- requiring our staff and representatives to use passwords when accessing our systems
- client data is backed up regularly and stored securely
- client data may be stored with a third party provider e.g. financial planning software; storage provider etc
- where appropriate, using strict confidentiality arrangements restricting third parties’ use or disclosure of personal information for any unauthorised purposes
- employing physical and electronic means, including access controls (as required) to protect against unauthorised access to buildings
- employing firewalls, intrusion prevention systems and virus scanning tools to protect against unauthorised persons, malware and viruses from entering our systems
- some of the systems we use are on dedicated secure networks or transmit electronic data via encryption
- providing secure storage for physical records
- the manner in which your data is stored is regularly reviewed to ensure it is stored securely and only authorised persons are able to access your data
- where personal information is no longer required, we take steps to de-identify or destroy the information in a secure manner
In the event you stop being a client of Totally Integrated Financial Planning, any personal information which we hold about you will be maintained securely for a period of at least 7 years after you cease being a client of Totally Integrated Financial Planning, in order to comply with legislative requirements.
If your financial planner leaves our Totally Integrated Financial Planning licence and starts to provide financial services under another licensee, you will have the choice to continue to receive ongoing services from Totally Integrated Financial Planning in which case a new adviser will be appointed. In the event you choose to leave Totally Integrated Financial Planning and obtain ongoing services from a new licensee, your information may be transferred to the new licensee. You will be advised of any such transfer before it takes place.
Disclosure of personal information overseas
Any overseas disclosure does not affect our commitment to safeguarding your personal information and we will take reasonable steps to ensure any overseas recipient of your personal information complies with Australian privacy law.
When we share your personal information to overseas recipients, we make sure appropriate data handling and security arrangements are in place and we conduct regular due diligence on these providers.
When transferring information to foreign jurisdictions, we will ensure that we satisfy the following:
- we will take reasonable steps to ensure the overseas recipient does not breach the APPs in relation to the information;
- we form a reasonable belief that the overseas recipient is subject to a law, or binding scheme, that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the APP protect the information and there are mechanisms that the individual can access to take action to enforce that protection of the law or binding scheme; or
- we will seek your informed consent prior to disclosing your information overseas. Most of the services that we provide are based on an integrated model of professional and reliable service providers that we have selected after thorough due diligence. If you do not agree to us disclosing your information outside Australia to our external service providers, we will not be able to provide services to you.
- Personal information is generally hosted on servers located in Australia. If you access our services from outside Australia, you consent to the transfer of your personal information to your overseas location which may be a jurisdiction that may not provide the same high level of protection we apply in Australia.
Notifiable data breaches
We are required to notify you and the Information Commissioner of an eligible data breach. An eligible data breach happens if:
- there is unauthorised access to, unauthorised disclosure of, or loss of personal information held by us; and
- the access, disclosure or loss is likely to result in serious harm to you.
If you receive a statement of an eligible data breach from us, you should read and implement the steps that are recommended to you in response to the eligible data breach.
Complaints about privacy
If you have any queries or are concerned about how your personal information has been collected, used or disclosed and you wish to make a complaint, please contact us from the information below:
We will acknowledge receipt of a complaint immediately, however, where this is not possible, acknowledgement will be made as soon as practicable. We will then investigate the complaint and respond to you within 45 days. Some complex matters may require an extension to thoroughly investigate the complaint and bring it to resolution.
If you are not fully satisfied with our response, you can contact an external body. In cases of privacy related complaints, this is generally the Office of the Australian Information Commissioner (OAIC).
You may also direct privacy complaints related to financial advice to:
About this Policy
The information in this document is considered to be true and correct at the date of publication. Changes to circumstances after the time of publication may impact on the accuracy of the information held.