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  • CRT Alert 094/2018

    Review of SuperMatch use of service

    We have been conducting an ongoing review of the use of the SuperMatch Service, in accordance with the terms and conditions. Following this review, we released version 7.0 of the Terms and Conditions and User Guide. A letter to trustees was issued on 18 December 2018 notifying of these updates.

    During our review it was apparent to us that there have been misinterpretations of the SuperMatch terms and conditions with the addendum leading to trustee solutions not fully complying with the self-certification requirements.

    Specifically, we have concerns about the multifactor requirements for member authentication, consent and disclosures of results from SuperMatch searches. As a result we have updated our guidance to provide further clarification of these requirements.

    We have also engaged with Australian Securities & Investment Commission (ASIC) in ongoing collaborative work and information sharing looking at the use of SuperMatch by trustees and the associated disclosure. ASIC concerns include the lack of appropriate disclosure when seeking permission from members to use SuperMatch. This has included the failure to provide all response data provided by us in the display of results of the search.

    ASIC and the ATO will continue to investigate potential cases of misleading and deceptive conduct where trustees fail to obtain explicit consent from a member to perform a search and where trustees do not provide balanced information about the benefits and risks of consolidation.   

    Reminders for trustees

    Multifactor Authentication is required before results of searches can be displayed electronically:

    • There must be a multifactor authentication event to verify the member before any SuperMatch data can be displayed in an electronic channel to the member, including any cached data.
    • This requirement was due to be in place by 31 December 2017, unless trustees have an approved extension from us.

    There must be explicit consent from the member before a search can be completed. Consent can be stored but you must inform the member of:

    • all the details involved with the storing of the consent
    • how to opt-out
    • the consent period not being indefinite.

    In making disclosures of results from SuperMatch searches, all email, SMS and mobile app notifications informing the member of the results of the search must be general in nature and cannot contain any specific SuperMatch response data. Specific information must be supplied only via an approved Trustee Member Services Portal with two factor authentication.

    Warnings regarding the possible impact of consolidation of accounts on insurance held should be displayed where the member has insurance with another fund identified through SuperMatch (as per the Insurance Indicator).

    Next steps:

    Trustees need further note:

    • If your member portal or SuperMatch solution is hosted by an administrator or intermediary we recommend you engage with them as soon as possible.
    • It's your obligation to ensure you are compliant with the SuperMatch terms and conditions.
    • For those trustees who have not contacted us already or currently not working with us, please undertake an assessment of your solution against the updated User Guide and Terms and Conditions
    • Where you are unsure, or identify any misalignment, contact us by the end of February 2019.
    • If your solution is found to be non-compliant, and you have not contacted us, you are at risk of having your SuperMatch service access disabled until an investigation has been completed.

    The ATO will work closely with you to ensure that your solution is compliant with the positions outlined in the updated documents.

    Contact us

    If you have any questions or concerns contact SPRenablingservices@ato.gov.au.

      Last modified: 04 Jan 2019QC 57712