The Government must be careful not to impose onerous conditions on superannuation trustees when it comes to the storage, security and destruction of tax file numbers (TFNs), according to the Association of Superannuation Funds of Australia (ASFA).
In its submission to Information Commissioner's review of the TFN guidelines consultation paper, ASFA has highlighted issues for trustees that arise out of the connection of TFNs with peoples' identities.
"ASFA considers it important that the Information Commissioner acknowledges that it would be unreasonable to require TFN recipients to destroy or de-identify TFN information stored on computer systems, in back-up files or in hard copy documents which have been archived," the submission said.
In particular, ASFA pointed out that it would often be impossible for trustees to determine the point at which information entered into systems or hard copy archives would no longer be required.
"Altering back-up data files would defeat the fundamental business purpose of creating back-up files in the first place," the submission said.
The ASFA submission also took issue with the requirement to store TFN information separately from an individual's other personal information, since the two were intrinsically linked.
"This is particularly the situation with the reporting of superannuation contributions information between employers and superannuation funds, and the superannuation funds and the Australian Taxation Office," the submission said.
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