1.2 We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. Our commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles (APPs). The APPs set out the way in which personal information must be treated.
1.4 This policy applies to any person for whom we currently hold, or may in the future collect, personal information.
1.5 This policy applies to personal information. In broad terms, ‘personal information’ is information or opinions relating to a particular individual who can be identified.
1.6 Information is not personal information where the information cannot be linked to an identifiable individual.
2. How do we manage the personal information we collect?
2.1 We manage the personal information we collect in numerous ways, such as by:
(a) implementing procedures for identifying and managing privacy risks at each stage of the information lifecycle, including collection, use, disclosure, storage, destruction or de-identification;
(b) implementing security systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure;
(c) providing staff with training on privacy issues;
(d) appropriately supervising staff who regularly handle personal information;
(e) implementing procedures for identifying and reporting privacy breaches and for receiving and responding to complaints;
(f) appointing a privacy officer within the business to monitor privacy compliance; and
(g) allowing individuals, the option of not identifying themselves, or using a pseudonym, when dealing with us in particular circumstances.
2.2 Subject to our professional obligations, we will take reasonable steps to destroy or permanently de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.
2.3 In limited circumstances, it may be possible for you to use a pseudonym or remain anonymous when dealing with us. If you wish to use a pseudonym or remain anonymous you should notify us when making first enquiries or providing initial instructions. We will use our best endeavours to deal with your request, subject to our professional obligations and ability to perform the service for you without using your name. In most cases, our professional obligations will require you to deal with us using your real name.
2.4 We are also subject to professional obligations that may affect how we deal with personal information.
3. What kinds of information do we collect and hold?
3.1 We may collect and hold personal information about you, which may include:
(a) sensitive information (see below);
(b) contact information;
(c) financial information
(d) date and place of birth;
(e) employment arrangements and history;
(f) tax returns and tax file numbers;
(g) insurance information;
(h) credit information;
(i) banking details; and
(j) any other personal information required to perform the financial, accounting or business service for you.
3.2 Sensitive information’ is a subset of personal information and includes personal information that may have serious ramifications for the individual concerned if used inappropriately.
3.3 We may collect sensitive information if it is relevant in providing accounting or financial services (such as completing tax returns). The sensitive information we collect and hold about you (mainly for tax or estate planning purposes) may include any of the following:
(a) health information;
(b) religious affiliation;
(c) political opinions;
(d) membership of professional or trade associations;
(e) membership of trade unions;
3.4 We will not collect sensitive information without the individual’s consent to whom the information relates unless permitted under the Privacy Act.
4. How and when do we collect personal information?
4.1 Our usual approach to collecting personal information is to collect it directly from you.
4.2 We may also collect personal information in other ways, which may include:
(a) from government bodies (such as the Australian Taxation Office, the Australian Securities and Investment Commission and Centrelink);
(b) from paid search providers;
(c) through referrals from individuals or other entities;
(d) through marketing and business development events; and
(e) from third party providers and suppliers (such as banks, insurance agents, lawyers and financial planners).
5. How do we hold personal information?
5.1 Our usual approach to holding personal information includes:
(i) at our premises (securely); and
(ii) off-site, by third party physical storage providers (securely); and
(b) electronically, on a public cloud.
5.2 We secure the personal information we hold in numerous ways, including:
(a) using security systems to access the premises after hours;
(b) using unique usernames, passwords and other protections on systems that can access personal information;
(c) having access to audit trails of personal information accessed; and
(d) holding certain sensitive documents securely.
6. Why do we collect, hold, use or disclose personal information?
6.1 We take reasonable steps to use and disclose personal information for the primary purpose for which we collect it. The primary purpose for which information is collected varies, depending on the particular service being provided, but is generally to provide accounting, financial or business services for you or your business.
6.2 In the case of potential employees, the primary purpose the information is collected is to assess the individual’s suitability for employment.
6.3 Personal information may also be used or disclosed by us for secondary purposes that are within your reasonable expectations and that are related to the primary purpose of collection.
6.4 For example, we may collect and use your personal information:
(a) to provide you with updates and alerts that are relevant to you or your business; and
(b) to invite you to events.
6.5 We may disclose personal information to:
(a) government and regulatory bodies (such as the Australian Taxation Office, Centrelink, the Australian Securities and Investment Commission and the Queensland Building and Construction Commission);
(b) our external auditors;
(c) other service providers or referral partners in order to provide the accounting, financial or business service for you, or to assist our functions or activities (such as debt collection agencies or law firms).
6.6 Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act.
7. Will we disclose personal information outside Australia?
7.1 In order to provide our services to you in the most efficient manner, we might disclose limited personal information to external service providers.
7.2 We may use software which stores data on overseas servers. For example, we may choose to use Xero, Xero Practice Manager or QuickBooks Online via Intuit which we understand store data on servers in the United States of America, or Microsoft SharePoint which we understand stores information on servers largely based in Hong Kong or Singapore.
7.3 We take all reasonable steps to ensure that these entities are committed to privacy and confidentiality obligations that are at least equal to the Australian Privacy Principles.
8. How do we manage your credit information?
What kinds of credit information may we collect?
8.1 In our capacity as a credit provider, we will only collect your identification information and payments details.
8.2 However, in the course of providing accounting, financial or business services for you, we might collect and hold the following kinds of credit information:
(a) information about any credit that has been provided to you;
(b) your repayment history;
(c) information about your overdue payments;
(d) if terms and conditions of your credit arrangements are varied;
(e) if any court proceedings are initiated against you in relation to your credit activities;
(f) information about any bankruptcy or debt agreements involving you;
(g) any publicly available information about your credit worthiness; and
(h) any information about you where you may have fraudulently or otherwise committed a serious credit infringement.
8.3 We may also collect personal information that may affect your credit worthiness from other credit providers (e.g., banks) that collect that information from credit reporting bodies. The kinds of personal information we collect may include any of those kinds of personal information outlined in section 3.1 of this policy.
How and when do we collect credit information?
8.4 In most cases, we will only collect credit information about you if you disclose it to us and it is relevant in providing you with the accounting, financial or business service.
8.5 Other sources we may collect credit information from include:
(a) government bodies (such as the Australian Taxation Office and the Australian Securities and Investment Commission);
(b) banks and other credit providers;
(c) other individuals and entities via referrals; and
(d) your suppliers and creditors.
8.6 We do not collect and hold credit information from credit reporting bodies unless it is incidentally collected in providing the accounting, financial or business service for you.
How do we store and hold the credit information?
8.7 We store and hold credit information in the same manner as outlined in section 5 of this policy.
Why do we collect the credit information?
8.8 Our usual purpose for collecting, holding, using and disclosing credit information about you is to enable us to provide you with the accounting or financial service.
8.9 We may also collect the credit information:
(a) to process payments;
(b) to assess eligibility for credit; and
(c) for other purposes incidental to our services as professional accountants.
Overseas disclosure of the credit information
8.10 We disclose limited information to service providers located in the Philippines and India; however, this is generally not credit information. Further, some software providers we use may store information in public clouds in overseas data centres in locations such as the United States, Hong Kong and Singapore.
How can I access my credit information, correct errors or make a complaint?
8.11 You can access and correct your credit information, or complain about a breach of your privacy in the same manner as set out in section 9 of this policy.
How do you make complaints and access and correct your personal information or credit information?
9.1 It is important that the information we hold about you is up-to-date. You should contact us if your personal information changes.
Access to information and correcting personal information
9.2 You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.
9.3 We will grant you access to your personal information as soon as possible, subject to the request circumstances.
9.4 In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.
9.5 We may deny access to personal information if:
(a) the request is unreasonable;
(b) providing access would have an unreasonable impact on the privacy of another person;
(c) providing access would pose a serious and imminent threat to the life or health of any person;
(d) providing access would compromise our professional obligations; or
(e) there are other legal grounds to deny the request.
9.6 We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.
9.7 If the personal information we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, where it is appropriate to do so.
9.8 If you wish to complain about an interference with your privacy, then you must follow the following process:
(a) The complaint must be firstly made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint.
(b) In the unlikely event the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.
9.9 A person may make a complaint or request to access or correct personal information about them held by us.
Changes to the policy
10.2 This policy is effective September 2021. If you have any comments on the policy, please contact the Trade Business Accountants Pty Ltd.