On 12 March 2014, a new, harmonised set of Australian Privacy Principles (APPs) amendments to the Privacy Act 1988 (Cth) came into force. They cover the collection and handling of personal information by Australian government agencies and many businesses in a range of sectors, as well as new credit reporting obligations and provide enhanced Commissioner powers.
We are committed to protecting the privacy of our contacts, customers, suppliers and employees (“you” and when relating to you, “your”) and complying with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act) in respect of the collection, management and disclosure of your personal information.
In this policy we describe how we manage your personal information.
- Information We Collect About You
The kinds of Personal Information that we collect is generally anything that identifies you as an individual and may include:
- contact details such as name, role or position, address, email address, mobile number, landline number, fax number; internet protocol (IP) addresses;
- information relating to your circumstances and affairs relevant to the services we provide to you, for example banking and investment information, including sufficient banking information to facilitate obtaining bank feeds on your accounts for the purpose of providing the services;
- information regarding our communications with you and your attendance at seminars and promotional events held by us;
- if you are a supplier or prospective supplier, information about your business skills, services, products and prices;
- if you are an employee or potential employee, we collect personal information to assist with assessing applications and to maintain the employment records required as an employer.
For enquiries through the web site or by phone or email we require sufficient information to be able to respond to your enquiry and make contact with you.
You may use a pseudonym if you wish for your initial enquiry about our services.
Without your consent we will not collect Sensitive Information – information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record.
This is subject to some exceptions including when:
- collection is required by law;
- collection is essential to the provision of services.
- How we collect personal information
If you ask us to provide you with services, we will request from you information necessary to properly identify you – your full name, address, date of birth – and to verify your identity by sighting photographic identification such as a drivers licence or passport.
If you are a client and do not provide us with name and address information, we cannot provide you the services.
In providing the services we will need to have access to certain financial information that you make available to us in order to provide the services we offer.
If you do not provide us with accurate personal information, we may not be able to provide the services requested or achieve the purpose for which the information has been sought.
The services provided may be limited by the information that you are willing to make available.
We collect personal information by various means including when:
- you contact us with a question or inquiry;
- you attend a seminar or event where we are hosting or presenting;
- you request us to provide services to you;
- you authorise another service provider to provide information to us (e.g. your accountant or financial planner or solicitor)
- we undertake a search or investigation;
- you visit our website.
Where practicable we collect personal information about you directly from you. However, we may have collected information about you from a third party such as a client, a third-party information provider, or a person responding to our questions or inquiries, or someone you have authorised to provide us with information.
- Unsolicited Personal information
We will only retain the information necessary to provide the services to you. Any other information you may provide to us will not be retained if it is not needed to provide the services.
If we later require the information that we have not previously retained for new services you request, we will request the information be provided by you when we require it to provide the new services.
- The purposes for which we collect, hold, use and disclose personal information
We collect, hold, use and hold personal information in order to:
- respond to your enquiries;
- provide services to you;
- employ competent and diligent personnel;
- monitor or improve the use of and satisfaction with our services; and
- let you know about our expertise and services that may be of interest to you.
We disclose personal information:
- in order to carry out the instructions of our clients; and
- subject to our confidentiality obligations, when using services in support of our business operation.
- The parties to whom your personal information is disclosed
Subject to our confidentiality obligations, we may share some relevant personal information with:
- Parties authorised by you such as your accountant, financial planner, solicitor, family members, business contacts;
- parties related to a service we provide to you, government authorities and service providers as reasonably required to provide the services;
- our e-mail marketing provider for the purposes of providing you our newsletter, invitations and updates; and
- third party service providers who assist us with archival, auditing, accounting, legal, business consulting, website or technology services.
We also will disclose your information if required by law to do so or in circumstances permitted by the Privacy Act – for example, where we have reasonable grounds to suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been is being or may be engaged in, in response to a subpoena, discovery request or a court order.
- Disclosure of information outside the jurisdiction of collection
We do not disclose personal information to overseas recipients, unless specifically instructed or authorised by you.
- Opting out of marketing communications
We may, from time to time, send you newsletters, invitations and updates about our services. You can opt out of receiving further such communications by notifying us at firstname.lastname@example.org or by clicking the “unsubscribe” option at the bottom of any marketing e-mail received from us.
We take reasonable physical, technical and administrative safeguards to protect your personal information from misuse, interference, loss, and unauthorised access, modification and disclosure. For example, we maintain our files in secure locations and limit access to personal information to individuals with a need to know.
The My Records Ready VAULT holds your information in a secure data centre located in Australia using AES 256 standard encryption.
My Records Ready VAULT web servers gather your IP address to assist with the diagnosis of problems or support issues with our services. Information is gathered in aggregate only and cannot be traced to an individual user.
If we use Reckon cloud-based software to facilitate providing services to you, see https://www.reckon.com/au/policies/data-security/ for information about the security of the Reckon Data Centres which are located in Australia.
- Access/correction/updating personal information
You can contact us to access, correct or update your personal information. Unless we are subject to confidentiality obligation or some other restriction on giving access to the information and we are permitted to refuse you access under the Privacy Act, we will endeavour to make your information available to you within 30 days. Examples of circumstances where we may refuse to give you access to your personal information include where:
- giving access would be unlawful;
- we reasonably believe that giving you access would pose a serious threat to the life, health or safety of any individual or to public health or public safety;
- giving access would have an unreasonable impact on the privacy of others;
- giving access could prejudice the taking of appropriate action in relation to unlawful activity;
- giving access could reveal evaluative information in a commercially sensitive decision-making process.
If you request to correct your personal information, we will correct, or, if we consider more appropriate, note your request for amendment of the information on your record.
We will not charge you to make a request to access your record but we may charge you to actually provide access depending on the costs associated with obtaining and providing the material.
These actions can usually be taken by contacting your usual representative or making a general request at email@example.com .
- Website Cookies and the use of personal information
We make use of “cookies” technology to improve the functionality of our website. A cookie is a small string of information that a website transfers to your browser for identification purposes.
If you provide personal information via our website (e.g. by completing an online form), cookies may be used to match your web browser to that personal information. This may be done for the following purposes:
- to monitor your usage of, and browsing behaviour on, our website;
- to identify information or services that may be of interest to you (based on your usage of, and browsing behaviour on, our website);
- and related marketing purposes.
Internet browsers typically permit settings to be adjusted to manage or block cookies. However, if you disable the cookies feature, you may not be able to access all the functionality of our website.
- Notification of Changes
- Complaints / Contact us
or by calling 07 3517 0776.
We will endeavour to respond to any complaint within 30 days. If you are not satisfied with our response to your complaint you may seek a review by contacting the Office of the Australian Information Commissioner using the information available