Centre In Finance Pty Ltd ABN 61 062431 583 AFSL 247284 (referred to as ‘we’, ‘our’, ‘us’) is bound by the Privacy Act 1988 ('Privacy Act'), including the Australian Privacy Principles ('APPs') and recognises the importance of ensuring the confidentiality and security of your personal information. All third parties (including customers, suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by us must abide by this Policy.
Copies of this Policy are available free of charge by contacting our Privacy Officer or can be downloaded from our website: cifp.com.au.
IN THIS POLICY:
- ‘Disclosing’ information means providing information to persons outside of us;
- ‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual;
- ‘Privacy Officer’ means the contact person for questions or complaints regarding our handling of personal information;
- ‘Sensitive information’ is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
- ‘Use’ of information means our use of information.
PERSONAL INFORMATION WE COLLECT AND HOLD?
We may collect and hold a range of information about you to provide you with our services, including:
- your full name;
- contact details (including telephone and email);
- date of birth;
- employment details and Social Security
- details of your current financial circumstances
- health, medical or lifestyle information relevant to an insurance product;
- Tax file number and certified photo identification as per the Anti- Money Laundering
- any additional information relating to you that you provide to us directly through our website or indirectly
- Failure to provide the personal information referred to above may expose you to higher risks in respect of the recommendations made to you; and
- Other relevant personal information relevant to your circumstance.
- Any additional information relating to you that you provide to us directly through our websites or indirectly through our websites or online as ‘cookies’.
HOW DO WE COLLECT PERSONAL INFORMATION?
Centre in Finance Pty Ltd will not collect sensitive information unless the individual has consented or an exemption under the APPs applies. These exemptions include if the collection is required or authorized by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
If the personal information we request is not provided by an individual, we may elect to terminate our retainer with the individual if we believe we are unable to provide the individual with a complete service.
Centre in Finance Pty Ltd not give individuals the option of dealing with them anonymously, or under a pseudonym. This is because it is impractical, and in some circumstances illegal, for Centre in Finance Pty Ltd to deal with individuals who are not identified.
WHO DO WE COLLECT PERSONAL INFORMATION ABOUT?
The personal information we may collect and hold includes (but is not limited to) personal information about the following individuals:
- potential customers;
- visitors to our website;
- service providers or suppliers; and
WHY DO WE COLLECT PERSONAL INFORMATION?
We collect and hold personal information about you so that we may:
- provide you with our products and services;
- review and meet your ongoing needs;
- provide you with information we believe may be relevant or of interest to you;
- let you know about other products or services we offer, send you information about special offers or invite you to events;
- consider any concerns or complaints you may have;
- comply with relevant laws, regulations and other legal obligations;
- help us improve the products and services offered to our customers and enhance our overall business; and
We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act. Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise or an exemption in the Privacy Act applies.
WHO DO WE DISCLOSE PERSONAL INFORMATION TO?
We may disclose personal information to:
- a related entity of us;
- an agent, professional advisor or service provider we engage to carry out our functions and activities. The third party service providers to whom we may disclose personal information is to lawyers, accountants, IT contractors, and marketing companies];
- our data hosting and IT (related and non-related party) service providers who may be located or store data in other countries;
- insurers, medical practitioners, claims assessors and investigators;
- organisations involved in a transfer or sale of our assets or business;
- financial institutions involved in managing our payments, such as banks;
- regulatory bodies, government agencies, law enforcement bodies and courts;
- as required by law, to government bodies such as the Australian Taxation Office (ATO), the Office of the Australian Information Commissioner (OAIC) and the Australian Transaction Reports and Analysis Centre (AUSTRAC)
Any-one whom you authorise us to disclose it; and If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues and will make third parties aware of this Policy.
SENDING INFORMATION OVERSEAS
We are likely to disclose your personal information to recipients located in the following countries:
We will not disclose your personal information to overseas recipients without your consent unless:
- we have taken reasonable steps to ensure that the recipient does not breach the Privacy Act, or the APPs; or
- the recipient is subject to a similar information privacy regime.
MANAGEMENT OF PERSONAL INFORMATION
We recognise the importance of securing the personal information of our customers. We will take steps to ensure your personal information is protected from misuse, interference or loss, and unauthorised access, modification or disclosure.
Your personal information is generally stored in our computer database. Any paper files are stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:
- passwords are required to access the system and passwords are routinely checked;
- data ownership is clearly defined;
- we change employees’ access capabilities when they are assigned to a new position;
- employees have restricted access to certain sections of the system;
- the system automatically logs and reviews all unauthorised access attempts;
- unauthorised employees are barred from updating and editing personal information;
- all computers which contain personal information are secured both physically and electronically;
- data is encrypted during transmission over the network; and
- print reporting of data containing personal information is limited.
We may only use personal information we collect from you for the purposes of direct marketing without your consent if:
- the personal information does not include sensitive information; and
- you would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
- we provide a simple way of opting out of direct marketing; and
- you have not requested to opt out of receiving direct marketing from us.
If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications.
You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations. We must give effect to the request within a reasonable period of time. You may also request that we provide you with the source of their information. If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.
We do not adopt identifiers assigned by the Government (such as driver’s licence numbers) for our own file recording purposes, unless one of the exemptions in the Privacy Act applies.
HOW DO WE KEEP PERSONAL INFORMATION ACCURATE AND UP-TO-DATE?
We are committed to ensuring that the personal information we collect, hold, use and disclose is relevant, accurate, complete and up-to-date.
We encourage you to contact us if any personal information we hold about you needs to be updated. If we correct information that has previously been disclosed to another entity, we will notify the other entity of the correction within a reasonable period. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We will not charge you for correcting your personal information.
ACCESSING YOUR PERSONAL INFORMATION
Subject to exceptions in the Privacy Act, you can access the personal information that we hold about you by contacting the Privacy Officer. We will generally provide access within 30 days of your request. If we refuse to provide you with access to the information, we will provide reasons for the refusal.
We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged.
UPDATES TO THIS POLICY
This Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.
It is the responsibility of management to inform employees and other relevant third parties about this Policy. Management must ensure that employees and other relevant third parties are advised of any changes to this Policy.All new employees are to be provided with timely and appropriate access to this Policy, and all employees are provided with training in relation to appropriate handling of personal information. Employees or other relevant third parties that do not comply with this Policy may be subject to disciplinary action.
MAKING A COMPLAINT
If you have any questions about this Policy, or wish to make a complaint about how we have handled your personal information, you can lodge a complaint with us by telephone, writing or emailing to our Privacy Officer:
Centre In Finance Pty Ltd AFSL No: 247284
Level 1,347 Camberwell Road
P.O Box 1120
Camberwell, Vic 3124
If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner by:
- telephoning - 1300 363 992
- writing - Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
- emailing - firstname.lastname@example.org