Privacy Policy

1. Commitment to Privacy

Booth Partners are committed to protecting the privacy of your personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the Privacy (Tax File Number) Rule 2015.

We understand the sensitive nature of financial and personal data and take our responsibilities seriously.

2. What Personal Information We Collect

We may collect the following types of information when providing accounting, taxation, and advisory services:

• Identity details (name, date of birth, gender, occupation, contact information).
• Financial details (bank account, superannuation, shareholdings, investments, assets, liabilities).
• Tax file numbers (TFNs), ABNs, ACNs, and other government identifiers.
• Employment, payroll, and remuneration information.
• Business and company records.
• Sensitive information (health information, family circumstances, where relevant to our services).
• Credit information (see section 7 below).
• Any other personal information necessary to provide our services.

For employment purposes, we may also collect information from job applicants to assess suitability for employment.

3. How We Collect Personal Information

We may collect your information:

• Directly from you (via meetings, forms, phone calls, emails, our website, or client portals).
• From third parties with your consent (e.g., ATO, ASIC, banks, financial advisers, auditors, insurers, legal advisers).
• From referrals, paid search providers, and business partners.
• From publicly available sources (e.g., ASIC registers, ABN Lookup).

When we collect information directly, we will take reasonable steps to ensure you are aware of why it is being collected and how it will be used.

4. Why We Collect and Use Your Information

We collect, use, and store your information to:

• Provide accounting, taxation, business advisory, and audit services.
• Comply with legal obligations (e.g., ATO, ASIC, AML/CTF laws).
• Manage our business operations, including administration, billing, and client communication.
• Assess the suitability of job applicants for employment.
• Improve our services and maintain professional standards.

We will only use your information for the purpose it was collected, unless permitted by law.

5. Disclosure of Personal Information

We may disclose your information to:

• Government agencies (ATO, ASIC, State Revenue Offices).
• External auditors, legal advisers, insurers, and financial institutions.
• Software providers and IT service providers (including cloud accounting platforms).
• Other professional advisers, with your consent.
• Referral partners and service providers assisting us with our services.

We will only disclose personal information to third parties where permitted by the Privacy Act, and we ensure confidentiality and data protection obligations are in place.

6. Use of Cloud Services and Cross-Border Disclosure

We use reputable third-party service providers to store, manage, and process information, including cloud-based accounting, document management, and communication systems. Examples include Xero, FYI Docs, Microsoft 365, and other accounting software providers.

These providers may store or process information in data centres located in Australia or overseas (including, but not limited to, New Zealand, the United States, Singapore, and the Philippines).

We may also use offshore administrative and accounting support providers, including TOA Global in the Philippines, to assist with client service and administration.

Where your personal information is disclosed overseas, we take strict and practical steps to protect it, including:

• Due diligence: assessing offshore service providers’ privacy, security, and governance practices before engagement.
• Contractual protections: requiring written agreements that bind offshore providers to handle your information in accordance with the Australian Privacy Principles and our confidentiality requirements.
• Data security measures: ensuring the use of secure networks, encryption of data in transit and at rest, access logging, and user authentication controls.
• Access limitations: restricting offshore personnel to the minimum information required to perform their role.
• Training and oversight: requiring offshore staff to undertake confidentiality and privacy training, and monitoring compliance.
• Audit and monitoring: conducting regular reviews of offshore provider compliance and data security controls.

We will not disclose personal information overseas unless we are satisfied that the recipient is subject to privacy and confidentiality obligations that are substantially similar to those under Australian law.

By engaging our services, you consent to this use of cloud services and overseas disclosure.

7. Credit Information

In the course of providing services, we may collect and hold credit information about you, including:

• Identification details.
• Information about credit provided to you and your repayment history.
• Overdue payments, variations to credit arrangements, or court proceedings.
• Information about bankruptcies or debt agreements.
• Publicly available information about your credit worthiness.
• Information from other credit providers (e.g., banks, suppliers).

We collect credit information only where relevant to our services (e.g., processing payments, assessing financial circumstances).

We do not collect credit information from credit reporting bodies unless it is incidentally provided in the course of delivering our services.

Credit information is stored securely in the same way as personal information and will not be disclosed overseas unless you expressly request it.

8. Data Security

We take reasonable steps to safeguard your personal information, including:

• Secure electronic systems (password protection, encryption, firewalls).
• Secure document management systems.
• Secure premises, lockable disposal bins, and controlled access.
• Limited staff access on a “need to know” basis.
• Regular staff training in confidentiality and data handling.

9. Access and Correction

You may request access to the personal information we hold about you, and request corrections if it is inaccurate, out of date, or incomplete.

Access may be refused where:

• The request is unreasonable or impractical.
• Providing access would impact the privacy of others.
• Access poses a serious threat to health or safety.
• Access would compromise our professional obligations.
• Legal grounds prevent disclosure.

We may require proof of identity and may charge a reasonable fee for administration costs, disclosed in advance.

10. Complaints

If you believe we have breached your privacy or have concerns about how your personal information is being handled, please contact our Privacy Officer in the first instance:

Privacy Officer
Postal Address: PO Box 1055, Nowra NSW 2541
Telephone number: (02) 4421 4344
Email address: mail@boothco.com.au

We will investigate your complaint and provide a written response within a reasonable time.

If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC):
www.oaic.gov.au | 1300 363 992

11. Retention of Information

We are required by law to retain certain records (e.g., tax and accounting records) for prescribed periods, even after you cease being a client. When no longer required, we will securely destroy or de-identify personal information.

12. Changes to this Policy

We may update, modify, or replace this policy from time to time to reflect changes in the law, technology, or our business practices. The latest version will always be available on our website or on request.

13. Contact Us

For questions, requests, or complaints about this Privacy Policy, please contact:

Booth Partners
Postal Address: PO Box 1055, Nowra NSW 2541
Telephone number: (02) 4421 4344
Email address: mail@boothco.com.au