BOOTH PARTNERS PRIVACY POLICY
Booth Partners are committed to protecting the privacy of your personal information. This policy explains how we manage the personal information that we collect, use and disclose and how to contact us if you have any further queries about our management of this information.
INTRODUCTION
In the course of our business, there are circumstances where we collect personal information. This privacy policy has been developed to ensure that such information is handled appropriately.
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.
Who does the privacy policy apply to?
This policy applies to any person for whom we currently hold, or may in the future collect, personal information.
What information does the privacy policy apply to?
This policy applies to personal information. In broad terms, ‘personal information’ is information oropinions, true or not, recorded in material form or not and relating to a particular individual who can beidentified. Information is not personal information where the information cannot be linked to an identifiable individual.
HOW DO WE MANAGE THE PERSONAL INFORMATION WE COLLECT?
We manage the personal information we collect in numerous ways, such as by:
- implementing procedures for identifying and managing privacy risks at each stage of the information lifecycle, including collection, use, disclosure, storage, destruction or de-identification;
- implementing security systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure;
- regularly providing staff with training or information bulletins on privacy issues;
- appropriately supervising staff who regularly handle personal information; and
- appointing a privacy officer within the business to monitor privacy compliance.
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.
Due to the nature of our business it is not practicable for us to provide individuals with the option of not identifying themselves by remaining anonymous or using a pseudonym when entering into transactions with us.
WHAT KINDS OF INFORMATION DO WE COLLECT AND HOLD?
Personal information
We may collect and hold personal information about you, which may include:
- sensitive information (see below);
- contact information;
- financial information;
- date and place of birth;
- employment arrangements and history;
- tax returns and tax file numbers;
- directorships, shareholding or other investment details;
- credit information;
- banking details; and
- any other personal information required to perform the accounting, taxation or business advisory service for you.
Sensitive information
‘Sensitive information’ is a subset of personal information that may have serious ramifications for the individual concerned if used inappropriately.
We may collect sensitive information if it is relevant in providing accounting or financial advisory services (such as completing tax returns). The sensitive information we collect and hold about you may include any of the following:
- health information; and
- information regarding family situations;
We will not collect sensitive information without the individual’s consent to whom the information relates unless permitted under the Privacy Act.
Special provisions apply to the collection and handling of tax file numbers. We are lawful tax file number recipients and comply with the binding Privacy Tax File Number Rule 2015 issued under the Privacy Act.
HOW AND WHEN DO WE COLLECT PERSONAL INFORMATION?
Our usual approach to collecting personal information is to collect it directly from you. When we collect personal information directly from you, we will take reasonable steps at or before the time of collection to ensure that you are aware of certain key matters, such as the purposes for which we are collecting the information, the organisations (or types of organisations) to which we would normally disclose information of that kind.
We may also collect personal information in other ways, which may include:
- from government bodies (such as the Australian Taxation Office, the Australian Securities and Investment Commission and Department of Human Services);
- from paid search providers;
- through referrals from individuals or other entities; and
- from third party providers and suppliers.
- personal interaction and via electronic means (including our App/Client Portal)
HOW DO WE HOLD PERSONAL INFORMATION?
Our usual approach to holding personal information includes:
- physically: at our premises (securely); and
- electronically: on secure servers.
We secure the personal information we hold in numerous ways, including:
- securing access to the office premises after hours;
- using secure servers to store personal information;
- using unique usernames, passwords and other protections on systems that can access
personal information; - holding certain sensitive documents securely; and
- using lockable disposal bins for documents that are no longer required to be destroyed.
WHY DO WE COLLECT, HOLD, USE OR DISCLOSE PERSONAL INFORMATION?
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, taxation or business advisory services to you or your business.
In the case of potential employees, the primary purpose of the information that is collected is to assess the individual’s suitability for employment.
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. For example, we may collect and use your personal information to provide you with updates and alerts or information that is relevant to you or your business.
We may disclose personal information to:
- any third party software providers (such as BankLink, Class Super, MYOB, Reckon,
Xero) who you authorise us to use; - authorised government bodies (such as the Australian Taxation Office and the Australian Securities and Investments Commission);
- our external auditors;
- financial institutions, finance brokers, with your consent;
- other service providers or referral partners in order to provide the accounting or financial service to you, or to assist our functions or activities (such as debt collection agencies or legal professionals); and
- our third party technology provider.
Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act.
WILL WE DISCLOSE PERSONAL INFORMATION OUTSIDE AUSTRALIA?
We currently use a number of software packages which utilise information stored in the cloud. If your personal information is transferred outside Australia, we will comply with the requirements of the Privacy Act that relate to trans-border data flows. We are satisfied that our third party service providers are committed to privacy and confidentiality obligations which are at least equal to the Australian Privacy Principles (APPs).
HOW DO WE MANAGE YOUR CREDIT INFORMATION?
What kinds of credit information may we collect?
In the course of providing accounting, taxation or business advisory services to you, we may collect and hold the following kinds of credit information:
- your identification information;
- information about any credit that has been provided to you;
- your repayment history;
- information about your overdue payments;
- if terms and conditions of your credit arrangements are varied;
- if any court proceedings are initiated against you in relation to your credit activities;
- information about any bankruptcy or debt agreements involving you;
- any publicly available information about your credit worthiness; and
- any information about you where you may have fraudulently or otherwise committed a serious credit infringement.
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.
How and when do we collect credit information?
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 or financial service.
Other sources we may collect credit information from include:
- authorised government bodies (such as the Australian Taxation Office and the Australian Securities and Investments Commission);
- banks and other credit providers; and
- your suppliers and creditors.
We do not collect and hold credit information from credit reporting bodies unless it is incidentally collected in providing the accounting, taxation or business advisory service to you.
How do we store and hold the credit information?
We store and hold credit information in the same manner as for personal information in this policy.
Why do we collect the credit information?
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.
This may include disclosing your credit information to any entity listed in the disclosure of personal information section of this policy, if it is necessary to provide you with the accounting or financial service.
We may also collect the credit information:
- to process payments; and
- for other purposes incidental to our services as professional accountants.
Overseas disclosure of the credit information
We will not disclose your credit information to entities without an Australian link unless you expresslyrequest us to.
How can I access my credit information, correct errors or make a complaint?
You can access and correct your credit information, or complain about an interference with your privacy in the same manner as set out in the following section of this policy.
HOW DO YOU MAKE COMPLAINTS AND ACCESS AND CORRECT YOUR PERSONAL
INFORMATION OR CREDIT INFORMATION?
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
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.
We will grant you access to your personal information as soon as possible, subject to the request circumstances. In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.
We may deny access to personal information if:
- the request is unreasonable;
- providing access would have an unreasonable impact on the privacy of another person;
- providing access would pose a serious and imminent threat to the life or health of any
person; - providing access would compromise our professional obligations; or
- there are other legal grounds to deny the request.
We may charge a fee for reasonable administration costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.
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.
Complaints
If you wish to complain about an interference with your privacy, then you must follow the following process:
- 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. - In the unlikely event the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.
Who to contact
A person may make a complaint or request to access or correct personal information about them held by us. Such a request must be made in writing to the following address:
Privacy Officer
Postal Address: PO Box 1055, NOWRA NSW 2541.
Telephone number: (02) 4421 4344
Email address: mail@boothco.com.au
CHANGES TO THE POLICY
We may update, modify or remove this policy at any time without prior notice.
This policy was last updated on 21 February 2019.
