Charltons Accountants Pty Limited (ABN 16 659 315 581) is committed to protecting your privacy and handling personal and sensitive information in a secure manner.
This policy explains how Charltons Accountants Pty Limited handles personal information and complies with the requirements of the Australian Privacy Act 1988 (Cth) (‘Privacy Act’) and the Australian Privacy Principles set out in that Act.
This policy outlines the obligations Charltons Accountants Pty Limited has in managing the personal information we hold about our clients, potential clients, staff and other individuals. This includes information that can reasonably identify an individual, either directly or indirectly. This policy is not intended to, nor can it, replace the provisions in the Acts themselves.
This policy applies to all personal information collected by us, or submitted to us, whether offline or online, including personal information collected or submitted through our website, applications or through our official social media pages.
Personal information we collect
As a provider of accounting, bookkeeping, advisory and audit services it may be necessary, and in some cases be a legislative and regulatory requirement, for us to collect and hold detailed personal information.
We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us.
In general, the main types of personal information we collect and hold includes (but is not limited to);
- Contact details
- Relationships and family
- Date of birth
- Employment contracts and employment history
- Job titles
- Tax File Numbers
- Details of your financial circumstances, including bank account details, your assets and liabilities (both actual and potential), income, expenditure, insurance cover and superannuation
- Credit information
- Health information (for some types of insurance cover)
In some instances, it may be necessary to collect personal, sensitive and special categories of information from clients that relates to their employees, members, customers, third parties, their spouse and dependants to provide professional services. In those circumstances we rely on clients to only provide us with information that they have handled in accordance with the Privacy Act, including obtaining any necessary consent for Charltons Accountants Pty Limited to collect, use and disclose that information.
Some of the personal information we collect is ‘sensitive information’ as defined by the Privacy Act. Sensitive information includes health information, information about your race, ethnic origin, political opinion, religion, trade union or other professional or trade association membership, sexual preference(s) and criminal record. We will only collect this information as permitted under the Privacy Act.
Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or where certain other limited circumstances apply (e.g. where required by law).
We are required to verify your identity to prevent identity fraud. In most cases, you will simply be asked to show us a primary photographic proof of identity document (e.g., drivers license) in person or via video conferencing. If this is not possible, we will advise you of alternative methods to verify your identity.
We may also be required to verify your identity for the purposes of the anti-money laundering laws. We may request from you such information as we require for these purposes and make searches of appropriate databases.
We do not retain copies or originals of identification documents.
How we use your personal information
Charltons Accountants Pty Limited acknowledges that your personal information is highly confidential and to this end the information collected by us will only be used for the purpose in which it was collected unless you have consented to it being used for another purpose or if the secondary purpose for which the information is being used or disclosed is related to the primary purpose and you would reasonably expect such use or disclosure.
The main purposes for which Charltons Accountants Pty Limited collect, hold and use personal information are;
- To provide you with our professional services
- To respond to an individual’s request
- To maintain contact with clients
- To provide you with information about our products and services, invite you to events or distribute articles or publications
- To communicate with you by a variety of measures including, but not limited to, by telephone, email, SMS or mail
- To investigate any complaints
- General management and reporting purposes such as invoicing, account management and recruitment
- Purposes related to the employment of our personnel and providing internal services to them and
- Other purposes related to our business
You have a right not to provide information that can identify you. If, however, you withhold your personal information, it may not be possible for us to provide you with our products and services, or alternatively, may affect the adequacy or appropriateness of advice for services provided.
If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible by law our user databases, together with any personal information and non-personal information contained in those databases.
How we collect your personal information
Charltons Accountants Pty Limited may collect personal information from you in a variety of ways, including when you interact with us electronically or in person.
We collect most information directly from individuals when we deal with them. The personal information collected may be provided in forms filled out by individuals, face to face meetings, email messages or telephone conversations. If you contact us, we may keep a record of that contact.
We may also receive personal information from third parties and where this is the case, we will protect it as set out in this policy. You have a right to refuse us authorisation to collect information from a third party.
Sometimes you may provide us with someone else’s personal information, e.g. other members of your family group. You must not provide that information to us unless you have their consent to do so. You should also take reasonable steps to inform them of the matters set out in this policy.
Disclosure of personal information
Charltons Accountants Pty Limited does not routinely disclose personal information to other organisations unless;
- Use or disclosure is permitted by this policy
- We believe it is necessary to provide you with a service or product which you have requested
- To protect the rights, property or personal safety of any member of the public
- You give your consent or
- Such disclosure is otherwise required or permitted by law, regulation, rule or professional standard
Charltons Accountants Pty Limited may also share non-personal, non-identifiable and aggregated information for research or promotional purposes. Except as set out in this policy we do not sell or trade personal information with third parties.
If, however, in providing our services we need to disclose personal information to a third party. This will be done to the extent that it is permitted by law and set out in this policy.
Examples of the types of third parties we may disclose personal information to include
- Companies or individuals contracted to assist us in providing services or who perform functions on our behalf (such barristers and solicitors, contractors or temporary employees, information technology service providers, superannuation fund trustees, insurance providers, fund managers, credit managers, debt collecting agencies and other product providers)
- Courts, tribunals and regulatory authorities, as required or authorised by law and in accordance with the Code of Ethics for Professional Accountants
- Auditors or compliance officers, as required by Law or Professional Associations
- Anyone else to whom you consent, such as banks, other accountants and financial institutions
Where you engage us to attend to your tax affairs we will assume (unless you advise otherwise) that you have specifically authorised us to deal directly with the Australian Tax Office, the New Zealand Inland Revenue or other taxation agency in a foreign jurisdiction regarding day to day type matters.
If, in the course of our dealings with these bodies, they request information regarding you that we believe is outside of the scope of our authority, we will request your specific authority before complying with the relevant request.
If we are required by law to disclose information about you or your organisation, we must co-operate fully. However, where it is possible and lawful for us to do so, we will advise you that the information has been disclosed.
Security of your personal information
Charltons Accountants Pty Limited is committed to ensuring that the information you provide to us is stored securely.
We hold personal information electronically and in hard copy form at our own premises. Some or all of this personal information may be available to directors and authorised staff of Charltons Accountants Pty Limited for use in accordance with this policy.
In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
Our employees are required to respect the confidentiality of personal information and the privacy of individuals. As part of our training, all employees are required to read this policy and understand their obligations in regard to personal information.
The transmission and exchange of information made by you is done so at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this policy.
Retention of your personal information
We will retain your personal information only as long as necessary to fulfil the purpose for which it was collected, as required by law and the Australian Privacy Principles, or in accordance with our documentation retention policies.
If you wish to have your personal information deleted, please let us know and we will take reasonable steps to delete it (unless we need to keep it for legal, auditing or internal risk management reasons).
Access to your personal information
You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth).
We will provide access to personal information upon request by an individual except in limited circumstances in which it is permitted for us to withhold this information as set out in the Privacy Act, for example where granting access would infringe another person’s privacy.
If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at email@example.com or call us on (+61) 2 8267 6666.
We will require you to verify your identity and to specify what information you require.
We endeavour to respond quickly to your request for details of personal information we hold, however you should anticipate that it may take some time to process your request as there may be a need to access the information from our archives.
We also endeavour to provide you with details of personal information we hold free of charge, however we reserve the right to charge you a fee for providing you with the information. If we propose to charge a fee, we will advise you in advance.
Keeping your personal information up to date
We endeavour to ensure that the personal information we hold is accurate, complete and up to date. Changes inevitably are required and unfortunately errors do occur from time to time. You should contact us immediately in order to advise us of any changes to the personal information we hold about you.
Privacy on our website
This policy also applies to any personal information we collect via our website Charltons.com.au.
Social media platforms
You may wish to participate in the various social media platforms hosted by us and which we make available to you. These platforms are designed to facilitate and share content. We cannot be held responsible if you publicly share personal information on these sites that is subsequently used, misused or otherwise appropriated by another party/entity.
Please be aware that this policy may be updated as and when required, for example, to take into account new laws, changes to our operations and practices, changes in the business environment and technology. We may modify this policy at any time and all modifications will be effective immediately upon our posting of the modifications on our websites.
Complaints about privacy
If you have concerns about how we are handling your personal information, please contact us at firstname.lastname@example.org or (+61) 2 8267 6666 and we will try to resolve your concerns. We take privacy complaints very seriously and will respond shortly after receiving written notice of your complaint.