At the FPA we recognise that your privacy is very important to you – it is to the FPA as well. We handle personal information provided by and about people every day. By personal information we mean information or an opinion about a person whose identity is apparent or can reasonably be ascertained.
The aim of the FPA is both to support and to ensure that it complies with the Privacy Act 1988 (Cth) (Privacy Act). The FPA also seeks to comply with the Spam Act 2003 (Cth) (Spam Act) that is aimed at reducing the number of unsolicited electronic commercial messages that you receive.
The information set out below is largely a summary of our obligations under the Privacy Act, in particular the relevant privacy principles.
We believe that this Policy will address any potential concerns you may have about how personal information you provide the FPA is collected, held, used, corrected, disclosed and transferred. You can obtain more information on request about the way we manage the personal information we hold. If you seek any further information please contact us in one of the ways set out below.
HOW WE COLLECT YOUR PERSONAL INFORMATION
In the course of our activities we may collect and hold personal and business details of you because you are a member (Member) of the Financial Planning Association of Australia (FPA) or otherwise involved or connected with the FPA or you engage with us in another capacity including, but not limited, to use of our website, attending meetings/conferences, utilising our education or training services or materials.
We typically collect personal information in two ways. First, when individuals provide personal information to us through submissions such as application or registration forms, user profiles, promotional sign-ups, application downloads, Curriculum Vitae submissions, submissions for publication on the FPA website, referral programs, participation in the disciplinary process of members or request for customer service. Second, some personal information may be collected automatically. This is described as ‘Passive Data Collection’. We may receive passively-collected information through a variety of methods including but not limited to cookies whilst accessing parts of the CMA website.
what information we collect
The types of personal information that we may collect include, but are not limited to:
- your name and contact details including, but not limited to, your address, email address and phone number;
- information which you provide to us when making an application to become a Member, including but not limited to employment details;
- information you provide to us when you manually update your Member details or instruct us to do the same;
- information which you provide to us in response to, or by participating in, one of our surveys, promotions, competitions or events;
- your credit card and/or banking details;
- details of the services that we have agreed to provide to you, you have purchased from us, or that you have otherwise engaged us to undertake;
- records of our communications with you, including any complaints, requests, service issues or queries;
- information about your visits to and activities on our website in connection with our services that we may provide to you, or event or activity you my attend;
- if you apply for a job with us, any information contained in your CV or any other information that you may otherwise provide to us in connection with making any such application; and
- information in any review or comment that you post online, including via our website or social media.
HOW WE USE INFORMATION
Our main purposes for collecting your personal information include:
- to assess the suitability of applicants for membership of the FPA and to update our records;
- to facilitate the enrolment in or assessment of courses of study or training courses/conferences;
- to disseminate by electronic means or otherwise topical information and details of events of interest (including conferences and educational services);
- to regulate, investigate and monitor the activities of members in accordance with the rules, policies and procedures of the FPA;
- to investigate complaints made against members for alleged breaches of professional standards, FPA’s Constitution and Disciplinary Regulations including without limitation any complaints subject to whistleblower provisions and the external publication of outcomes of any disciplinary proceedings;
- to facilitate the provision of a referral service to interested members of the public;
- to publish articles, blogs and other information received for our online services;
- to personalise and display advertisements and content that is relevant to you;
- to provide Chapter Chairs with the ability to contact members directly about events or other areas of interest for their local Chapter members;
- to facilitate the provision of materials to members for director elections;
- to recognise members who contribute to Future2, including by way of acknowledgments of support on the internet;
- to facilitate the audit of Continuing Professional Development (CPD), including requests made by third parties verifying the satisfaction of CPD criteria; and
- to enable FPA to respond to queries from third parties, including without limitation financial institutions and licensees, in relation to membership status of the FPA including current employment details and membership status.
We will only collect personal information from you that is necessary for one or more of our functions and activities.
We will only collect personal information from you by lawful and fair means, without being unreasonably intrusive, such as when you complete a membership application or update form, enrolment form, registration form (for in person or online services) or questionnaire etc. At or before the time we collect personal information from you we will take reasonable steps to inform you why we are collecting that personal information, who else we might disclose that personal information to and what will happen if you do not provide personal information to us.
Other than in connection with our monitoring and investigative activities under the relevant legislation and FPA Regulations:
- where reasonable and practicable, we will only collect personal information about you, from you; and
- wherever it is lawful and practicable, we will give you the option of not identifying yourself or not providing personal information when entering into transactions with us.
However, failure to provide full and complete information we request may mean that we are unable to provide services to you fully and properly.
Once we hold personal information we will take reasonable steps to keep it accurate, complete and up-to-date.
If you provide personal information to use about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this Policy.
USE AND DISCLOSURE
We 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.
Where possible (for example, where not otherwise required by law or regulatory standards), prior to the online publication of personal information we will ensure the de-identification of personal information is undertaken. This enables the value and utility of information published and provided on online resources to be maximised. The FPA will de-identify personal information by removing or modifying identifying features such as name, address, or date of birth, remove or modify quasi-identifiers such as significant dates, profession or income and /or by suppressing or modifying data with broader categorisations. However, this may not necessarily apply in circumstances where FPA publishes the outcome of any disciplinary proceedings against members (current or former).
In order to fulfil the purposes set out above we may provide access to your personal information to third parties with whom we have a business relationship, for example those who maintain and update our database, who assist with mail-outs or advertising, who arrange, participate in and sponsor conferences and who deliver educational and other services.
Your personal information may also be provided to third party financial institutions and licensees in relation to the auditing of FPA membership status, CPD criteria or the investigating or monitoring of membership status. Given the heightened importance of transparency in the financial services industry you understand and acknowledge that this is a reasonable disclosure.
Where you make a complaint against a member of the FPA for alleged breaches of professional standards, we may also disclose your personal information to the member to facilitate the investigation of the complaint. You accept that not all recipients of your information may have privacy policies equivalent to the FPA’s and you consent to the disclosure of your personal information for those purposes.
There are some circumstances where by law we are required to disclose your personal information, including to Courts, Tribunals, Regulators or law enforcement agencies.
In relation to direct marketing, where practicable we will seek your consent before we use your personal information for this purpose. You may tell us at any time you do not wish to receive any further direct marketing materials – if you do, we will stop sending you such materials.
In accordance with the Spam Act, should you wish to unsubscribe from commercial electronic messages from the FPA, all future commercial electronic messages from the FPA will enable you to unsubscribe from that particular type of electronic message from the FPA and this can be done at any time. If you do not unsubscribe, the FPA will continue to send you relevant information of the types described above.
The FPA may also use messaging methods other than email.
ACCESS AND CORRECTION
Subject to FPA Regulations, and where it is reasonable for us to rely on any relevant exception under the Australian Privacy Principles.
- If you ask, we will tell you what personal information we hold about you, and what we do with it.
- We will facilitate access to you by allowing an inspection of your personal information in person, or by providing copies or a summary of relevant documents, depending on what is most appropriate in the circumstances, following receipt of your request. Any charge we make for providing access will be reasonable.
If you can show us that the personal information is inaccurate, we will take reasonable steps to correct it. Note that we need not provide access to personal information in several types of situation, for example where a request is frivolous, or where to provide access would pose a threat to health or public safety, unreasonably interfere with another person’s privacy, or be a breach of the law.
We will take reasonable steps to protect your personal information from misuse, interference and loss as well as unauthorised access, modification or disclosure. Subjective to the relevant regulations and legislation, we will destroy or permanently de-identify your personal information we no longer need.
This part specifically relates to articles, blogs and any other information published online by the FPA and/or FPA Members. The FPA, Members and Individuals (including you) must adhere to this Policy, the FPA online Terms and Conditions and any other relevant policy, Policy or document, when making use of online publications and resources. Where possible, the FPA will make use of pseudonyms when publishing articles, blogs and any other online material (save for the records of any disciplinary proceedings against members).
A cookie is a small file which remains on your computer and contains information enabling our website to recognise your browser.
When you visit our website, details may be recorded about your visit, such as time and date, your server address, pages accessed, time spent and type of browser.
We may track ‘opens’ and ‘clicks’ via a tracking pixel to see who opens our email communication and whether they click on the links contained in the email. This information is used to help us deliver relevant messaging. If this is something you do not wish to occur, please contact our Privacy Officer using the contact details below.
OPTING OUT OF COOKIES
We will not adopt as our own any identifiers that you may provide to us such as TFNs, Medicare numbers etc.
THIRD PARTY WEBSITES
OVERSEAS DISCLOSURE OF PERSONAL INFORMATION
We may from time to time transfer personal information outside Australia in accordance with the Privacy Act to countries whose privacy laws do not provide the same level of protection as Australia’s privacy laws. For example, we may transfer your personal information to the Asia-Pacific, European Union or the United States of America. We may also use cloud storage and IT servers that are located offshore.
By providing us with your personal information, you consent to us disclosing your information to entities located outside Australia and, when permitted by law to do so, on the basis that we are not required to take such steps as are reasonable in the circumstances to ensure that any overseas recipient complies with Australian privacy laws in relation to your information.
We are committed to providing Members, and other parties whose personal information we hold, a fair and responsible system for the handling of their complaints relating to our collection, use and disclosure of personal information.
If at any time you have any complaints in relation to privacy, please contact our Privacy Officer at one of the points referred to below. We will seek to address any concerns that you have through our complaints handling processes, but if you wish to take matters further you may refer your concerns to the Office of the Australian Information Commissioner.
CHANGES TO THIS POLICY
We are constantly reviewing our statements and policies in an attempt to keep up to date with market expectations and legal developments. Subsequently, we may change this Policy from time to time as the need arises.
If you seek any further information from the FPA about this Policy or our privacy procedures generally please contact our Privacy Officer at one of the reference points below:
Privacy Officer, FPA, Level 4, 75 Castlereagh Street, Sydney NSW 2000 or GPO Box 4285, Sydney NSW 2001.
Further information on privacy in Australia may be obtained by visiting the web site of the Office of the Australian Information Commissioner at www.oaic.gov.