Your privacy is important to us and we are committed to being open and transparent about how we manage personal information. This helps build community trust and confidence in our organisation. Your Personal Information may be collected for the purposes of providing you a service by our Authorised Representatives, their staff and related entities of Matrix Integrated Professional Advice Pty Ltd. If you have any concerns on how we manage your Personal Information, please refer to the Complaints section of this policy or speak to your Adviser.
Who we are
In this Privacy Policy, references to ‘we’, ‘our’, ‘us’, ‘Matrix’ and ‘MIPA’ (as applicable), are to Matrix Integrated Professional Advice Pty Ltd (AFSL Number 538537, ABN 21 653 111 338).
Definitions
Authorised Representative means an Authorised Representative as defined in the Corporations Act 2001 (Cth).
Adviser has the same meaning as Authorised Representative. May also be referenced as Financial Planner or Financial Adviser.
Financial Service means the provision of financial products such as life insurance, superannuation and retirement income, managed investments and financial planning services and financial product advice.
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not.
Sensitive Information means information or an opinion about an individuals:
- racial or ethnic origin;
- political opinions or membership of a political association;
- religious or philosophical beliefs or affiliations;
- membership of a professional or trade association or trade union;
- sexual orientation or practices; or
- criminal record
that is also Personal Information or
- health information about an individual;
- genetic information about an individual that is not otherwise health information;
- biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
- biometric templates.
This Policy
This Privacy Policy applies to Matrix, our employees, and our Authorised Representatives and their staff. Authorised Representatives are those individuals licensed by Matrix Integrated Professional Advice Pty Ltd (and registered with ASIC) as suitably qualified to provide financial advice to individuals and small businesses.
This policy sets out how we and our Authorised Representatives manage your Personal Information. We respect the privacy of any Personal Information we collect about you and are committed to ensuring that this is handled in accordance with the provisions of the Privacy Act 1988, the Australian Privacy Principles, the FSC Life Insurance Code of Practice and any other applicable privacy related laws. Where there is specific legislation, this will generally govern how we use Personal Information despite the provisions of the Privacy Act 1988. For example, for certain Financial Services, we are required to collect your tax file number and provide that information to the Australian Taxation Office.
This policy is specific to the services provided under our Australian Financial Services Licenses and by our Advisers (and related staff). It has been written specifically for clients of Matrix because of the unique relationship Advisers have with their clients.
Your Privacy
Collection of Personal Information
As Advisers have a legal obligation to provide appropriate advice, and act in the best interests of their clients, the extent of information they require from you may vary, however it is often the full picture of an individual’s relevant personal circumstances. The information they collect is necessary to not only meet these standards, but also to complete any transactions on your behalf with various product issuers, such as superannuation funds and life insurer providers. These can be services provided over the short term, however they are often part of a long term relationship with an Adviser.
Collecting Personal Information also allows us to meet Australian or international legal or regulatory obligations that we, or product providers, might have. These may include, but are not limited to, our obligation to identify and verify clients under the Anti-Money Laundering & Counter Terrorism Financing Act 2006 (AML/CTF Act) or provide information to the US government if a client is considered a US resident for tax purposes under the US Foreign Account Tax Compliance Act.
Collection of Personal Information from other people
In some instances, your information may also need to be collected from third parties such as your employer if you are a member of a corporate superannuation plan, or from your accountant, mortgage broker or solicitor. These may also be provided or received from third parties to enable a secondary service, such as when referred to a solicitor for Estate Planning purposes. In these cases, we will ask for your consent.
Relatives, Dependents and Other Individuals
To enable our Advisers to provide their financial planning advice and services, often your relevant personal circumstances will include information regarding your family situation, such as information about your partner, dependants, beneficiaries and children. This information will only be gathered where it is necessary to provide you services, such as financial planning advice, or for example, where members of your family may become beneficiaries to your life insurance policy or superannuation fund. You are not obligated to provide this information, however it may affect the quality of, or restrict the services provided to you.
Where this information is reasonably required from you, and you willingly provide it, we expect and assume that you have their consent to provide this information to us.
In these circumstances, you need to ensure that they are aware:
- That you have provided their personal information to us
- Of who we are and how they can contact us
- That they may access the Personal Information that we hold about them
- Of the purposes for which you provided their Personal Information to us
- That their Personal Information will be handled in accordance with this Policy, and
- We recommend that you refer them to this Policy.
Use and Disclosure of Personal Information
How do we use your Personal Information?
The Personal Information we hold is used for the primary purpose of providing you financial planning and credit assistance advice services as well as reviewing your ongoing needs. We may also use your Personal Information for related secondary purposes such as: enhancing customer service and product options; communicating with you regarding the products and service you have with us; handling your complaints; and giving you ongoing educational information, newsletters or marketing that we believe may be relevant to your financial needs and circumstances. Where the second purpose is unrelated to the primary purpose you have sought our services for, we will ask for your consent. You may provide your consent in writing, or via telephone.
Depending on the product or service concerned, your Personal Information may be disclosed to:
- Other areas within Matrix Integrated Professional Advice Pty Ltd, who provide financial and other related services.
- Advisers, brokers and those who are authorised by us to review the client’s needs and circumstances from time to time.
- Service providers and specialist Advisers to us who have been contracted to provide Matrix Integrated Professional Advice Pty Ltd with administrative, financial, insurance, accounting, legal, information technology, research or other services.
- Other insurers, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law.
- Credit reporting or reference agencies or insurance investigators.
- AUSTRAC, the government agency who oversees Anti-Money Laundering and Counter Terrorism. Before we arrange the provision of products or services to a client, we are required to validate the client’s identity. We will request and copy some personal documents for that purpose. We are also required to provide details of entities and certain transactions where we hold reasonable suspicion of reportable suspect matters.
- Product or service providers who have an obligation to disclose information to the Australian Tax Office (ATO) where the ATO has agreements to share information with overseas tax authorities.
- Relevant external dispute resolution bodies who would handle your complaint.
Independent service provider
The Advisers authorised by us, may engage individually (or via us), independent service providers to assist them in providing services to you. These services may range from contracted staff for back office duties, and client relationship management systems, to more complex tasks such as accessing direct share advice (on behalf of clients) from specialist share brokerage firms.
These independent service providers (located in Australia) are still bound by the Privacy Act 1988 including the Australian Privacy Principles, and we will also adhere to this policy when dealing with them.
Sensitive Information is subject to greater restrictions
Some Personal Information we hold is classed as Sensitive Information. Sensitive Information may have further restrictions on its disclosure.
Sensitive Information is usually needed for applications for personal insurance and to manage claims on those products. It may also be relevant to credit and other applications. It is Matrix’s policy that Sensitive Information will be used and disclosed only for the purposes for which it was provided, unless the client agrees otherwise or the use or disclosure of this information is allowed by law.
We will only collect Sensitive Information from you where it is reasonably necessary for us to provide the service to you and with your consent, or in limited other circumstances specified under privacy laws.
Unless we have your consent, we cannot use or disclose Sensitive Information about you for any purpose other than the primary purpose of collection or a directly related secondary purpose; nor can it be shared by related bodies corporate in the same way that they may share other Personal Information. Documents asking for Sensitive Information will explain this.
Marketing material
From time to time, Matrix Integrated Professional Advice Pty Ltd (and its related entities) or your Adviser may promote opportunities or products that we believe may be relevant to your financial needs and circumstances.
You can inform us if you do not wish to receive marketing material from us as your Adviser’s licensee or your Adviser. The ability to ‘opt-out’ does not include important disclosure documents and letters your Adviser may send you that include portfolio updates on your current investments, an offer of review or other communications required as part of an Adviser’s general obligations.
Please understand that there could be a delay of up to 60 days before your request is fully implemented, and we apologize if you receive marketing material in this time. You will find details on how to contact us at the end of this Policy.
Information Security
How does Matrix Integrated Professional Advice Pty Ltd and its advisers keep my Personal Information secure and for how long is it kept?
We take all reasonable steps to ensure that your Personal Information is kept secure and is protected from misuse, loss and unauthorised access, modification and disclosure. If you use the secure member sections of our websites we will verify your username and password. Once verified, you will have access to secured content.
We may need to maintain records for a significant period of time. Unless otherwise required by law, when we consider information is no longer needed, we will remove any details that will identify you or we will securely destroy the records. Under the Corporations Act 2001 (Cth), Advisers are obligated to retain a client’s ‘financial planning file’ for a period of 7 years from the date of their last provision of service. The financial planning file will contain a client’s personal information. Processes are in place to ensure this information is securely stored.
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the internet, or other electronic medium. We train our employees, Advisers and their staff who handle Personal Information to respect the confidentiality of client information and the privacy of individuals.
Matrix Integrated Professional Advice Pty Ltd has appointed a Privacy Officer to ensure that the management of Personal Information by it and its subsidiaries is in accordance with its privacy policy (including this policy) and the Privacy Act.
Cross-border disclosure of Personal Information (overseas recipients)
In the course of providing you with Financial Services, we may either engage organisations based overseas or organisations based in Australia that utilise some services themselves from overseas. Some of the organisations to which we may disclose your personal information may be located outside New South Wales or Australia in countries including New Zealand, Japan, South Africa, USA, member states of the European Union, India, Vietnam, Malaysia, Singapore, Thailand, Sri Lanka, Cambodia, Hong Kong and the Philippines. Matrix or our Advisers may send your Personal Information to them, including through electronic transmission. Where personal information is disclosed, we require our contractors and service providers to comply with the provisions of the Privacy Act 1988 and the FSC Life Insurance Code of Practice (where applicable).
Where we disclose your Personal Information to contractors and service providers and we are aware that your Personal Information may be accessed by, or provided to, another party via that contractor or service provider, we will do all that we reasonably can to ensure that any further party granted access to your Personal Information will comply with the Privacy Act 1988 and the FSC Life Insurance Code of Practice (where applicable).
Where this takes place, we will endeavour to protect your personal information and your privacy as we would in Australia. Matrix Integrated Professional Advice Pty Ltd may send your Personal Information to them, including through electronic transmission. Where personal information is disclosed, we require our contractors and service providers to comply with the provisions of the Privacy Act 1988 and the FSC Life Insurance Code of Practice (where applicable).
Dealing with breaches
We consider breaches of your privacy to be very serious and will ensure that appropriate investigation and where necessary, appropriate penalties (including dismissal in some cases) are applies.
From 22 February 2018, we will be required to notify you and the Office of the Australian Information Commissioner (OAIC) if an ‘eligible data breach’ occurs in relation to your personal information that is held by us or another entity with whom we have shared your information. A data breach may occur if your personal information is lost or subjected to unauthorised access, modification, disclosure or other misuse or interference. This obligation extends to breaches that occur within Australia, and where the information is held overseas.
Access and Correction
Can I access my Personal Information?
Under the Privacy Act, you have the right to access any Personal Information that we hold about you and to advise us or your Adviser of any inaccuracy. You can ask us for access to Personal Information that we hold about you at any time. To do so, please call Matrix Integrated Professional Advice Pty Ltd on 02 9899 6077 or email mipa@matrixnorwest.com.au and ask for a Request for Personal Information Form which will be sent to you to complete.
We will respond to your request within 30 calendar days. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.
We will provide you with access to Personal Information held about you except to the extent that we are permitted to refuse access in accordance with the Privacy Act 1988, and the Australian Privacy Principles. If we refuse to provide you with access to some information, we will provide you with our reasons in writing for doing so.
Correction of Personal Information
We will correct any Personal Information that we hold about you if we become aware that it is inaccurate, incomplete, out of date, irrelevant or misleading.
If you believe that the Personal Information we hold about you is inaccurate, incomplete, out of date, irrelevant or misleading, you can ask us to correct it and we will take reasonable steps to do so. If we disagree about any information being inaccurate, incomplete or out of date and you ask us to do so, we will take reasonable steps to include a note on your record that you believe that such information is inaccurate, incomplete or out of date.
Enquiries and Complaints
If you consider that any action by us breaches this Privacy Policy, the Australian Privacy Principles or otherwise fails to respect your privacy, you can make a complaint. Upon lodgement of a complaint with us, you will receive an acknowledgement of receipt and an indication of the timeframe in which we will respond to your complaint. We will try to resolve your complaint within 45 days. When this is not possible, we will inform you of the reasons for the delay.
To make a complaint, please forward it in writing to:
Complaints Manager
Matrix Integrated Professional Advice Pty Ltd
PO Box 6787 NORWEST NSW 2153
Email: mipa@matrixnorwest.com.au
Phone: 02 9899 6077
If you are not satisfied with our response to your complaint, you can escalate the matter to the Office of the Australian Information Commissioner (OAIC) to complain about the way we have handled your personal information. The OAIC can be contacted at:
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Email: enquiries@oaic.gov.au
Phone: 1300 363 992
We are committed to customer focused, effective and efficient complaint handling. We strive to address each claim genuinely, promptly, fairly and consistently, ensure each complaint is treated in an un-biased manner, and all allegations are investigated thoroughly.
This document provides information about our dispute resolution process including how and where complaints may be made and how and when we will communicate with you about resolving your complaint.
If you have a complaint about Matrix Integrated Professional Advice Pty Ltd or one of our financial advisers, we would like to hear from you. The Privacy Policy applies to the Licensee and all subsidiary companies which are set out at the end of this policy.
How you can lodge a complaint
If you wish to make a complaint, please contact the Claims Team on the information below:
Mail PO Box 6787 NORWEST NSW 2153
Phone 02 9899 6077
Email mipa@matrixnorwest.com.au
Website www.matrixnorwest.com.au
Our complaint process is free of charge to you. Your complaint does not need to be in writing. If you require any assistance to lodge your complaint, please let us know. You may also choose to authorise a representative to make a complaint on your behalf.
We are bound by the Privacy Act, and we manage and protect your personal information in accordance with the Australian Privacy Principles.
How we will deal with your complaint
We will respond to your complaint in a timely and flexible manner. Our goal is to ensure the earliest possible resolution and we will try to resolve your complaint wherever possible at the first point of contact. Where your complaint is urgent it will be prioritised.
We will ensure you have the opportunity to explain your complaint. To this end we ask that where possible, that you provide the following information about your complaint:
- your full name, date of birth and contact details
- if relevant, your financial adviser’s or mortgage broker’s name
- the names of any service providers, such as any investment, insurance or credit product providers, associated with your complaint
- any identifying account numbers or other references, such as an investor number, loan number, policy number or superannuation account number
- supporting documentation and
- the resolution you are seeking.
We will address your complaint fairly and consistently, treating each complaint in an un-biased manner, and ensuring all allegations are investigated thoroughly. We will inform the financial adviser or mortgage broker involved about your complaint and ask them to respond to us.
Once your complaint is resolved any agreed outcomes will be implemented in a timely manner.
How and when we will communicate with you about your complaint
We will acknowledge the receipt of your complaint within 1 business day verbally or in writing. Where this is not possible, acknowledgement will be made as soon as possible.
We will investigate your complaint promptly and respond to you within 30 calendar days. Our response will include:
- The outcome of your complaint including the actions taken to resolve it
- The reasons for our decisions and
- Information about your rights if you are not satisfied with the resolution.
If we are able to resolve the complaint to your complete satisfaction within 5 business days, we may not provide a written response unless you request a response in writing.
Some complex matters may require additional time to thoroughly investigate the complaint and bring it to a resolution. Where additional time is required, we will advise you in writing within 30 calendar days of receiving the complaint. We will explain the reasons for the delay.
We will communicate openly throughout the process.
If you are not satisfied with the resolution of your complaint, you can lodge a complaint with the Australian Financial Complaints Authority (AFCA).
Your right to lodge a complaint with AFCA
If an issue has not been resolved to your satisfaction, you can lodge a complaint with AFCA. AFCA provides fair and independent complaint resolution that is free to consumers. The contact details for AFCA are:
Mail GPO Box 3, Melbourne VIC 3001
Phone 1800 931 678 (free of charge)
Email info@afca.org.au
Online www.afca.org.au
We may amend or update our Complaints Policy as required by law or as our business processes changes. We will post the updated policy on our website – www.matrixnorwest.com.au. We encourage you to check our website from time to time to view our current policy or contact us for a printed copy.
The Complaints Policy applies to the following organisations which are all part of the Licensee’s Group:
- Matrix Norwest Financial Planners Pty Ltd ABN 38 003 667 669
- Matrix Norwest Asset Management Pty Ltd ABN 54 645 347 280
- WRI Matrix Norwest Pty Ltd ABN 54 096 923 447
