FINWELL GROUP PRIVACY POLICY

Confidentiality of client data and full adherence to the Privacy Act is of the utmost importance in all of Finwell’s activities.

Confidentiality Clause

The following Confidentiality Clause is contained in every Finwell Contract of Employment:

Confidentiality of Information

“Whilst employed with Finwell Group, you may be given access to personal and financial information about our clients, lists of client or prospective client contact details, and information about our business practises, software systems, management activities, trade secrets or other intellectual property. This information will only be given to you to assist you in carrying out your role within the business. Any items of this nature developed or created by you as part of your role in Finwell will be considered intellectual property owned by Finwell.

You agree that you will keep this information confidential and not disclose it to anyone without the permission of the owner, or use it for any purpose other than to carry out the work assigned to you. You acknowledge that damages may be sought to recover the value of any loss occasioned by Finwell or its clients due to your abuse of confidential information or intellectual property. This agreement remains in force even if your employment is ended for any reason.”

Confidentiality Agreement

A Confidentiality Agreement is attached to this issue. It should have been signed by all Employees of the Finwell Group of Companies.

If an employee has not signed the Confidentiality Agreement it is hereby made their personal responsibility to do so. Failure to do so may result in disciplinary actions including termination due to the sensitivity of the data we handle.

It is advised that anyone in doubt as to whether or not they have signed this agreement, simply do so on receipt of this issue and forward the copy to the Chief Administration Officer for immediate filing.

Violation

Violation of the Privacy Act can bring about a penalty of $10,000 per breach.

If, for example, an employee allows 100 different identities and their contact details to be shared to external parties without permission, this can bring about $1,000,000 in fines.

Should this occur, Finwell Group will terminate the offending employee and will seek in every legal manner possible the recoup of such penalties from said employee.

Examples

The following are some examples of how violations could take place of either privacy or confidentiality. Please note, these only serve as some indication and are in no way intended to encompass the full scope of violations that could take place. The following may not be used in any way to limit the full meaning of the above clause or any Confidentiality Agreement that has been signed.

Using specific names of clients when promoting Finwell’s results to new prospects. Specifics must only be given in general terms, never names of clients, their contacts, occupations or anything of a nature that could identify them.
A violation of privacy may take place where a Finwell representative holds an online meeting with a client or prospect by having other members of the Finwell representative’s household (or anyone else) in a position to hear the content of the meeting. For this reason some form of headphone which limits the broadcast of the meeting should be used, or the Finwell representative should be sure that nobody else is able to hear the content of the meeting.
Communicating in any way any negative comments about Finwell’s internal business, the business or actions of it’s Director, owner(s), Executives, employees or clients or any of their affairs to any other individual who is not an employee of Finwell will be considered a breach of the above clause where such disclosure is detrimental to the company, it’s privacy, image or activities and will be enforced to whichever extent is executable under law. Please keep in mind that spouses and family members of Finwell employees are not themselves employed by Finwell, nor have they signed any Confidentiality
It is a breach to record a client or prospect meeting without informing the client and obtaining their consent.
Providing or allowing access in any way to information that contains any of the following to individuals or entities not contracted to the Finwell Group of Companies:
- Names of clients or prospects
- Contact details of any kind (Address, Phone Number, E-mail etc)
- Client or prospects occupation or place or work
- Any form of financial data – this includes balances of accounts, superannuation funds, loan or mortgage information, credit data, lending institution etc.

Finwell Group

Employees may share data between the different entities of the Finwell Group where necessary to prepare for or deliver the services of any of the entities to a client or prospect. This sharing may take place only between individuals fully contracted to Finwell and must only be for the purpose of executing the business of the Finwell Group of Companies.

Privacy Policy of Finwell Advice

IDFP Pty Ltd Trading as Finwell Advice has it’s own Privacy Policy.

Where no other privacy policy specifically applies to the actions of any Finwell Group employee (such as the privacy policy specific to Silver Oak Lending Pty Ltd Trading as Finwell Lending), it will be considered that the Privacy Policy of Finwell Advice applies in full.

As such it is requisite that every employee read Finwell Policy Letter Finwell Advice Privacy Policy and submit a written attest that they have done so to the Chief Administration Officer for immediate filing.

Court of Law or Authorized Legal Body

Nothing in this policy is to prevent valid testimony where required by a legally constituted court of law or similar legal body or to otherwise violate the law of the land in which Finwell operates.

Summary

Finwell Group of companies, it’s Director and Executives make no apologies for the severity of this policy. The security of data is paramount to the survival of the Finwell Group and its clients and thereby each of it’s employees. Breaches will be dealt with summarily and to the full extent of the law.

It is also recognized that Finwell Group is a proud and able group, who is worthy of the trust that our clients place in us. We must continue to live up to this.

Any staff member who understands the importance of maintaining security of data should find no disagreement with any of the above. These policies only secure your future survival within the Finwell Group of Companies, along with the survival of the group itself.

Ben Lawrence

Chief Establishment Officer

For

Adam Carmody Executive Director

Privacy Policy – Finwell Group

Privacy Policy