Our commitment

At the FAAA we recognise that your privacy is very important to you – it is to the FAAA 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 FAAA is both to support and to ensure that it complies with the Privacy Act 1988 (Cth) (Privacy Act). The FAAA also must comply with the Spam Act 2003 (Cth) (Spam Act) that is aimed at preventing the sending of unsolicited electronic commercial messages and allowing you to unsubscribe from future messages.

The information set out below is largely a summary of our obligations under the Privacy Act, in particular the relevant privacy principles.

This Policy  addresses how personal information you provide to the FAAA 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 your personal and/or business details  because you are a member (Member) of the Financial Advice Association of Australia (FAAA) or otherwise involved or connected with the FAAA, 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 FAAA website, referral programs, participation in the disciplinary process of members or requests 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 FAAA 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, or renewing your membership, including but not limited to employment details, and any Declarations you make in line with the FAAA Member Regulations in force from time to time ;
• 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 events or activity you may 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 FAAA 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 FAAA;
• to investigate complaints made against members for alleged breaches of professional standards, FAAA’s Constitution and Disciplinary Regulations including without limitation any complaints subject to whistle-blower 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 or Community Chairs with the ability to contact members directly about events or other areas of interest for their local Chapter / Community members;
• to facilitate the provision of materials to members for director elections;
• to recognise members who contribute to any FAAA charitable endeavour, or any charitable purpose associated with the FAAA, 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;
• to enable FAAA to respond to queries from third parties, including without limitation financial institutions and licensees, or as required by law, in relation to membership status of the FAAA including current employment details and membership status;
• where you express an interest in being part of a pro bono advice scheme, in order to allow either us or the provider to contact you;
• to enable the granting of awards and scholarships; and
• to provide membership services and to communicate with you, including to:
  • establish your identity
  • contact you for any purpose not listed above
  • manage our risk and comply with our legal obligations
  • communicate information about products and services to you
  • meet our internal administrative, marketing, planning and research requirements;

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 renewal, update a form, enrolment form, registration form (for in person or online services) or questionnaire etc. 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 FAAA 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. As a member, it may also be a breach of your membership obligations.

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, with limited exceptions. These exceptions are:

• 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,
• where it is permitted or required by law
• or where 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 publication of personal information we will ensure the de-identification of personal information is undertaken. However, this may not necessarily apply in circumstances where FAAA 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 FAAA 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 FAAA 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 FAAA’s and you consent to the disclosure of your personal information for those purposes.

There are some circumstances where we are required by law to disclose your personal information, including to Courts, Tribunals, Regulators or law enforcement agencies.

In relation to direct marketing, , 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 FAAA, commercial electronic messages from the FAAA will enable you to unsubscribe from that particular type of electronic message from the FAAA, and this can be done at any time. If you do not unsubscribe, the FAAA will continue to send you relevant information of the types described above.

The FAAA may also use messaging methods other than email.

It is your responsibility to ensure that any personal data you provide to us is accurate. The FAAA may not undertake any additional review or checking of personal information supplied to us by members or third parties and the FAAA is not liable for any adverse consequence arising from the use or publication of your personal data (for example on our “Find a Planner” tool) where the information supplied to the FAAA is not accurate.

Access and correction

Unless it is reasonable for us to rely on any relevant exception under the Australian Privacy Principles, we will give you access to your personal information on request as follows.

• 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.

Please note that we need not provide access to personal information in some situations, 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. In such cases information may be redacted or withheld entirely, depending on what is required under the purpose for which the information is being withheld.

Security

We will take reasonable steps to protect your personal information from misuse, interference and loss as well as unauthorised access, modification or disclosure. Subject to the relevant regulations and legislation, we will destroy or permanently de-identify your personal information we no longer need.

Online publications

This part specifically relates to articles, blogs and any other information published online by the FAAA and/or FAAA Members. The FAAA, Members and Individuals (including you) must adhere to this Policy, the FAAA online Terms and Conditions and any other relevant policy or document, when making use of online publications and resources.

Cookies

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 use cookies to identify your browser so that next time you visit our website we remember your details. They may also be used for marketing purposes to ensure that advertisements you see on our website or which you receive by virtue of your membership are more relevant to you and your interests. Cookies may also be used for targeting and tracking methods to measure the performance of our email campaigns.

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

If you do not wish to use cookies, you may be able to adjust the settings on your browser to reject cookies or notify you when they are being used.

Identifiers

We will not adopt as our own any identifiers that you may provide to us unless they are publicly available.

Third party websites

Our website contains a number of links to other websites, including the websites of our commercial partners or relevant regulators. By using these links you acknowledge that it is your responsibility  to check the privacy policy of those websites, and that the FAAA is not liable for privacy practices of those other parties.

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 need to transfer your personal information to the Asia-Pacific, European Union, United Kingdom 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 in so far as we are permitted to do so by law, relevant regulation and the Australian Privacy Principles.

Complaints resolution

We provide 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 regularly review our statements and policies to keep up to date with market expectations and legal developments. We may change this Policy from time to time as the need arises.

A copy of this Privacy Policy will be available on our website and will also be available on request. Members acknowledge and agree to comply with this Privacy Policy as amended from time to time.

Contact us

If you seek any further information from the FAAA about this Policy or our privacy procedures generally, please contact our Privacy Officer:

• Via mail: Privacy Officer, FAAA, Level 6, Suite 6.03, 55 Clarence St Sydney NSW 2000 or GPO Box 4285, Sydney NSW 2001.
• Via telephone: call us on 1300 337 301 and ask to speak with the Privacy Officer
• Via email: send us a note on privacy@faaa.au, for the attention of the Privacy Officer.

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.au.