Your Right to Privacy
Personal information we collect
As a provider of accounting, bookkeeping, advisory, taxation, wealth creation strategies and business compliance services it may be necessary, and in some cases be a legislative and regulatory requirement, for us to collect and hold detailed personal information. In general, the main types of personal information we collect and hold includes (but is not limited to):
■ Contact details
■ Dates of Birth
■ Employment details and employment history
■ 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
■ Details of your investment preferences and aversion or tolerance to risk (if a wealth advisory client)
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.
How we use your personal information
PLH Accountants acknowledge 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. This may include to:
■ provide you with products and services during the usual course of our business activities;
■ administer our business activities (including invoicing, account management and recruitment);
■ manage, research and develop our products and services;
■ provide you with information about our products and services, invite you to events or distribute articles or publications;
■ communicate with you by a variety of measures including, but not limited to, by telephone, email, SMS or mail; and
■ investigate any complaints. 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 or 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 at law our user databases, together with any
personal information and non-personal information contained in those databases.
How we collect your personal information
PLH Accountants may collect personal information from you in a variety of ways, including when
you interact with us electronically or in person. This includes, but is not limited to, when you
provide feedback, when you provide information about your personal or business affairs, change
your content or email preference(s), respond to surveys and/or promotions, provide financial or
credit card information, or communicate with your accountant.
We may also receive personal information from third parties and where this is the case, we will
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 Privacy
Some of the personal information 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).
Unsolicited personal information
There may be times when we receive personal information that we do not solicit. If this occurs,
we will determine if you have given your consent and the information is necessary for us to
provide our services, or whether the collection is required or authorised by or under an Australian
law or a court/tribunal order. If it is, then the information will be dealt with in accordance with the
Australian Privacy Principles as if the information had been solicited.
If it is determined that you have not consented to the information being disclosed to us and that
there is no requirement at law for us to collect that information, we will destroy or de-identify the
information as soon as practicable, provided it is lawful and reasonable to do so.
Disclosure of personal information
In providing our services we may 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 as mailing houses, specialist consultants, barristers and solicitors,
contractors or temporary employees to handle peak period workloads, information technology
service providers, superannuation fund trustees, insurance providers, fund managers, market
research organisations 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, accountants and other financial institutions.
Where Wealth Advisory services are provided to you, we are required under the Code of Professional Practice of the Financial Planning Association of Australia, to make certain information available for inspection by the Association on request to ensure ongoing compliance with mandatory professional standards. The Corporations Act has also provided the Australian Securities and Investments Commission with the authority to inspect certain personal information that is kept on our files about you. Where such an inspection takes place, this may involve the disclosure of your personal information to representatives of the Australian Securities and Investments Commission. 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 “ATO”), 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, e.g. Tax Office audit, 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
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.
Hosting and International Data Transfers
Depending on the nature of the engagement or circumstances of personal information collection, we may disclose your personal information to entities overseas to fulfil the purpose for which the personal information was collected or related purpose in accordance with the Privacy Act. These may include, but are not limited to Australia, New Zealand, Malaysia, the Philippines and India. CIB Accountants & Advisers has offices and/or facilities in Australia. Our suppliers and contractors are situated in Australia, New Zealand and Malaysia. The hosting facilities for our website are situated in Australia. Data Transfers to each of these countries will be protected by appropriate safeguards, including one or more of the following: the use of standard data protection clauses adopted or approved by
the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from our Privacy Officer (see contact details below). You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. There will be circumstances in which the disclosure of the information is required or authorised by Australian law or a court/tribunal order, the Code of Ethics for Professional Accountants, or DFK ANZ as part of their quality review program or where you have given your direct consent to disclose it.
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), and to the extent applicable the EU GDPR. 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 We will require you to verify your identity and to specify what information you require. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law. If access is denied we will explain the reason why it is denied. We endeavour to respond 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.
Keeping 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.
Website & Cookies
When you visit our websites
Third party sites
Our websites may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that CIB Accountants & Advisers is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.
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.
Complaints about privacy
If you have any complaints about our privacy practices, please feel free to send in details of your complaints to firstname.lastname@example.org. We take complaints very seriously and will respond shortly after receiving written notice of your complaint. If you would like access to your personal information, or have any questions about privacy-related issues, you should contact us directly