1 Introduction 

Synchronised Advice Pty Ltd (‘Synchron’) as licensee & Concord Wealth Pty Ltd, as an Authorised Representative, are 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
Synchron, 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 Synchronised Business 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 Synchronised Business Services Pty Ltd.
Synchron			Synchronised Business Services Pty Ltd [ABN 33 007 207 650]  [AFSL 243313].
Synchron  Board			Synchronised Business Services Pty Ltd [ABN 33 007 207 650] has a board which consists of two internal directors and one independent chairman
Synchron Staff			A person employed or contracted by Synchronised Business 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 Framework. 

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 requirements.

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 questionnaires.

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.

Synchron 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 

Synchron 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. Synchron and 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 

Synchron 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 Synchron or our Authorised Representatives.

 

3.2 Tax File Numbers 

Synchron 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 details.

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 Synchron 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, Synchron 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 Synchron 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 Synchron 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 

Synchron operates in the following countries outside Australia:
• The Philippines.

Clients’ personal information may be shared with Synchron 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 Synchron 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 

Synchron 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:           John Prossor

Phone:          03 9328 3900

Email:           j.prossor@synchron.net.au

+Post:           PO Box 438

North Melbourne VIC 3051

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 www.oaic.gov.au and submitting an online form;

• Obtaining a hard copy form at www.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 Synchron 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

activity.

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  Synchron 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 Synchron or our Authorised  Representatives hold about them is incorrect, they have a right to request their personal  information be corrected.

Where Synchron 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.

9.1 Anonymity and pseudonymity 

Clients are entitled to remain anonymous or use a pseudonym when dealing with Synchron  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 

Synchron 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 Synchron 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.

Synchron 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 platform.

Where the data is held by an online provider, Synchron 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.

Synchron 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 

11.1 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.