VA Platinum Insights

Most mortgage brokers don’t have a lead problem , they have a capacity problem.

In this episode, Kate Garrett, Director of Littlespring Finance, explains how she increased her brokerage capacity from around 10 deals per month to consistently handling 18–25.

The shift didn’t come from more marketing or longer hours. It came from changing how work flowed through the business and introducing full-time operational support that allowed her to focus on revenue-generating activity.

For brokers approaching their own growth ceiling, her experience highlights a shift that many growing brokerages eventually need to make.

The Capacity Ceiling Most Brokers Eventually Hit

Most brokers reach a point where deal flow increases — but so does pressure.

The issue isn’t finding clients. It’s managing the operational workload that follows.

As files move through the pipeline, brokers often find themselves handling:

• Document collection
• Lender follow-ups
• Application preparation
• File updates
• Settlement coordination
  
  

None of these tasks generate revenue directly, but they consume a significant portion of a broker’s time.

Over time, the broker becomes the operational bottleneck inside their own business.‍

When every file requires the broker’s involvement at multiple stages, growth eventually slows, not because there aren’t enough deals, but because there aren’t enough hours in the day.

Why Part-Time Support Doesn’t Fully Solve the Problem

Many brokers try to solve this problem by bringing in part-time administrative support.

On the surface, it feels like a sensible first step.

But mortgage broking workflows rarely fit neatly into part-time schedules.

Files move constantly throughout the week, and tasks arise at unpredictable moments — lender updates, valuation issues, compliance checks, or missing documentation.

When support is only available part-time:

• Files can stall outside available hours
• Tasks build up between working days
• Brokers step back in to keep deals moving
  
  

Instead of removing the bottleneck, the broker often becomes the backup operator whenever the workload spikes.

The real issue isn’t simply having help. It’s having consistent operational coverage.‍

The Operational Shift That Unlocks Growth

The change that allowed Kate to scale her brokerage was introducing full-time operational support embedded directly into her workflow.

Instead of managing every stage of a deal, the responsibilities became clearly divided.

Broker focus

• Meeting clients
• Structuring deals
• Managing relationships
• Generating new business

Operational support focus

• Preparing applications
• Managing documentation
• Liaising with lenders
• Moving files toward settlement
  
  

This shift dramatically changed how work moved through the pipeline.

More deals were able to progress without Kate touching every file.

That single change created the capacity needed to handle nearly double the volume of deals.

The Reality of Training and Onboarding

Operational support doesn’t instantly solve capacity challenges.

In the early stages, brokers must invest time in training and onboarding.

New team members need to learn:

• How files are structured
• How documents are handled
• Lender preferences and submission standards
• Client communication expectations
  
  

That means brokers initially spend time explaining systems, processes, and workflows.

But once those foundations are in place, the support structure becomes a true operational extension of the business.

Instead of reacting to every file, the broker begins to operate at a higher level  focusing on clients and growth.

The Outcome: More Deals Without Longer Hours

The biggest change wasn’t simply efficiency.

It was confidence in the workflow.

When operational processes run reliably without constant oversight, brokers gain the freedom to focus on the parts of the business that actually drive growth.

That includes:

• Developing referral relationships
• Supporting complex lending scenarios
• Spending more time with clients
• Expanding the brokerage strategically
  
  

For Kate, that shift allowed Littlespring Finance to move from around 10 deals per month to consistently handling 18–25.

Not by working longer hours but by changing how work flowed through the business.

The Insight Most Brokers Miss

Brokers don’t scale by doing more deals themselves.
They scale by removing themselves from the file.

When the broker is responsible for every operational step, growth eventually stalls.

But when the workflow is redesigned with the right operational support in place, capacity expands naturally.

The broker stops executing every task and starts leading the business instead.

What the Full Conversation Reveals

This article covers the key operational shift but the full conversation goes much deeper.

In the episode, Kate also shares:

• How daily communication with operational support actually works
• How trust develops over time within the partnership
• What the onboarding process looks like in practice
• Why meeting your offshore team in person can strengthen the relationship

These insights give a clearer picture of how a brokerage support structure functions day-to-day.

Watch the Full Episode

If your brokerage is approaching a capacity ceiling, this conversation is worth your time.

Kate shares the operational changes that helped Littlespring Finance grow from around 10 deals per month to consistently handling 18–25 without increasing her workload.

Watch the full episode here :

‍‍

Why I encourage Clients to visit their VAs within the first 18 Months

If you’re working with Virtual Assistants (VA), one of the best things you can do is visit them in Cebu or Davao within the first 18 months.

It’s not a requirement for success, but it makes a noticeable difference.

When you sit beside your VA, see how they work, meet the broader team, and spend time together outside of work, the relationship changes. Communication improves, expectations become clearer, and your VA feels even more connected to your business.

Most clients who visit say the same thing afterwards - they wish they had done it sooner.

 

Making the Trip to Cebu

Over the years I’ve tried just about every airline, route, and connection possible between Australia and Cebu. Some were great, some less so, but it means I can give clients a fairly honest view of what works.

If you’re planning the trip, here are a few options and what to expect.

Singapore Airlines

Singapore Airlines is my personal top pick when flying to Cebu.

From Australia, the journey via Changi Airport typically takes about 7 hours for the first leg, followed by around 4 hours from Singapore to Cebu.

Layovers in Singapore are commonly 1.5 to 5 hours, which keeps the journey fairly efficient. Changi Airport is also very easy to transit through, which helps after a long flight.

Another advantage is pricing. Quite often Singapore Airlines comes out more reasonable than other full-service airlines, whether you’re flying Economy or Business, depending on timing.

If you collect frequent flyer points, it’s definitely worth checking availability for upgrades on the longer leg.

Cathay Pacific

Cathay Pacific is another reliable option.

Flights from Australia to Hong Kong take roughly 9 hours, followed by about a 2.5-hour hop to Cebu.

Hong Kong is generally an efficient airport to transit through, and the connection to Cebu is fairly quick.

The main thing to watch is pricing, which can sometimes be higher depending on the travel period.

They offer good service and options for night time flights. Using points to upgrade from premium economy to business on the longer leg is worth considering if you want extra comfort.

Scoot

Scoot is a lower-cost alternative, flying via Singapore.

It’s a simpler onboard experience than the full-service airlines, but it can be good value if the timing works for you.

Just be aware that schedules don’t run as frequently, so your connection time may be longer than the major carriers.

Philippine Airlines (PAL)

PAL typically operates flights from Australia to Cebu via Manila.

The first leg from Melbourne usually takes around 8 to 9 hours, followed by about a 1 to 2-hour domestic flight to Cebu. Layover times in Manila depend on the specific schedule and can vary from a couple of hours to longer connections.

It’s worth noting that Manila can be a more complex airport for international transfers, and flight schedules can occasionally change. Because of this, it’s advisable to allow extra time between connecting flights to avoid stress or missed connections.

From both my own experience and feedback from some clients, travelers have sometimes encountered challenges in Manila, including:

·       Delays or mishandles in baggage handling.

·       Security procedures that can be time-consuming especially during peak travel periods.

·       Instances of theft, such as stolen phones or personal items.

Being aware of these potential issues and planning accordingly can help make the transfer smoother and reduce the risk of complications.

PAL is generally reliable, though not as seamless as Singapore Airlines or Cathay Pacific. If you have points or want to upgrade, check availability for added comfort.

Cebu Pacific

Based on experience, they are the least reliable.

Cebu Pacific is the most budget-friendly option but comes with trade-offs.

Flights often stop in Manila, even if advertised as direct, and layovers can be long depending on your itinerary. Travel times are usually longer overall, but for cost-conscious travelers willing to be flexible, it’s a practical choice.

Traveling to Davao

To those visiting our Davao office, it’s important to plan your travel accordingly.

Flights from Australia to Davao typically route via Manila, with a connection to Davao taking around 1.5 hours. Layover times in Manila can vary, and it’s worth allowing extra time to navigate the airport efficiently, as schedules sometimes change and connections can require additional planning.

Alternatively, some clients choose to fly via Cebu, connecting onward to Davao. The Cebu to Davao leg takes about 1 hour. This option can be convenient if your itinerary aligns with flights through Cebu, though for direct access, Manila connections are the standard route from Melbourne.

While my own trips to Davao are usually same-day visits from Cebu, clients traveling specifically to Davao will need to plan for the connection and layover logistics. Proper scheduling ensures a smooth and productive visit with your team there.

Whether going to Cebu or Davao, there are other low-cost carriers that you can try. You can even choose to book flights with different airlines to customise your travel.

Some people do this to buy time and spend it on touring other cities before Cebu or Davao. It’s not an easy option because it takes harder work, but if maximising your travel is your priority, then you’ll be alright.

I hope you find my personal notes on getting the best Australia to Cebu or Davao flights helpful!

Written by Brian Jones, Founder & CEO of VAP.

Do you only want to hire Filipino staff because you’re a scrooge and you want work done for peanuts?

Remember if you pay peanuts, you get monkeys.

In this article, I’m exposing in raw detail what you should be paying Filipino virtual assistants and what their standard of living is at different levels of income.

Can they afford to put their kids through school?

Do they have to take a second job just to put food on the table?

If you’re like me, you’ve asked these questions and probably many more.

Overview of the Labour Market

Overall, the Philippines is an employees market.

It’s said that an employee can leave one business at morning tea and start with another by the afternoon.

This isn’t actually true because the labour code in the Philippines is strict that employees give 30 days’ notice to leave a business, but you get the picture.

There’s more to recruiting and keeping virtual assistants. You have to ensure you pay on time, treat them with respect, evaluate them regularly, give them paid holidays, and consider extras like health insurance and bonuses.

The horrific stories staff tell me about their previous working conditions and salaries have alarmed me.

It’s no wonder they want to jump ship.

Some Nagging Questions

Even though we pay our team well, every so often, I find myself asking…..

What does it cost my team to live comfortably?

Do I pay them enough?

Am I exploiting lower wages?

Or, am I paying my teams much more than the average and therefore giving them a better life?

For peace of mind, I interviewed staff and did some research online.

I’ve broken the findings down into 5 key areas:

1. The Philippines versus Australia

After 10min of Googling (is that even a word?), I discovered:

The website Numbeo states that:

“You would need around AUD $2,516.86 (99,161.36₱) in Cebu per month to maintain the same standard of life that you can have with AUD $6,200.00 in Melbourne (assuming you rent in both cities).”

The website Pay Scale states that:

the average wage in the Philippines for a customer services representative is AUD $790 (19,800₱).

Holy smoke, there’s a huge difference of 3 times between what a Filipino would need to earn compared to what they actually receive to have the same standard of living in Australia.

2. Do Filipinos expect the same standard of living as Australians?

In my trips to the Philippines, I can tell you that Filipinos don’t have the same expectations as Australians.

A Filipino considers they are doing well if they:

• Buy a daily coffee
• Can pay shopping centre prices at the food court compared to street vendors
• Buy regular items such as clothes and shoes
• See a movie

Australian’s take the above as a given, so they consider they are doing well if they can also:

• Own a car
• Live in a 3 bedroom, 2 bathroom house they are paying off
• Afford to regularly travel overseas

Consider this example, one-third of Australian parents CHOOSE to send their children to private schools, costing them AUD $20,000 per annum per child. That’s double the annual customer service wage in the Philippines just to send a child to a private school instead of a public school where the standard of teaching is arguably similar and would cost around AUD $850.

3. Non-cash remuneration

This is a big trap, so don’t get caught out.

Let’s say you’re interviewing a candidate and they earn ₱20,000/mth but you were considering paying them ₱30,000/mth.

You start second-guessing yourself why you should pay 30% more.

Make sure you ask questions about their ‘other benefits’ such as:

• Is breakfast supplied? If yes, is it just bread or is it a cooked breakfast?
• Do you get HMO (health insurance)? If yes, can you include family members at no extra cost?
• How much rice money?
• Do you get a travel allowance?
• Do you receive an attendance bonus or a Christmas bonus?

These extra benefits could add up to another ₱10,000 per month.

4. Comparison of living standards for different jobs

If we have to, anyone can live within their means.

As an employer, do you want your staff to value their job, or just be doing it until they can find something better?

Imagine training a team member for 6 months only to have them leave because they didn’t feel valued.

The table below gives you a guide as to the salary you should be paying Filipino virtual assistants. Mind you, we have staff joining us with 3+ years’ experience and they are being paid as junior call center agents.

5. How do the lowest-paid staff survive?

When a low-paid person is earning as little as AUD$250/mth (₱10,000), there is nothing left for social activities, hobbies, or personal pleasure.

So although happiness is an internal mindset, not having enough money can contribute to people’s level of health, wellness and mindfulness.

These entry-level working Filipino citizens would need to spend at least ₱10,300 on housing rent, bills, food, transportation, laundry, bathroom, and a phone credit allowance.

They need to be living at home with family or living in a hostel-style accommodation where they only have a bedroom and need to share the bathroom, kitchen and lounge with other tenants.

6. What about above-average paid staff?

Staff earning an annual income of ₱20,000-₱25,000, may opt to get an apartment instead of living in a cramp boarding house or bed space. A basic apartment can cost between ₱6,000-₱10,000 per month whereas renting a whole house can be anywhere between ₱12,000 to ₱20,000 depending on the location and neighborhood.

For a single person living on his/her own, ₱15,000 can get a person by with a little extra to enjoy personal desires.

But do you want to pay staff so that they can just get by?

Maybe they’ll end up taking a second job working at night and then start not performing all of a sudden and you begin questioning why.

Out of the blue, they stop communicating with you.

Of course, you blame them and blame the whole Philippine Virtual Assistant industry. But you shouldn’t.

Did you consider their feelings? Did you respect them? Did you create an open and transparent relationship? Or did you act as a dictator from across the ocean and expect them to perform for you?

By the way, if this is you now? Don’t worry, I was there too 4 years ago. But we can all learn to be better. I’m still improving every day.

7. Above-average working-class Filipinos with KIDS

All VA Platinum staff start off in this income band between ₱25,000 to ₱40,000.

Many of our team have children because we typically hire staff with years of experience.

Here are common expenses you will have to prepare for when bearing fruit:

A one-time fee (depending on how many children you intend to have!). Note that the Philippine government offers monetary assistance of up to ₱32,000 expecting mothers for the first (4) four children.

Then here comes your monthly expenses on top of hospital bills and month-to-month expenses.

To conclude, for an average Filipino household family with 1 child to maintain a comfortable lifestyle, the family income must reach at least ₱50,000 per month. Should they consider adding more children, the cost would be higher.

8. Other things to know

Many Filipinos support their family, parents included. In fact, many are the main breadwinners of their families, supporting their siblings through school and helping their parents in their retirement.

This is important to Filipinos so don’t downplay it. Understand it, and value that you have a staff member that is looking out for their whole family. I get choked up about this because it’s a special kind of person that does this.

Filipinos don’t like conflict, so try to be even-tempered and fair with all your feedback.

Filipinos are traditional and have important annual holidays to celebrate their ancestors and religions.

Cash is the best bonus/reward.

What have I learnt?

It’s not easy to get the equation right to paying Filipino virtual assistants the right wage.

There’s a lot to consider and if you’re still confused, don’t worry, I think you have to take each situation as it comes.

The main thing I believe is paying Filipino virtual assistants slightly more than you feel comfortable paying. This will help ensure your staff feel valued and they will want to reward you back with incredible performance.

Lastly, I can’t stress this enough….get over and meet your Virtual Assistants. Get to know them. Understand where they live and how they get around.

Every time I’ve done this, it has helped me know what to pay my team and the rewards I get back are 10x.

Unsure what questions to ask a virtual assistant or prospective staff before hiring?

More financial planners, mortgage brokers and financial advisers are adapting to better business practices with the help of virtual assistants in the Philippines.

Apart from the obvious cost-effective benefits, advisers are more productive when they hand over the administrative tasks to their staff.

If you’re reading this because you’re about to get your own virtual assistant for financial planning or a virtual assistant for mortgage broking, you’re in the right place!

Here’s what most financial planners, mortgage brokers and other financial advisers miss when conducting interviews.

A good resume should show their relevant work background, work description, education and other qualifications. If this kind of information isn’t laid out, then it’s actually a bad sign.

In addition to prodding deep into the technical content of their resumes, what you could also focus on is how compatible you are with the staff you’re hiring.

The Invitation to Dinner Test

Compatibility plays a crucial part in hiring a virtual assistant. After all, they will work with you directly and interact with you on a daily basis.

You don’t want someone who “just gets the job done”. Instead, you want someone who you can easily relate to and communicate with.

For every interview, ask yourself – “Is this someone I’m willing to invite over for dinner with my family?”

Are they interesting enough? Can I have a meaningful conversation with this person? Are they fun? Are they both interesting and interested?

The answer to that is your best bet at making the most out of your offshoring venture.

In this article, I’m rounding up my top 5 questions to ask a virtual assistant during an interview. These questions have worked in my favour, and will work for you too!

1. Ask them about their life outside work.

One of the questions to ask a virtual assistant is to have them talk about what happens outside of work and see how easily the conversation flows. Check how interesting and engaging they can be.

Ask simple questions like, “Tell me about your daily life”, “Are you married?”, “Which flavour ice cream do you like to eat?”, or “What’s your weekend like?”…

Conversations don’t work one way, so try to share some of your stories with them too!

Ask them if they have questions for you too. This way you can gauge their interest in you.

If they’re not interesting for you, then they’re not going to be an interesting person for a client, or for a client’s client.

This awfully sounds like going on a blind date, but isn’t having a good conversation the best way to start all types of relationships?

You wouldn’t get a lifetime’s worth of knowing your staff but it gives you a good insight into what your staff values are. In return, it’ll be easier for you to make them realise the value you put in your work and business.

2. How easy are they to understand?

This is more of a question you ask yourself while conducting the interview.

How well do they respond to a question?

Do they resort to using a very thick accent? Do they talk too quickly?

Do they make it easy for you to understand what they are saying?

Are they answering in a coherent manner or do they lose the subject too often that it’s distracting?

Knowing how well someone communicates doesn’t only prove their speaking skills. What’s more useful to know is the person’s ability to think on their feet.

3. Ask why they want to work with you.

Know the reason why they want to be part of your business.

Is it because of the pay?

Personally, I think that getting “a bigger pay” is not enough reason. Simply because, if someone else lures them out with more, they tend to jump ship easily.

Is it just because of career advancement?

Or, do they just want a change in the working environment?

If they come to you because of this, then you can expect that they will probably last 2-3 years until they feel the same issue and leave.

Is it because their bosses weren’t treating them well and that makes them emotionally stressed?

Is there’s no clear guidance in the company training or some of their work expectation that wasn’t provided?

Look for a stronger motivation and reassure the staff of what you can provide for them.

Your assessment should help you find staff who can stay with you for 5 years plus.

This is how you can predict how long they can work for you and what kind of commitment they’re willing to give you.

4. Ask about their relationship with their previous company.

This is somehow related to question number 3, but placed in a different angle.

What you want to know is how they talk about their relationship with the previous company.

If you get a hint that you might be operating similarly to their previous workplace, or that you share a key characteristic with them and it has become crucial to why the staff left, then it’s a possible NO for that candidate.

Here’s an example:

If an applicant tells me that they left their old job because their previous company was growing too fast, I know that they’re not a good fit for VA Platinum.

Or,

If an applicant tells me that they left because their previous company was operating early in the day and I know that I operate in the same schedule, then it’s absolutely a no-go.

Also, consider how they describe their previous company to you.

If they’re too revealing about their previous workplace, or that they easily give up classified information… you might find yourself in the same threat.

You want to keep everyone happy by understanding the staff’s expectations from you and your business.

5.  Ask them about their successes.

While it’s great to hear about individual achievements, it’s better to hear how well they work with a team.

This is a personal deal-breaker for me since I work with a lot of people.

I want to hear how a person performs in a team and what achievements their team had.

Ask them, “While in a team, what did your team achieve?”

What you want to hear is not about them being better than their elbow buddy. Rather, you want to understand how they help others to be better for the team’s sake.

Asking these questions helps me and my clients get the best suited virtual assistants in the Philippines.

It’s wonderful to know how a “culturally fit” staff member works seamlessly for the benefit of your business.

Aside from the geographical distance, there’s really not much difference between hiring a virtual assistant and having someone in your physical office.

You should always treat and interact with your staff as if they sit beside you every day.

Building a good relationship with your virtual assistant that goes beyond what your business requires is a great investment. It’s an amazing workplace culture you will want to cultivate and enjoy.

As a busy executive or business owner, how much better would your life be if you hired someone who’s dedicated to looking after your diary, travel plans, emails, and reports?

So much easier, I bet!

And so, you must have thought about hiring a personal assistant or executive assistant.

Good decision!

As you’re on your own EA search, you probably have stumbled upon several online contents showing a buzz about hiring a Virtual Executive Assistant.

You should be thinking… “Is there a real benefit in hiring someone local versus getting someone offshore?”

Since I’m about to hire a virtual executive assistant (EA) myself, I’ve written this article to explore the whys of hiring offshore executive assistants.

While doing my research, I came across this very interesting news…

As reported in the Australian Financial Review in February 2018, Ernst and Young now have 38 Executive Assistants in Manila working for executives in Australia and New Zealand. Ernst and Young started a trial in 2016 with 20 EAs in Manila and the number has been steadily grown. 15% of Ernst and Young’s EAs are now hired offshore!

So what made them (and soon…me!) hire an offshore and virtual executive assistant?

Here’s what I have to say…

1. Scope of responsibility

Personally, I’d be happy to employ someone very organised and resourceful, has advanced skills in MS Excel, can handle document preparation, and take on tasks confidently in a timely manner.

Specifically, I need my EA to:

• Manage my travel schedules
• Process and keep track of my expenses
• Coordinate my meeting schedules
• Email management
• Compile and create presentations

Unsurprisingly, these are tasks that don’t require physical presence. So having someone offshore to take care of them isn’t much of a worry.

Also, tasks are easily delegated and communicated over email, Skype, Zoom, or whichever communication tool you prefer to use.

The catch is, it’s absolutely important that you make clear and concise instructions. This way you may anticipate that the work you want to be done is done well.

Of course, there are downsides to not having a local EA,

Basically, A Virtual EA cannot…

• Find a venue to run an off-site meeting
• Facilitate print jobs
• Pick or deliver things
• Attend events or meetings on your behalf

But if like me, you only require support that does not involve the tasks above, then hiring a virtual VA might just be the right decision to make!

2. Availability

Well, the point of hiring an EA is you want someone to help carry on tasks that eat away your time.

You might think that availability is a serious concern if you hire someone offshore, but it’s fascinating to know that it’s not.

In a study conducted by the Stanford University School of Business, it has been revealed that those who work from home (or remotely) were 13% more productive than those who are in the office.

This goes to show that as long as you clearly define your work hours, you can get in touch with your virtual executive assistant as often as you can with a local EA!

3. Monitoring Work

Getting the job done well is essentially what I value the most.

Because of the limitation of interaction you have with a virtual EA, there might be lesser opportunities to track a virtual EA’s work.

The good news is, with the help of tools for time-tracking, such as TimeDoctor, Toggl, Qbserve, etc. you can remotely observe how your staff spends the day!

4. Cost-saving

On the latest Payscale report, it shows that a local EA in Melbourne earns an average base salary of $5,755 AUD per month.

Meanwhile, an offshore EA from the Philippines will normally cost you around $2,000 AUD – and that already accounts for HMO, internet, facilities, and even free meals!

So how much difference are we talking about, cost-wise? Holy smokes! We’re talking about more than 50% savings!

Plus, it’s no secret that the cost of living in the Philippines is much cheaper compared to Australia. That said, even though your savings is significantly large, your staff still enjoys working for a better value compared to other white-collar jobs in their country.

4. The right talent

Regardless if you’re looking for local or offshore talent, you are still to undergo the pains of recruitment.

As for the Virtual Executive Assistant hunt, there are different strategies you can use to find the right talent.

But let me narrow them down into 2:

Do it Yourself
Pretty much self-explanatory and would involve a lot of your time. If you want a hands-on approach to finding the best person for the job, then this might be a route you’d want to take.

You can always post your hiring notice in Upwork, Odesk, etc., and pray that someone good reaches out to you.

Have an Offshore Virtual Service Provider
This helps a lot, especially when you want to make sure that the people you get are already professionally screened. You have a better chance of finding the right talent and personality (including background checks) to support you.

Additional care is also provided to your staff to ensure that the quality of work is monitored, even when you are not around. Security measures are also covered by the company to ensure that there are no concerns with data breaches and confidentiality.

Now, does it really make a lot of difference if you hire offshore? I say YES – and all for the right reasons! In fact, when bigger companies try to get into the virtual EA trend, it just goes to show that there really is more to gain in this option.

As the cost of running a financial services business in Australia increase and ASIC places heavier compliance obligations on businesses, there are very few options to save money while improving customer service.

The most obvious strategy businesses are taking advantage of is using offshore businesses like VA Platinum.

So, are you using overseas administration services as part of your business?

If yes, and you haven’t a clue about how the Australian law works for data privacy, or do not know how it should be implemented in your operations, below, I’ve given a step by step of what you need to know and how you can stay on the right side of the law.

Seriously, this could save you from some serious penalties and possible jail time.

And I don’t mean to scare. Laws are meant to be intimidating, and so we have to be mindful and respectful of them to avoid the backlash of the looming “or else”.

Firstly, let’s do a bit of background research….

What is APP 8 and why does it matter?

The Australian Privacy Principle, or APPs, is a 13-point framework of the Australian Privacy Act of 1988. The Privacy Act was created to protect and regulate how personal information is handled. In its essence, it safeguards the rights of individuals and strengthens community trust in businesses and agencies.

Personal information is defined as…

“Information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.”

Personal information is, but not limited to: an individual’s name, signature, address, telephone number, date of birth, medical records, bank account details, and commentary or opinion about a person.

All APPs are created to guide us with the proper way of handling personal information, for a number of specific scenarios. APP 8 specifically outlines the cross-border disclosure of personal information.

APP 8 particularly details your legal obligations if you are utilising overseas or offshore operation that involves passing around personal information.

Personal information is defined as…

1. If you use Dropbox, Google Drive, OneDrive, or other similar file storage facility that your offshore staff access.
2. Where you provide access to your customer database such as Adviser Logic, Xplan, Midwinter, etc.
3. Where you send a fact find or scope of advice document offshore to prepare advice documents such as a Statement of Advice.

Key Points

You can find the full inclusions of APP 8 through the Office of the Australian Information Commissioner.

For the purpose of simplifying the points under this principle, I’ve outlined them below:

1. Implement Data and Privacy Security Measures in your office

If your business discloses personal information to an overseas recipient, you must take reasonable steps to ensure that the recipient does not breach the APPs in connection with the personal information.

This means that you have to implement an anti-recording policy in the office or use software that effectively keeps people away from accessing personal information outside of work.

2. Acknowledge accountability for Data & Privacy Breach

An Australian entity may still be held accountable for the practices or acts of an overseas recipient which result in a privacy breach even if they have taken reasonable steps.

However, the Office of the Australian Information Commissioner (OAIC) will take into account the reasonable steps followed when resolving the matter.

3.Provide proper disclosure to clients

Proper disclosure must be issued to the individual for them to effectively grant consent.

Following point number 3, I have asked my clients to include a disclosure to clients with regards to using offshore staff through us. I created the following text to put inside their respective Fact Find and Privacy Policy (or in their FSG and SoA):

“Some of the information (including health information) collected by us may be disclosed to employees or contractors of [YOUR COMPANY NAME] outside of Australia. You consent to your information being disclosed to a destination outside Australia for this purpose, including but not limited to Cebu, Philippines.”

For those wanting a smaller disclosure, I encouraged them to use what one of our VA Platinum clients has included in their privacy policy that every client must sign.

“Note: we do utilise some overseas administration.”

Either way, I recommend that when using offshore staff, you must include a suitable disclosure that is easily identifiable in a document that the client signs off on.

4. Make sure that personal data is used strictly for its primary purpose

The Privacy Principle sets out that the business must only disclose personal information for the primary purpose it was collected unless an exception to this principle applies. An Australian entity is only allowed to use or disclose personal information for a secondary purpose (defined as the non-primary purpose) in the following situations:

• where the individual grants consent;
• where the law requires disclosure; or
• where it is “reasonably expected” that the Australian entity would disclose the information for secondary purposes.

In these circumstances, the Australian entity must justify its actions and satisfy the Office of the Australian Information Commissioner (OAIC) that its disclosure was reasonably expected.

In summary, it’s incredibly easy to comply with Australia’s privacy laws when using offshore staff in our overseas outsourcing businesses.

You simply need to disclose to customers that their data may be sent offshore and only used for the purpose intended and have the client sign-off that they grant you permission.

Easy peasy!