DATE: 7 March 2018
Front Row Financial Management Pty Ltd ACN 168 945 097 as trustee for the FRFM Unit Trust ABN 97 476 145 568 trading as Front Row Financial (Front Row/We/us)
Please note that if at any time Front Row is required by law to release information about you, Front Row must cooperate fully.
- Your personal information
Front Row recognises that your privacy is very important to you and that you have a right to control your personal information. We know that providing personal information is an act of trust and we take that trust seriously.
What does “personal information” mean?
Personal information is any information about you that identifies you or by which your identity may be reasonably determined. By collecting this personal information we are able to:
- Assist you in managing your financial needs;
- Contact you when and where necessary;
- Ensure that you attain the best possible service; and
- Identify you and protect you from any unauthorised access to your personal information.
If you choose not to provide personal information to us, we may not be able to provide you with our services.
Types of Personal Information Collected
We collect your personal information directly from you either in person, over the phone or by email. We collect your information to provide our services to you at your request and to ensure that you receive the best possible service from us.
Some of the types of information which Front Row gathers include:-
- Information that you give us:
Information that you provide to us is received and stored by Front Row. We may utilise the information you provide, such as your name, date of birth, residential address, email address, telephone numbers and financial information to communicate with you and to provide you with our services.
- Automatic information:
Front Row may record anonymous information which tells us about visitors to our website but not the identity of those visitors. For example, we may collect information about the date, time and duration of those visits and which pages of our website are being commonly accessed. We may also use “cookies” that are small pieces of information that allow an organisation to track websites browsed by you. You may be able to adjust your browser to disable cookies. However, if you do disable cookies, you may not be able to interact with our website or take advantage of the improved functionality that cookies enable.
- Email communications:
We receive personal information from you when you provide your contact details and email address when you interact with or contact Front Row.
- Information relating to your engagement of us:
- Information that you provide to us for the purposes of engaging us to provide our services to you, which includes your financial information.
- Any other information that you send or provide to Front Row.
How Front Row Collects and Holds Personal Information
Front Row will collect your personal information directly from you, either in person, over the phone or by email.
As a general rule, we do not collect sensitive information. Sensitive information is a type of personal information and can include, but is not limited to, information about an individual’s health, opinions and beliefs. However, if we do collect sensitive information, it will usually be for the purposes of providing our services and we will seek your consent to collect it.
Front Row holds and stores personal information within a number of controlled third-party applications discussed in detail at point 3 below.
- Why Does Front Row Collect and Hold Personal Information?
We collect your personal information for purposes including:-
- Supplying to you the financial services which you have requested;
- Providing you with updates on news and upcoming promotions;
- Updating you in relation to products or services that have or could be provided to you;
- Administering the website, http://frontrowfinancial.com.au/
- Enabling your access to use the website;
- Send to you statements and invoices and collect payments from you;
- Improving the quality of services provided to you; and
- Send to you marketing communications.
We may use personally identifiable information in a summative form to improve our services and make them more responsive to the needs of our customers. This statistical compilation and analysis of information may also be used by us or provided to others as a summary report for marketing, advertising or research purposes.
We will not sell, transfer, assign or rent your personal information.
In order to deliver the requested services to you, it will be necessary for us to disclose your personal information to other parties such as financial institutions with whom you may apply for financial products.
We will not otherwise disclose your personal information to other companies without your consent.
Personal information is also collected to ensure that the products or services that have been sought from Front Row are effectively and efficiently delivered to you.
Who would Front Row disclose your personal information to?
Front Row will need to disclose your personal information, where you have consented to us doing so, in providing you with our services or where disclosure is necessary to achieve the purpose for which it was submitted.
We may need to disclose or transfer your personal information if Front Row is acquired or merged with another entity.
Front Row will, at all times, attempt to ensure that we do not disclose your personal information to a third party where consent for such disclosure has not been given. In all cases where we may be required to disclose information we will attempt to obtain your direct consent for such disclosure.
Please note that if at any time Front Row is required by law to release information about you, we must cooperate fully. We may also disclose your information in order to investigate, halt or take action regarding illegal activities.
- Direct marketing
Front Row may from time to time use your personal information, such as your email address or contact details, to provide you with information about other services that we offer.
If at any time you do not wish to receive any information about these services please feel free to contact us on (07) 3256 8072 or by email on firstname.lastname@example.org and we will not send you any further material.
- Your personal information and overseas disclosure
Information which Front Row collects is stored and processed on an NAS Synology device located on Front Row’s premises.
All files and information are backed up to Microsoft OneDrive servers and encrypted via password protection. All information collected or held by email is hosted in Microsoft Office 365.
You acknowledge that the servers for Microsoft may be held in countries abroad and you agree to cross-border transfers of personal information.
- Data quality and security
Front Row endeavours to take all reasonable steps to keep secure any personal information which we hold about you, and to keep this information accurate and up to date.
In the extremely unlikely event that Front Row suspects that there has been a data breach that may cause you serious harm, we will take all reasonable steps to assess if your data has been accessed or lost, and if this information being accessed or lost may cause you serious harm. This assessment will always be completed expeditiously and within 30 days.
If Front Row finds that there has been a data breach that has the potential to cause you serious harm, this will be reported to the Office of the Information Commissioner and you directly.
We strive to ensure the security, integrity and privacy of the personal information of our clients. We use a variety of physical and electronic security measures including restricting physical access to our offices and firewalls and secure databases to keep personal information secure from misuse, loss, modification, unauthorised access or disclosure. In addition, our employees are obliged to respect the confidentiality of personal information held by Front Row.
- How can you access your personal information and/or seek correction?
You may access and/or request that your personal information be edited or corrected by contacting us in any of the following manners:
By Post: Brendan Turnbull, Front Row Financial Management, PO Box 907, Bulimba QLD 4171
By phone: (07) 3162 0046
We strive to ensure that all personal information stored is accurate, up-to-date and complete.
We may require you to sign a document stating that you have accessed your information.
- How can you complain about a breach of the APP’s?
If you are unsatisfied with the manner in which Front Row has dealt with your personal information and wish to complain, you can direct your complaints to:-
By Post: Brendan Turnbull, Front Row Financial Management, PO Box 907, Bulimba QLD 4171
Front Row will, within seven days, respond to you and attempt to resolve with you your issues as they pertain to your personal information.
If you are still unsatisfied, you may wish to direct your complaint to the Office of the Australian Information Commissioner at http://www.oaic.gov.au/ or alternatively:
By phone: 1300 363 992
In writing: The Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001
- Updating This Policy