Privacy Policy
Introduction
Profile recognises that your privacy is very important to you, which makes it equally important to us. We comply with the requirements of the Privacy Act and are committed to supporting the National Privacy Principles (NPPs) set out in the Privacy Amendment (Private Sector) Act 2000. The 10 national Privacy principles are:
- Collection
- Use and disclosure
- Data quality
- Data security
- Openness
- Access and correction
- Identifiers
- Anonymity
- Transborder data flows
- Sensitive Information
This Statement addresses how personal information you provide Profile Financial Services is collected, held, used, corrected, disclosed and transferred. You can obtain more information on request by contacting us directly.
Collection
Profile, as a financial planning firm is 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 ("personal information"). In order to provide you with comprehensive financial planning and advice, Profile requires 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;
- medical history for risk insurance applications.
In order to comply with the requirements of the Privacy Act, we are required to advise you that this firm may hold some or all of this information about you. The information has been and will continue to be collected by us for the purpose of providing you with financial services including:
- the preparation of your financial strategy;
- the provision of financial planning advice to you;
- making securities and investment recommendations;
- reviewing your financial strategy and securities and investment recommendations;
- the provision of risk insurance advice and cover;
- debt reduction;
- Estate Planning strategies and advice; and/or
- for other related matters
The Corporations Act and Rules of Professional Conduct of the Financial Planning Association of Australia require us to collect sufficient information to ensure appropriate advice can be given in respect of recommendations made to our clients. If you elect not to provide us with the personal information referred to above, we may terminate our services to you if we believe we are unable to provide you with the services requested in a compliant and value-add manner.
We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us. Generally collection of your personal information will be effected in either face to face interviews, over the telephone or via online means. From time to time additional and/or updated personal information may be collected through one or more of those methods.
Use and Disclosure
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 National 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.
Additionally the Rules of Professional Conduct of the Financial Planning Association of Australia may require Profile 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.
The Corporations Act further requires Profile to maintain certain transaction records and make those records available for inspection by the Australian Securities and Investments Commission.
Profile may use 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. If you do not wish to receive such information you may request not to receive it, by advising us via any of the methods detailed below. Please allow 2 weeks for your request to be actioned.
Personal Information may be disclosed 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.
Profile ensures a high level of service to its clients by ensuring that other Profile representatives and staff have access to client information for the purposes of assisting you as necessary during periods of absence of your adviser or to field administrative enquiries. It is a condition of employment at Profile that all Representatives adopt and adhere to this privacy policy.
External contractors must adopt and adhere to our privacy policy as a condition of their ongoing services to the business. You can be assured, that your information will be maintained in accordance with this policy by any contractor to whom it is disclosed.
In the event that we propose to sell our business we may need to disclose some of 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 used or disclosed by them. In the event that a sale of our business is effected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer.
Profile will only use your personal information for the main purpose we told you it was needed for, except where you consent to us using that personal information for another purpose, where the other purpose is related to the main purpose and you would reasonably expect us to use the personal information for that other purpose, or where it is permitted or required by law, or we reasonably believe it is necessary on health or public safety grounds to use the personal information for another purpose.
Access and Correction
You may enquire at any time what personal information is held about you, and what we do with it. On receipt of your request Profile will facilitate access to you by allowing an inspection of your personal information in person, or by providing copies or an accurate summary of relevant documents, depending on what is most appropriate in the circumstance. Prior to providing this access we will require you to provide evidence of your identity. Any charge we make for providing access will be reasonable.
We will not provide you access to personal information which would reveal any confidential formulae or the detail of any in house evaluative decision making process, but may instead provide you with the result of the formulae or process or an explanation of that result.
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.
- An explanation will be provided in the event that personal information requests are refused. Every effort is to be made to ensure that personal information held is up to date and accurate. In the event that you or Profile finds that Personal Information held is inaccurate, we will take all reasonable steps to correct the information. If we do not agree that your personal information requires correcting, we will take reasonable steps to ensure that whenever your personal information is accessed it is apparent that you are not satisfied as to the accuracy or completeness of that information.
Security
Personal information is generally held in client files and on computer databases.
Profile regularly reviews information security to ensure personal information is protected from misuse, loss, unauthorised access, modification or disclosure. At all times personal information is treated as confidential and any sensitive information is treated as highly confidential. All paper files are stored in lockable cabinets/rooms. Access to Profile premises is tightly controlled and security systems are in place within the building.
All computer-based information is protected through the use of firewalls, access passwords on each computer and screen saver passwords. Data is regularly backed up and stored securely off site.
In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in our secure storage facility for a period of 7 years in order to comply with legislative and professional requirements, following which time the information will be destroyed.
Online Considerations
Information is gathered as a result of visits to Profile’s website including, time and date, server address, pages accessed, time spent and type of browser. This information is used in an anonymous form for statistical purposes and as such cannot identify you individually.
When you log into the client section of our site, we may use cookies to identify who you are, while you are logged in for the session. The cookie is unique to that session, and the data within the cookie is encrypted.
Identifiers
We will not adopt as our own any identifiers that you may provide to us such as TFNs, Medicare numbers etc.
Sending Data Overseas and Third Party Websites
Profile does not send any personal information about clients overseas unless you consent to this, or we reasonably believe that the other country has privacy laws substantially similar to our own, or we provide the information in other circumstances giving like protection.
Our website may contain links to other websites. When visiting these websites be sure to check the privacy policy as we are not responsible for privacy practices of those other parties.
Complaints Resolution
If you wish to complain about any breach or potential breach of this privacy policy or the National Privacy Principles, you should contact our Compliance Manager by any of the methods detailed below. Your complaint will be considered and responded to within 14 days. We will seek to address any concerns that you have through our complaints handling processes, however, if you are unhappy with our response, you are entitled to contact the Office of the Federal Privacy Commissioner who may investigate your complaint further.
Contact Us
If you seek any further information from Profile about this Statement or our privacy policy generally, please contact the Compliance Manager using our online form.