The following policy is intended for dissemination to our clients and prospects.
It is to be adhered to by Finwell Group employees. Refer also to Finwell Policy Letter FINWELL GROUP PRIVACY POLICY.
Investors Direct Financial Planning Pty Ltd Trading as Finwell Advice (‘Finwell Advice’) is committed to ensuring the confidentiality of your personal information in accordance with the Privacy Act 1988 and the Australian Privacy Principles (APPs).
We collect information for a number of reasons including:
and
Information is generally collected:
If you are unable to provide us with your personal information, we may not be able to organise for you to receive a product or service.
You can nominate an Authorised Representative to access your personal information. This authority can be revoked at any time. Finwell Advice may collect personal information from a third party (such as another Financial Adviser, Product Provider or Medical Practitioner) or a publicly available source but only if you have consented to the collection or it can reasonably be expected that consent has been provided by you.
Finwell Advice and our Authorised Representatives may use websites to collect personal information from or about you. Finwell Advice and Authorised Representatives may have access to your accounts and information where we have an arrangement with a third party provider, i.e. a retail superannuation fund or insurance company.
Finwell Advice, its staff and Authorised Representatives will not ask to receive a password and/or personal identification number from you to access details about you. If you receive a request to provide these, you should deny the request and report this to the Privacy Officer of Finwell.
This information will be kept confidential and secure at all times.
These are text files stored on a person’s computer when they visit a website. Their sole purpose is to identify users and possibly prepare customised web pages or to save site login information.
Finwell Advice and our Authorised Representatives may use cookies on our websites. Cookies can be purged from your browser after every use. This is generally a very simple procedure. Please refer to your browser’s help file for more information.
Although Finwell Advice and our Authorised Representatives strive to ensure your security, no data transmission over the internet can be guaranteed to be completely secure.
Finwell Advice and our Authorised Representatives may provide links on our web pages to external industry parties. The content and views expressed on these third party websites are not the responsibility of Finwell Advice or our Authorised Representatives.
Finwell Advice and our Authorised Representatives may need to collect your tax file number to provide you with a product or a service (for example, managed fund investments and superannuation products).
However this information will be kept securely and destroyed or we will permanently de-identify TFN information where it is no longer required.
The personal information generally collected includes:
Where the information is deemed to be sensitive, for example, the collection of health information, there will be higher level of privacy protection afforded.
There may be cases where Finwell Advice and our Authorised Representatives will need to disclose your personal information to third parties.
This is generally to assist us in providing you with a product or service. This may include:
Your hard copy and electronic records are stored in secure buildings and internal information systems.
We protect your information by way of staff training, secure storage and system security.
Finwell Advice will take reasonable steps to destroy or de-identify the personal information we hold once it is no longer needed for any purpose for which it may be used or disclosed.
It is generally unlikely that we will disclose your personal information overseas. However, we may occasionally use third-party service providers or offshore outsourcing services to provide services to you. Depending on the circumstances, the relevant countries will vary such that it is not practicable to list them here.
Any overseas disclosure does not affect our commitment to safeguarding your personal information and we will take reasonable steps to ensure any overseas recipient complies with the APPs.
Where it is likely that we will transfer your personal information overseas, we will either seek your consent, inform you and/or ensure that appropriate contractual measures are in place requiring the overseas entity to protect your personal information in accordance with our obligations under Australian privacy law.
Where you apply for certain life risk products (such as life insurance, income protection insurance, trauma insurance, total and permanent disability insurance) it will be necessary for Finwell Advice and our Authorised Representatives to collect sensitive information about your health.
This information will only be collected when you give consent by completing the product’s application form or inform us of your information verbally.
The information will be sourced by the Life Insurance company from you, your medical professional and by other medical professionals where medical tests may have been performed.
Due to confidentiality, it is sometimes the case whereby Finwell Advice or the Authorised Representative may not be made fully aware of the medical circumstances by the Life Insurance Company.
Unless required by law, we will only collect sensitive information with your consent.
Finwell Advice operates within Australia: Your personal information may be shared with the Finwell Group’s employees.
Occasionally, Finwell Advice, its staff and Authorised Representatives may travel overseas. If they travel overseas they will still be held to the standards as set out in this document and the APPs.
In the event that an Authorised Representative proposes to sell their business, or if an Authorised Representative is no longer eligible to provide advice, we may disclose some of your personal and sensitive information to potential purchasers for the purpose of conducting due diligence investigations. Any such disclosures will be made in the strictest confidence and conditional that no personal information will be used or disclosed by them. In the event of a sale being effected, Finwell Advice or our Authorised Representatives may transfer your personal information to the purchaser of the business. In this instance, you will be provided a notice by mail to your last known mailing address that such a transfer will be taking place. You will then have the opportunity to object to the transfer within 14 days of the date of the notice.
You are able to access any personal information that is held by Finwell Advice or our Authorised Representatives subject to limited exceptions or required by law. The following factors will be considered:
To access the information, you will need to contact the Privacy Officer as detailed in this policy. You may be charged a small fee applicable to the collection and provision of your personal information but will be notified of this fee prior to processing your request.
The Finwell Privacy Officer will be able to advise you how long it will take to provide the information. Generally however, you will receive the requested information within 14 days of the request.
If you believe that the personal information we hold about you is incorrect, you have a right to request your personal information be corrected. Where we are unable to provide you with the information you have requested or correct your information, we will inform you and explain the reasons why.
You may remain anonymous or use a pseudonym when dealing with us. However, it may not be possible for us to assist you with your request if you wish to use a pseudonym or remain anonymous.
Finwell Advice has nominated a Privacy Officer to handle any queries or issues related to Privacy. This person has been nominated at a senior level and has access to the Board.
Name: Daniel Milne Phone: (03) 9017 3235
Email: daniel@finwellgroup.com.au Post: Level 1/39 Hall St, Moonee Ponds VIC 3039
We take your privacy seriously and any complaints you may have will be addressed through our complaints handling process. All complaints will be given fair consideration and we will aim to resolve them within 45 days. We encourage you to submit your complaint to the Privacy Officer (details above) either via email to post. Where it is found that we are unable to finalise the investigation of your complaint within 45 days, we will contact you to request an extension.
If you believe you did not receive a satisfactory resolution to your concern, you may contact the Office of the Australian Information Commissioner. You are able to do so by
The Office of the Australian Information Commissioner is also available via Social Media outlets. Please refer to the Contact Us page at www.oaic.gov.au/about-us/contact-us-page.
