Privacy Policy

Financial Framework’s Privacy Policy

Financial Framework is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information. We have adopted the National Privacy Principles (NPPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Federal Privacy Commissioner at www.privacy.gov.au.

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect on our website include: names, addresses, email addresses, phone and facsimile numbers.

This Personal Information is obtained in many ways including interviews, correspondence, by telephone and facsimile, by email, via our website www.financialframework.com.au, from your website, from media and publications such as social media and Facebook, from other publicly available sources, from cookies and from third party applications such as online chat. We don’t guarantee website links or policy of authorised third parties.

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing or selecting the unsubscribe option in the footer of our emails.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

• For the primary purpose for which it was obtained
• For a secondary purpose that is directly related to the primary purpose
• With your consent; or where required or authorised by law.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

• Third parties where you consent to the use or disclosure; and
• Where required or authorised by law.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing at admin@financialframework.com.au.

Financial Framework will not charge any fee for your access request.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Do We Use Cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in quote submissions. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We do not use cookies on our website to identify personally identifiable information. Cookies on the website are completely anonymous and we will not use personably identifiable information unless you have voluntarily provided information via the use of a form on www.financialframework.com.au.

Data may become personally identifiable when cookies are used in association with visitors coming from email marketing campaigns and submitting forms on www.financialframework.com.au. However, this information will not be used for any other purpose than to approve a request of the individual user.

We use cookies to:
• Understand and save user’s preferences for future visits.
• Keep track of advertisements and remarket appropriate offers to visitors of www.financialframework.com.au across the Google network.

• Remarket to visitors via the use of banner ads.
  • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future.
• Compile aggregate data about site traffic and site interactions in order to create more relevant offers across lookalike audiences online across Google’s advertising network.

We may also use trusted third party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If you disable cookies off, some features will be disabled. It won’t affect your site experience if you choose to turn of cookies.

To find out more information about how to control the information that cookies can see visit http://www.google.com/settings/ads.

If you would like to opt out of our third party use of cookies visit http://www.networkadvertising.org/managing/opt_out… to find out more.

Third Party Disclosure

No, we do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Statement of Financial Framework’s Privacy Policy

Version	Reviewer/Approver	Name	Date
V1.0	Reviewer	Emma Ross	01/04/2024
V1.0	Approver	Will Walker	02/05/2024

Table of Contents

• Introduction………………………………… 3
  • Purpose…………………………………… 3
  • Definitions……………………………….. 3
  • Dependencies……………………………. 3
• Why we collect information………………. 3
• How we collect this information…………. 4
  • Privacy on the internet…………………. 4
    • Cookies………………………………. 4
    • Links to third party websites……… 4
  • Tax File Numbers……………………….. 5
• What we collect…………………………….. 5
• Disclosure of personal information………. 5
• Collection of sensitive information………. 6
• Where we operate…………………………. 6
• Sending personal information overseas… 6
• Privacy Officer……………………………… 6
• Sale of an Authorised Representative’s business…………………………………………………. 7
• Access to personal information……….. 7
  • Anonymity and pseudonymity…………. 8
• Security…………………………………. 8
• Review…………………………………… 8
  • Review Frequency……………………… 8
  • Revision History……………………….. 9

1. Introduction

Financial Framework Pty Ltd (‘Financial Framework’) is committed to ensuring the confidentiality of client’s personal information in accordance the Privacy Act 1988 and the Australian Privacy Principles (APPs).

1.1  Purpose

The following document aims to detail how a client’s personal information is handled by

Financial Framework, its Authorised Representatives and staff.

1.2  Definitions

 

Term	Definition
AFSL	Australian Financial Services License.
ASIC	Australian Securities and Investments Commission.
AUSTRAC	Australian Transaction Reports and Analysis Centre. This is the regulator responsible for policing the AML/CTF Act.
Authorised Representatives	Those persons who have been provided with the authority to use the FF Financial Services Pty Ltd Australian Financial Services License to provide personal financial planning services.
Clients	Those people or peoples who receive a service from and Authorised Representative or a staff member of Financial Framework Pty Ltd.
Financial Framework	FF Financial Services Pty Ltd (ABN 22671389905 and AFSL 553987)
Financial Framework Staff	A person employed or contracted by FF Financial Services Services Pty Ltd.

 

1.3  Dependencies

• Changes to industry standards;
• Changes to the Privacy Act 1988;
• Changes to the Privacy Amendment (Enhancing Privacy Protection) Act 2012;
• Changes to the Australian Privacy Principles;
• Changes to the Best Practice Standards;
• Changes by Regulators;
• Changes to the Risk Management

 

2     Why we collect information

We collect information from clients for a number of reasons including:

• To deliver products or services to clients;
• To improve our service to clients;
• Preparing financial plans;
• To provide financial advice to clients;
• Establish and manage investments and accounts;
• Implement investment and insurance instructions;
• Process any contributions, transfers or payments of benefits;
• Monitor and report on investment performance of a client’s account;
• Reviewing financial plans;
• To provide clients with future products and services they may be interested in;
• To fulfil our regulatory and legislative

3     How we collect this information

Information is generally collected from:

• When we ascertain from clients the facts necessary to make a fair and reasonable

assessment of their insurance or financial needs and objectives (“Fact Find”);

• When a client completes an application form for insurance;
• When a client completes an application form for an insurance claim;
• When a client completes and application form for investments;
• When a client completes an application form for superannuation
• When a client completes an application form to increase their level of insurance;
• When a client completes supplementary medical or financial

If a client is unable to provide us with their personal information, we may not be able to organise for them to receive a product or service. Clients can nominate an Authorised Representative to access their personal information. This can be revoked at any time.

Financial Framework 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 the client has consented to the collection or it can reasonably be expected that it has been provided by the client.

3.1  Privacy on the internet

Financial Framework and our Authorised Representatives may use websites to collect personal information from clients. Clients and Authorised Representatives may receive a password and a personal identification number to access details online. It is a condition of use that this information is kept confidential and secure at all times.

3.1.2  Cookies

These are text files stored on a person’s computer when they visit a website. Its sole purpose is to identify users and possibly prepare customised web pages or to save site login information. Financial Frameworkand 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.

3.1.3  Links to third party websites

Financial Framework 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 Financial Framework or our Authorised Representatives.

3.2  Tax File Numbers

Financial Framework and our Authorised Representatives may need to collect a client’s tax file number to provide them with a product or a service (for example, managed fund investments and superannuation products). However this information must be kept securely and destroy or permanently de-identify TFN information where it is no longer required.

4     What we collect

The personal information generally collected includes:

• Name;
• Address;
• Phone number;
• Email address;
• Age details;
• Occupation;
• Financial details;
• Health Details;
• Transaction information;
• Bank account details;
• Tax File Number;
• Income details from employers;
• Details of dependents;
• Beneficiary

Where the information is deemed to be sensitive, for example, the collection of health information, there will be higher level of privacy protection afforded.

5     Disclosure of personal information

There may be cases where Financial Framework and our Authorised Representatives will need to disclose a client’s personal information to third parties. This is generally to assist us in providing the client with a product or service. This may include:

• Doctors, medical services or other organisation to help assist with the collection of information for an insurance application or a claim;
• Any fund (investment administrator or superannuation trustee) to which a client’s benefit is transferred, created or rolled over;
• Employers where it relates to a client’s employer sponsored superannuation arrangement;
• A client’s personal representative or any other person who may be entitled to receive the client’s death benefit;
• An external dispute resolution service, insurer or legal representative (where required or applicable);
• The policy owner (where the client is the life insurer but not the owner);
• Exchange of information with authorised financial institutions to confirm bank account details for payment.

If required by law or a regulatory body to do so, Financial Framework and our Authorised Representatives will comply and provide the appropriate body with the required client information.

6     Collection of sensitive information

Where a client applies for certain life risk products (such as life insurance, trauma insurance, total and permanent disability insurance) it will be necessary for Financial Framework and our Authorised Representatives to collect sensitive information about a client’s health. This information will only be collected when the client gives their consent by completing the product’s application form. The information will be sourced by the Life Insurance company from the client, their medical professional and by other medical professionals where medical tests may have been performed. Due to confidentiality, it is sometimes the case whereby Financial Framework or the Authorised Representative may not be made fully aware of the medical circumstances by the Life Insurance company.

Unless required by law, the collection of sensitive information should only occur if the client has consented to the collection of the information.

7     Where we operate

Financial Framework operates in the following countries outside Australia:

• The Clients’ personal information may be shared with Financial Framework employees in that country.

8     Sending personal information overseas

If we send a client’s personal information to overseas recipients, we ensure that appropriate data handling and security measures are in place.

Authorised Representatives of Financial Framework may enter their own outsourcing arrangements and send information to countries other than those listed above. Those arrangements must be disclosed separately by Authorised Representatives to their clients.

9     Privacy Officer

Financial Framework 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:          Will Walker

Phone:          08 61444 000

Email:          will.walker@financialframework.com.au

Post:          3 Rosslyn St, West Leederville, WA 6007 

If a client wishes to make a complaint in relation to a potential breach of the Privacy Act or the APPs, we will address their concerns through our complaints handling process. All complaints will be given fair consideration and will aim to be resolved within 45 days. We encourage clients to submit their complaint to the nominated Privacy Officer (details above) either via email to post. Where it is found that we are unable to finalise the investigation of a client’s complaint within 45 days, we will contact the client to request an extension.

If a client believes they did not receive a satisfactory resolution to their concern, they may contact the Office of the Australian Information Commissioner. They are able to do so by:

• Visiting oaic.gov.au and submitting an online form;
• Obtaining a hard copy form at oaic.gov.au/about-us/contact-us-page;
• Phone: 1300 363 992;
• Fax: 02 9284 9666;
• Email: enquiries@oaic.gov.au

The Office of the Australian Information Commissioner is also available via Social Medial outlets. Please refer to the Contact Us page at www.oaic.gov.au/about-us/contact-us- page.

10  Sale of an Authorised Representative’s business

In the event that either our Authorised Representative or we propose to sell our business, or if an Authorised Representative is no longer eligible to provide advice, we may disclose some of a client’s 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, we or our Authorised Representatives may transfer a client’s personal information to the purchaser of the business. In this instance, the client will be provided a notice by mail to their last known mailing address that such a transfer will be taking place. They will then have the opportunity to object to the transfer within 14 days of the date of the notice.

11  Access to personal information

Clients are able to access any personal information that is held by Financial Framework or our Authorised Representatives subject to limited exceptions or required by law. The following factors will be considered:

• The information is related to a commercially sensitive decision making process;
• Access would be unlawful;
• Denying access is required or authorised by or under law;
• Providing access would be likely to prejudice an investigation of possible unlawful

To access the information, a client will need to contact the Privacy Officer as detailed in this policy.

Clients may be charged a small fee applicable to the collection and provision of their personal information but will be notified of this fee prior to processing their request. The Financial Framework Privacy Officer will be able to advise the client how long it will take to provide the information. Generally however, clients will receive the requested information within 14 days of the request.

If a client believes that the personal information that Financial Framework or our Authorised Representatives hold about them is incorrect, they have a right to request their personal information be corrected.

Where Financial Framework or our Authorised Representatives are unable to provide a client with the information they have requested, the reasons that the information could not be provided should be explained to the client.

11.1  Anonymity and pseudonymity

Clients are entitled to remain anonymous or use a pseudonym when dealing with Financial Framework or our Authorised Representatives. However, it may not be possible to assist client with requests if they wish to remain anonymous or use a pseudonym.

12  Security

Financial Framework and our Authorised Representatives strive to ensure the security, integrity and privacy of personally identifiable information. Only those authorised to do so are able to access such information. All client information is kept in a secure location and can only be accessed by authorised personnel.

However, although Financial Framework and our Authorised Representatives strive to ensure a client’s security, no data transmission over the internet can be guaranteed to be completely secure.

A client’s personal information is kept for as long as it is required to meet the client’s financial product or service needs. For record keeping, it is generally kept for a further period of at least seven years.

Financial Framework and Authorised Representatives are required to hold personal and sensitive information in as secure a position as possible. This will include but is not limited to:

• Locked offices;
• Locked filing cabinets;
• Limited access by staff;
• Storage via a third party online provider;
• Storage via a third party online

Where the data is held by an online provider, Financial Framework or the Authorised Representative should ensure that access is limited and the data is held by a provider whose only aim is storage. Those who have access to personal information should have the appropriate training, knowledge, skills and commitment to protect personal information from unauthorised access or misuse.

Financial Framework and our Authorised Representatives are required to take reasonable steps to destroy or de-identify personal information held once it is no longer needed for any purpose for which it may be used or disclosed.

13  Review

13.1  Review Frequency

This policy will be reviewed every two years by the Compliance Manager or other nominated person to ensure it remains relevant to our business. Should amendments be required either at that time, or in any intervening period, those amendments will be made immediately and staff notified.

13.2  Revision History

 

Author	Version	Date	Revision Details
Emma Ross	1.0	1st May 2024	·        Creation of Policy.