1. PURPOSE OF THE POLICY
Pascoe Partners Group (The ‘Firm’) includes Pascoe Partners Perth Pty Ltd as trustee for The Watson Practice Trust, The Cox Practice Trust, The Hernadi Practice Trust and The Gotsis Practice Trust trading as Pascoe Partners Accountants, Pascoe Partners Custodian Services Pty Ltd and Western Advisory Pty Ltd trading as Western Advisory. The Firm endeavours to take all reasonable steps in order to comply with the Privacy Act 1988 (Cth.) (the ‘Act’), the Australian Privacy Principles (APPs) and any applicable State or Territory privacy laws and to protect the privacy of the personal information that the Firm holds.
2. PERSONAL INFORMATION THAT THE FIRM COLLECTS
The Firm collects and holds personal information pertaining to its clients, prospective clients, prospective employees, employees, referral sources, alumni, contractors and subcontractors.
What is personal information?
“Personal information” means information or an opinion (whether true or not, and whether it is recorded in a material form or not) about an identified individual, or an individual who is reasonably identifiable.
What is sensitive information?
If it is reasonably necessary in the circumstances, the Firm may also collect sensitive information (which is a type of personal information) such as your medical history or medical or health checks.
The collection and holding of personal information
The Firm collects and holds personal information from individuals who communicate with us directly, in person or via telephone, email or through our website (including prospective employees and individuals who are contacting us on behalf of a business that wishes to engage our services or enquire about our services).
You can always choose to deal with us anonymously (or by providing a pseudonym), unless it is impracticable for us to deal with you on that basis.
The Firm may collect personal information directly from an individual who contacts us via phone or email or submits personal information to us via our website or through a written application.
Personal information may also be collected where the Firm is required to do so by law (for example, via education, child protection, work health and safety laws, charitable collections, medical treatment or other legislation in Australia).
Personal information that the Firm collects may include:
When applicable the Firm may ask you for additional information that is not stated above in order to assist us in carrying out our services or to comply with legislative requirements. As an example, the Firm may on occasion require your bank account details, details of directorships and any other investments you may have.
2.1 WHY THE FIRM COLLECTS CLIENT INFORMATION?
The Firm collects, holds, uses and discloses your personal information for the purpose of providing our services, conducting our business and communicating with you.
The main purposes as to why the Firm collect client’s personal information are:
Some examples of the specific purposes for which the Firm may collect, hold, use and disclose your personal information include the following:
3. COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
The Firm collects uses and discloses your personal information in accordance with this policy. Where requested by you, the Firm will provide details of this activity.
At no stage will any information collected in relation to the above be disclosed to any unrelated third party without your prior approval, unless the Firm is legally obliged to do so or should the Firm believe withholding the information may cause you or someone else unreasonable harm to health or wellbeing.
3.1 USE AND DISCLOSURE – GENERAL
As part of the recruitment, client services and marketing processes, the Firm may utilise the services of a third party. Information collected about you will only be used for the purpose of providing our services, conducting our business and communicating with you and will not be disclosed to a third party without your consent, except as provided in this statement or otherwise required by law.
3.2 USE AND DISCLOSURE – MARKETING
The Firm may use and disclose your personal information in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting the Firm marketing team or through any opt-out mechanism contained in a marketing communication to you.
4. PRIVACY ON OUR WEBSITE
You do not have to provide us with any personal information if you visit our website. However, if you remain anonymous or go by a pseudonym as you do not wish to reveal your identity, the Firm may be unable to efficiently respond to a request.
Cookies may be used in some areas of the website to improve on the navigation use by visitors.
If you are concerned about Cookies, most browsers recognise when a cookie is offered and allow you to opt out, if you do this you can still navigate on our website.
5. STORAGE AND DATA SECURITY
All reasonable steps are taken to protect the security of personal information held by the Firm. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy. Where the Firm engages a third party for the explicit storage of data, the third party must comply with the Act. Appropriate de-sensitisation of data is practiced and information is destroyed using secure means.
6. ACCESS ARRANGEMENTS
You are able to access personal information held about you by the Firm in a prompt and confidential manner. The Firm treats all requests for access seriously and your request to access your personal information will not negatively impact your existing obligations or affect any arrangement between you and Firm.
If you are a client of the Firm you will be able to gain access to the information the Firm holds about you by contacting the Manager/Principal/Partner responsible for providing your services.
All requests will be dealt with in a timely manner and the Firm will endeavour to respond within 30 days. If you find that the personal information the Firm holds about you is inaccurate, incomplete or out-of-date, please contact the Firm immediately via the contact details below and the Firm will correct it.
6.1 REQUESTING ACCESS TO YOUR PERSONAL INFORMATION AND COMPLAINTS
The Firm takes reasonable steps to ensure that the personal information the Firm collects, uses or discloses is accurate, complete and up-to-date. However, the Firm relies on the accuracy of personal information as provided to us both directly and indirectly.
If you would like to access the personal information that the Firm holds about you, please let us know by making a request via the contact details set out below. The Firm will respond to your request for access within a reasonable period, usually within 30 days. If you find that the personal information the Firm holds about you is inaccurate, incomplete or out-of-date, please contact the Firm immediately via the contact details below and the Firm will correct it.
Any issues or complaints in relation to the collection, use, disclosure, quality, security of and access to your personal information may be made to the firm directly.
6.2 THE FIRM’S RIGHT TO DENY ACCESS
Your right to access your personal information is not absolute. The Firm may deny access to your personal information if:
Where possible, the Firm will respond to your request within 30 days of a request being received; or where the request is not complicated or does not require access to a large volume, information will be provided as soon as reasonably practical.
7. DATA INTEGRITY
The Firm endeavours to maintain accurate and up to date information about you. From time to time, the Firm will request you to provide an update of your personal information, to aid in meeting its obligations under the APPs.
8. TRANSFER OF PERSONAL INFORMATION OUTSIDE OF AUSTRALIA
In some circumstances, the Firm will, from time to time, be required to transfer your personal information to government and non-government organisations and other third parties. In this instance, the Firm will seek your express written consent prior to the provision of your personal information; and will manage the transfer of your personal information in accordance with this Policy.
The Firm will only provide a transfer of your personal information without your consent if the Firm reasonably believes it is in your best interest to do so, and if the Firm has taken all reasonable steps in its attempts to obtain your consent prior to the transfer of information.
For any further information about this policy, please contact Pascoe Partners on (08) 9322 3400.