1. Purpose of the policy
At Sullivan Dewing, your privacy is important to us. We respect the importance of protecting and maintaining personal information.
Sullivan Dewing is bound by the Privacy Act and the Australian Privacy Principles (APPs).
Please note that if at any time Sullivan Dewing is required by law to release information about you or your organisation, Sullivan Dewing must cooperate fully.
2. The kinds of personal information we collect and hold
Sullivan Dewing will collect information that is reasonably necessary for the primary purpose of providing a professional service to you and for complying with our legal obligations. If this information is considered sensitive, then unless the law provides otherwise, Sullivan Dewing will also require your consent to the collection of this sensitive information. We will only collect sensitive information if it is necessary to provide our services to you.
Sullivan Dewing collects information in several different ways, for example:-
When you engage Sullivan Dewing to provide you with tax, audit, accounting and business planning services;
When you send Sullivan Dewing an e-mail, we collect and retain that e-mail on our internal database and mail server;
Sullivan Dewing will collect personal information in a fair and lawful manner. In most instances, we will collect personal information from you unless it is unreasonable and impracticable to do so.
Information collected might include:
Name and contact details
Date of birth and gender
Bank account details
Employment details and employment history
Details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, investments, insurance cover and superannuation
Documentation used for identification and verification purposes
3. How we collect personal information
Sullivan Dewing only collects personal information that has been directly provided to us by our clients or prospective clients, associates of clients, our suppliers or potential suppliers, our employees or potential employees, or is otherwise available in the public domain where this information will assist us with the provision of services to our current and prospective clients. Information may have been provided verbally or in writing (including by email or through web forms).
Sullivan Dewing may from time to time collect personal information concerning an associate of a client or a prospective client (e.g. a spouse or a child) where it is considered unreasonable or impracticable to seek this same information directly from the associate.
For example, we may at times seek personal information such as a name, address, date of birth and similar personal information directly from a client in relation to their associate. This could be their spouse, de-facto partner or children, where we are satisfied that the associate would not object to the provision of that information to us in order for Sullivan Dewing to provide services involving that associate.
4. How we use your personal information
Sullivan Dewing may at times use and disclose personal information about an individual for the “primary purpose” of collection (i.e. the dominant or fundamental purpose for which that information is collected). As well as providing services to clients, that “primary purpose” includes facilitating our internal business processes, communicating with clients, prospective clients and other external parties, providing ongoing marketing information about our products and services, complying with our legal obligations and dealing with enquiries and complaints.
In certain circumstances, the law may permit or require us to use or disclose personal information for other purposes (for instance where a client would reasonably expect us to and the purpose is related to the purpose of collection).
For tax clients, tax file numbers can be:
disclosed as directed by our clients;
collected by tax agents and accountants;
used only to conduct client’s affairs; and
disclosed only to client and the Australian Tax Office.
5. Disclosure of Personal Information
Personal information is not disclosed to a third party unless the disclosure is necessary to support the delivery of the client services for which Sullivan Dewing has been, or is expected to be, engaged, or is required by law. Examples where personal information may be disclosed to a third party include:
disclosures to our related companies to provide services;
superannuation details to a fund administrator;
Tax File Number Declaration to the Australian Taxation Office;
where Sullivan Dewing is required by law to provide personal information so that Sullivan Dewing complies with court orders, subpoenas or other legislation that requires us to provide personal information (for example, a garnishee order).
In certain circumstances, Sullivan Dewing may also disclose personal information to third party service providers (such as IT service providers) who assist us to administer our business.
Should it be necessary for Sullivan Dewing to forward personal information to third parties outside the firm, we will make every effort to ensure that the confidentiality of the information is protected.
Where Sullivan Dewing has collected the information from you, we may use this information for the purpose of direct marketing.
Sullivan Dewing may use or disclose the personal information we hold about you for the purpose of direct marketing, such as articles that may be of interest to you. If there is a reasonable expectation that your personal information will be used for this purpose and you have not opted out of receiving direct marketing communications from us, or where you have provided your consent.
Sullivan Dewing will not directly market to you using information that is considered sensitive unless you have provided consent.
6. How we store your personal information
Sullivan Dewing will take all reasonable steps to protect against the loss, misuse and/or alteration of the information under its control, including through appropriate physical and electronic security strategies. Only authorised Sullivan Dewing employees and our IT suppliers are provided access to personal information, and these authorised persons are required to treat this information as confidential. We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will destroy or de-identify these records.
Sullivan Dewing will only store data with an external provider if a technical assessment of a service provider’s security protocols are considered to meet or exceed the level of security that Sullivan Dewing could apply if the electronic data were to be stored in Sullivan Dewing’s own in-house systems and where we are satisfied that Sullivan Dewing is able to meet its commitments under Australian Privacy Legislation.
7. Access to personal information
Individuals may at any time request access to personal information that Sullivan Dewing holds about them. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. If Sullivan Dewing were to refuse to give access to the personal information, or in the manner requested, we will provide written notice of the reasons (unless unreasonable to do so) and details, should you wish to complain about the refusal. Generally a refusal will only be in cases where denying such access is permitted under the Australian Privacy Principles or is otherwise lawful.
All requests for access to personal information should be in writing to the Privacy Officer. We will respond to your request within a reasonable period (but not more than 30 days) after the request is made. Sullivan Dewing may charge a fee for supplying personal information.
8. Privacy Enquiries
If you wish to make an enquiry about your personal information at Sullivan Dewing, or make a complaint because you believe that we may have breached the Australian Privacy Principles or a privacy code that applies to us, please email our Privacy Officer at email@example.com
or telephone (02) 9526 1211.
We will respond to each request within a reasonable period (but not more than 30 days).
If you have lodged a complaint with Sullivan Dewing and are not satisfied with our response, you may contact the office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001. Phone 1300 363 992 or firstname.lastname@example.org.