1.Personal information about you is collected only when knowingly and voluntarily submitted and when reasonably required by us to perform one or more of our functions or activities.
2. Personal Information is collected by us via the following means: direct requests for information made by us to you either verbally or in writing, online and hard copy application forms completed by you or on your behalf.
3. We may also collect your personal information indirectly through third parties such as credit reporting agencies, your authorised representative, your bank or financial adviser, your employer or government authorities including the Australian Taxation Office. We may also collect your personal information from other publicly available means or through websites (such as ASIC, ABN Lookup or social media sites) who disclose to their users that the user’s personal information is provided to businesses such as ours. We may also collect or have access to personal information obtained by related entities to fulfil the purpose for which the personal information was collected, or a related or ancillary purpose or otherwise in accordance with the Privacy Act. We will do this only where you have consented to or would reasonably expect us to obtain this information.
It is our intention that this Policy will protect your personal information from being dealt with in any way that is inconsistent with applicable privacy laws in Australia including the Australian Privacy Principles (APPs). The types of personal information that we may collect and hold includes:
- your name, address, contact details such as telephone numbers and email address;
- your date of birth and gender;
- your job title;
- information in identification documents (such as your passport or drivers licence);
- government identifiers;
- bank account details, shareholdings and details of investments;
- details of superannuation and insurance arrangements;
- education qualifications, employment history and salary;
- personal information about your spouse and dependants; and
- other information that is necessary in the ordinary course of our business.
5. Where it is reasonable and practical to do so we will only collect personal information about you from you. You have no obligation to provide any information requested by us however if you choose to withhold personal information from us it may prevent us from being able to provide you with the comprehensive and complete accounting and advisory services requested.
6. We will take reasonable steps to ensure that your personal information is accurate, complete and up-to-date as soon as practicable after receiving your notification of any error or inaccuracy.
Provision of Personal Information About Another Person
Use of Information
8. Personal information collected from you is used for the following purposes:
- to provide you with tailored service and advice;
- to manage your account with us;
- to liaise with relevant government authorities on your behalf where we are authorised to do so or where such communications are reasonably expected in the circumstances;
- to liaise with others in our firm to manage or administer aspects of your business and investment affairs;
- to communicate with you regarding other relevant products and services we provide;
- to maintain contact with our clients and other contacts;
- to notify of seminars and other events and provide you with other marketing material;
- for recruitment purposes;
- to conduct surveys;
- for seeking your feedback; and
- for any other business related purposes.
9. Direct marketing
We may also use your personal information for the purpose of marketing our services. If you do not want to receive marketing material from us, you can contact us as detailed below:
- for electronic communications, you can click on the unsubscribe function in the communication;
- for hard copy communications, you can email us, email@example.com or telephone us on (02) 4942 0200.
10. Personal information is held in paper archives, by electronic or computer data base and remotely in cloud based storage systems.
11. We will not disclose your personal information unless you have consented to that disclosure. Your consent may be express or implied. Such disclosure may include to your financial advisers, bankers and their service providers, our merchant and payment organisations.
12. We may also disclose your personal information where it is required or authorised by or under an Australian law or a court/tribunal order or where a permitted general situation exists under the APPs. Where disclosure is necessary for an enforcement related activity of an enforcement agency, we will provide written notification of that disclosure as is required by the APPs.
13. Where you are a member of a partnership, family or other financially related group or where you have provided personal information to us in company of another person (group members) we may mail financial and other documents containing personal information for the group members in one envelope. We may also conduct meetings with group members where personal information of any or all of the group members is discussed. If you wish to retain some information from certain group members then please advise us, otherwise we will assume that all group members are authorised to have access to all personal information of the group.
14. We may engage third parties to provide you with services on our behalf. In that circumstance, we may disclose your personal information to those third parties in order to meet your request for those services. Where the outsourced service requires the disclosure of personal information to an overseas recipient, the overseas recipients will be required to take reasonable steps to ensure that the Australian Privacy Principles are complied with.
15. We may disclose your personal information to recipients that are outside of Australia and we will update this Policy with details of those overseas recipients as required. You should review our Policy regularly to keep informed of any updates.
As part of provision of the services to you we may store your personal information using online accounting software. The personal information that you provide to us may be transferred to the servers of our accounting software providers as a function of transmission across the internet. By providing your personal information you are consenting to that personal information being transferred to and stored on the servers as set out in this Policy. However, as the third parties who host our servers do not control, and are not permitted to access or use your personal information (except for the limited purpose of storing the information), we do not “disclose” personal information to those server hosts, whether or not they are located overseas.
Notwithstanding the above, for the purpose of transparency we advise that the servers of our accounting software providers are currently located in the United States of America (USA), however this location may change without prior notice to you. Your personal information may be routed through, and stored on, those servers. If the location of those servers changes in the future, we will update this Policy.
We will use reasonable endeavours to ensure that our server hosts do not have access to, and use the necessary level of protection to safeguard, your personal information and otherwise comply with the APPs. If you do not want your personal information to be transferred to a server located in the USA or to any other international locations, you should not provide us with your personal information or use our services.
16. We strive to ensure the security, integrity and privacy of personal information collected and held by us, and we review and update our security measures in light of current technologies. Unfortunately, as the internet is not in itself a secure environment we cannot guarantee that our data storage measures are totally secure.
17. However, we will endeavour to take all reasonable steps to protect the personal information we collect from you from misuse, interference, loss and unauthorised access, modification or disclosure.
18. Where the personal information is no longer required for the purpose for which it was collected (or a permitted secondary purpose) we will take reasonable steps to destroy or de-identify the information.
Using Government Identifiers
19. In certain circumstances we may be required to collect government identifiers from or relating to you, such as your tax file number, Medicare number or pension or other benefit number. We will not use or disclose this information unless you have provided your consent to the disclosure or otherwise where we are required or authorised to do so by law.
20. During the course of our business and providing the services to you we may be required to collect sensitive information about you or other individuals. We will at all times comply with the APPs during the course of collecting that sensitive information.
21. We understand the importance of protecting children’s privacy.
22. It is our policy to never knowingly collect or maintain information about anyone under the age of 13, except as part of a specific engagement to provide professional services which necessitates such personal information be collected or for the purposes of ensuring compliance with our auditor independence policies. We will endeavour to ensure that personal information about a child is collected from a parent or guardian.
23. The following clauses 23-28 relate to any employee, candidate, potential employee or applicant seeking employment with us.
24. We may collect personal information from current, future and past employees directly and from third parties who have agreed to provide human resources related services to us or who have third agreed to provide applicants with a professional or personal reference. We may also rely on word of mouth and personal referrals in our recruitment activities. We may collect sensitive information such as information about your health where necessary. We will use this personal information to provide employment related services, professional development and training, remuneration and payroll and injury support. Third parties are engaged to provide some of these services and in doing so are all contractually obliged to comply with the Privacy Act and this Policy.
25. By engaging in any part of a job application process with us you consent to us collecting and using your information in this manner.
26. The kinds of personal information we may collect include your name, address, contact details, employment and academic histories, and the names and contact information of your referees.
Disclosure of Employee Information
27. If you send us an application or a resume for a job, we will use your personal information (including, where necessary, sensitive information such as information relating to your health) to assess your application and may disclose this information to recruitment agencies and other third party service providers for purposes such as aptitude, psychological and medical testing. Where candidates are located overseas, we may use overseas service providers for purposes such as aptitude, psychological and medical testing in the jurisdictions in which the candidates are located or in the jurisdictions in which the recruitment agency is located, or both depending on the nature of the recruitment.
28. We will use information you provide regarding your prior employment history to seek further information about you from referees.
IP Addresses and other Websites
29. If information is gathered by our website/portal or online database, our web servers may gather your IP address to assist with the diagnosis of problems or support issues with our services. This information is gathered in aggregate only and cannot be traced to an individual user.
Cookies and Applets
Access to Information
32. Depending on which services you are attempting to access, you may be able interact with us anonymously or using a pseudonym. However, this will mean that there we may not be able to provide you with certain services.
33. We will endeavour to take all reasonable steps to keep information about you accurate and up to date. If, at any time, you discover that information held about you is incorrect, you may contact us to have the information corrected. Further, you may request access to any of your personal information we hold except if the provision of the information is contrary to any applicable privacy law.
34. In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us.
35. If you wish to make a complaint regarding any aspect of the collection, access to, use or storage of personal information by us, please make your complaint in writing to the address below. We will consider your complaint promptly and contact you to seek to resolve the matter. If we have not responded to you within a reasonable time, you are entitled under privacy legislation to make a complaint to the Office of the Australian Information Commissioner.
36. Please direct all requests for access to or correction of personal information or all complaints to: Privacy Officer, firstname.lastname@example.org
How long is it held for?
37. Unless you specify an expiry date, we hold the information at a time of our own discretion.
38. For more information about privacy issues in Australia and protecting your privacy or to make a complaint about our handling of your personal information, visit the Office of the Australian Information Commissioner's web site; http://www.oaic.gov.au/.