Don't over-complicate superannuation privacy
Superannuation funds should be permitted to 'bundle' consent by their members to provide information covered by the Privacy Act, according to the Association of Superannuation Funds of Australia (ASFA).
In a submission filed with the Privacy Commission dealing with the draft Australian Privacy Principles, ASFA has argued that the 'bundling' of consents is often necessary in practice for superannuation funds to prevent confusion, inconvenience and inefficiencies.
"In the superannuation industry (and, indeed, the broader financial services industry), a provider will typically collect some relatively commonplace items of personal information, which are then used and/or disclosed for a number of different purposes, many of which are required or authorised by law," the submission said.
"In carrying out these purposes, the provider may need to disclose the information to a range of outsourced service providers - for example, administration ('back-office') service providers, insurers, actuaries, technology providers, mail-houses, regulators and complaints handling bodies and, in relation to members who seek to roll over their benefit, other superannuation funds."
The ASFA submission said it was currently common practice for the provider to obtain a single, 'bundled' consent to the collection of such information.
"Requiring the provider to request separate consents - in effect purporting to allow the member to 'pick and choose' the uses and/or disclosures for which they will consent - is highly impractical, for a number of reasons," it said.
"In some cases, the member may attempt to withhold their consent to the collection of information that is required or authorised by law, which is likely to cause confusion.
"It would significantly increase the length and complexity of the collection notification; It would require the provider to develop and maintain the capacity to record and store multiple consents for individual items of personal information."
Originally published on SMSF Essentials.
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