Data Collection and Storage Policy.

Divergent Wealth Pty Ltd operates under the licence and compliance standards of Lifespan Financial Planning Pty Ltd (AFSL 229892), and we fully adhere to their data collection, cybersecurity, and compliance obligations.

Information We Collect

We collect personal information required to provide you with appropriate financial advice, including:

  • Name, contact details, and identification information

  • Financial circumstances, objectives, and personal goals

  • Supporting documents necessary to assess suitability of advice

  • Tax File Numbers

All data collection practices are carried out in accordance with the Privacy Act 1988 and the Australian Privacy Principles (APPs).

How Your Information is Stored

Your personal and financial information is stored securely using enterprise-grade systems with multi‑layered protection. This includes:

  • Two‑Factor Authentication (2FA) across internal platforms

  • Encrypted cloud storage and secured off‑site backups

  • Compliance with the Essential Eight cybersecurity strategies published by the Australian Cyber Security Centre

  • Strict role-based access controls to ensure that only authorised staff can view client information

We maintain electronic records of all advice, research, and file notes in a retrievable and auditable format. Your information is accessed exclusively by authorised Diversion Wealth staff and authorised personnel within Lifespan Financial Planning, including compliance and audit teams.

Technology Platforms

We use secure, industry‑recognised platforms, mostly the Microsoft 365 Suite, to manage secure client communication, document sharing, and advice delivery.

While Divergent Wealth takes all reasonable steps to ensure your information remains within Australia, some trusted third‑party partners may store or process data on overseas servers. In these instances, we require that:

  • The provider meets or exceeds international security benchmarks

  • All data remains encrypted and subject to access controls

  • Providers are reviewed regularly for compliance with the Australian Privacy Principles

Use and Purpose of Data

We do not sell or rent client information. Data is only accessed and used for the purpose of delivering quality financial advice and services in line with regulatory obligations.

Data Sharing and Communications

To minimise risk, we discourage the use of email for transmitting sensitive financial documents. Instead, we require clients to use their secure SharePoint client portal to upload personal or financial information, helping mitigate risks such as phishing, interception, or accidental disclosure.

Recordkeeping and Retention

Divergent Wealth retains client files in accordance with Lifespan’s recordkeeping requirements, for a minimum of seven years following the end of the client relationship.

Client Rights and Queries

Clients have the right to request access to their personal information and to correct any inaccurate or outdated records. Requests can be made in writing to Divergent Wealth.

For full details, please refer to Lifespan's Privacy Policy or contact us at hello@divergentwealth.com.au.