3. Personal or sensitive information we collectWe may collect personal information that you have supplied to us such as your name, age, date of birth, address, and other contact details. We may also collect sensitive information from you with your consent (in specific circumstances). The type of information we may collect depends on your dealings with us and may include:
Name, contact details;
Identification information – e.g. your tax file number, driver’s licence;
Employment information – e.g. current and historical;
Financial information – e.g. bank accounts, shareholdings, loans;
Financial circumstances – e.g. assets and liabilities, credit reporting, income, expenditure, insurance, superannuation; and
Information provided to us via client surveys.
4. Collection & UseWe may collect personal information from you or from third parties by:
Having face-to-face meetings and telephone discussions with you;
Asking you to complete client questionnaires;
You using our website and interacting with our social media sites;
You communicating with us through correspondence;
Conferring with third parties such as financiers or the Australian Taxation Office on your behalf;
Using “cookies” or other similar tracking technologies on our website that track website usage, preferences and personal account information; and
Requesting information from a publicly available source.
Providing you with business advice;
Preparing tax returns and financial accounts; and
Liaising with third parties on your behalf such as financial institutions, government organisations, insurance.
We may disclose your personal information for the following purposes:
- To enable you to access and use our services and in turn provide our services to you;
- To provide you with direct marketing materials that may be of interest to you such as articles or product brochures or correspondence from our business partners;
- For purposes that you consent to such disclosure or for a related purpose where you would reasonably expect such disclosure; and
- Any circumstance otherwise authorised by the APPs and/or the Privacy Act.
We will only use sensitive information for the primary purpose it was obtained for or for a secondary purpose that is directly related to the primary purpose (or where otherwise required by law).
We may disclose your personal and sensitive information to trusted third parties, including the following entities:
- Our representatives, advisers, employees, dealers, agents and related bodies corporate;
- Third party suppliers and service providers such as the providers for the operation of our website or business services;
- The Australian Taxation Office (ATO) to meet ongoing compliance;
- The Australian Securities & Investments Commission (ASIC) on request to meet ongoing compliance, mandatory professional standards and other legal obligations;
- Specific third parties authorised by you to receive information held by us; and
- As required by law or directed by legal decision/process;
- Any industry body, tribunal, court or otherwise connected with any complaint regarding our services.
We take our security obligations seriously and your personal information is regarded as confidential and may be held in both hard copy and/or electronic versions. We will take all reasonable steps to safeguard your information so that it is not misused, lost, modified, accessed by unauthorised persons or disclosed without authorisation.
As responsible data custodians we are familiar with the requirements of the Notifiable Data Breaches scheme and are committed to responding to data breaches in accordance with our obligations under the Privacy Act. We will notify the Office of the Australian Information Commissioner and you if there is unauthorised access to, unauthorised disclosure of, or loss of,personal information held by us and the access, disclosure or loss is likely to result in serious harm to any of the individuals to whom the information relates in accordance with the Privacy Act.
7. Accessing, Updating and Correcting Your Personal and Sensitive Information
You have a right to access your personal information, subject to exceptions allowed by law. If you would like to do so, please provide us with a request in writing to the contact details listed below. Depending upon the complexity of the request, we will endeavour to respond to you within four weeks of receiving your request. We reserve the right to charge a fee for searching for, and providing access to, your information on a per request basis. Where we cannot provide you with access to all of your personal information, we will provide you with reasons why. We may also require your identity to be verified when you send in your request and prior to sending any substantive response.
If at any time you believe that information we hold about you is incomplete, inaccurate, irrelevant, misleading or not up-to-date, please contact us and we will take reasonable steps to correct the information in accordance with the Privacy Act.
8. Complaints and Inquiries
Please make sure to include your name and return contact details with any inquiry.
We will endeavour to respond to your complaint or inquiry within a reasonable period from when it is received.
If you are not satisfied with our response to your complaint or inquiry you can contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
Policy Effective: 20 May 2019