1. INTRODUCTION

1.1 In the course of our business in Australia, there are circumstances where we collect personal information. This privacy policy has been developed to ensure that such information is handled appropriately.

1.2 We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. Our commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles (APPs). The APPs set out the way in which personal information must be treated.

1.3 This privacy policy also incorporates our policy on managing credit information (see particularly section 8 onwards).

Who does the privacy policy apply to?

1.4 This policy applies to any person for whom we currently hold, or may in the future collect, personal information.

What information does the privacy policy apply to?

1.5 This policy applies to personal information. In broad terms, ‘personal information’ is information or opinions relating to a particular individual who can be identified.

1.6 Information is not personal information where the information cannot be linked to an identifiable individual.

2.HOW DO WE MANAGE THE PERSONAL INFORMATION WE COLLECT?

2.1 We manage the personal information we collect in numerous ways, such as by:

(a) implementing procedures for identifying and managing privacy risks;

(b) implementing security systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure;

(c) regularly providing staff with training on privacy issues;

(d) appropriately supervising staff who regularly handle personal information;

(e) implementing procedures for receiving and responding to complaints;

(f) appointing a privacy officer within the business to monitor privacy compliance.

(g) having access to audit trails of information accessed; and

(h) allowing individuals the option of not identifying themselves, or using a pseudonym, when dealing with us in particular circumstances.

2.2 As with all personal information, we will take reasonable steps to destroy or permanently de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.

2.3 In limited circumstances, it may be possible for you to use a pseudonym or remain anonymous when dealing with us. If you wish to use a pseudonym or remain anonymous you should notify us when making first enquiries or providing initial instructions. We will use our best endeavours to deal with your request, subject to our professional obligations and ability to perform the accounting service to you without using your name. In most cases, our professional obligations will require you to deal with us using your real name.

2.4 We are also subject to professional obligations which may affect how we deal with personal information.

3.WHAT KINDS OF INFORMATION DO WE COLLECT AND HOLD?

Personal information

3.1 We may collect and hold personal information about you, which may include:

(a) sensitive information (see below);

(b) contact information;

(c) financial information;

(d) date and place of birth;

(e) employment history and arrangements;

(f) tax returns and tax file numbers;

(g) insurance history;

(h) family situations;

(i) credit information;

(j) banking details; and

(k) any other personal information required to perform the financial or accounting service for you.

Sensitive information

3.2 ‘Sensitive information’ is a subset of personal information and includes personal information that may have serious ramifications for the individual concerned if used inappropriately.

3.3 The sensitive information we collect and hold about an individual may include any of the following if it is relevant in providing the accounting or financial service to the individual (such as completing tax returns):

(a) health information;

(b) religious affiliation;

(c) political opinions;

(d) membership of professional or trade associations; and

(e) membership of trade unions.

3.4 We will not collect sensitive information without the individual’s consent to whom the information relates unless permitted under the Privacy Act.

4. HOW AND WHEN DO WE COLLECT PERSONAL INFORMATION?

4.1 Our usual approach to collecting personal information is to collect it directly from you.

4.2 We may also collect personal information in other ways, which may include:

(a) through referrals from individuals or other entities;

(b) from third party providers and suppliers;

(c) from paid search providers;

(d) from government agencies (such as the ATO); and

(e) when conducting marketing and business development events.

5.HOW DO WE HOLD PERSONAL INFORMATION?

5.1 Our usual approach to holding personal information includes:

(a) physically:

(i) at our premises (securely); and

(ii) off-site, by third party physical storage providers (securely);

(b) electronically:

(i) on secure online servers;

(ii) on a private cloud;

(iii) by a third party data storage provider; and

(iv) on our website.

5.2 We secure the personal information we hold in numerous ways, including:

(a) using security cards to access areas that contain personal information;

(b) using secure servers to store personal information;

(c) using unique usernames, passwords and other protections on systems that can access personal information;

(d) keeping certain sensitive documents in secure storerooms; and

(e) archiving specific documents when they are no longer being used.

6.WHY DO WE COLLECT, HOLD, USE OR DISCLOSE PERSONAL INFORMATION?

6.1 We take reasonable steps to use and disclose personal information for the primary purpose for which we collect it. The primary purpose for which information is collected varies, depending on the particular service being provided, but is generally to provide accounting or financial services to your or your business.

6.2 In the case of potential employees, the primary purpose the information is collected is to assess the individual’s suitability for employment.

6.3 Personal information may also be used or disclosed by us for secondary purposes which are within your reasonable expectations and which are related to the primary purpose of collection.

6.4 For example, we may collect and use your personal information:

(a) to provide you with updates that are relevant to you or your business; and

(b) to invite you to events.

6.5 We may disclose personal information:

(a) to other service providers or referral partners in order to provide the accounting or financial service to you, or to assist our functions or activities (such as debt collection agencies or law firms);

(b) to other third parties with your consent;

(c) to our external auditors;

(d) to government agencies (such as the ATO); and

(e) to our third party technology providers (such as our data storage providers).

6.6 Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act.

7.WILL WE DISCLOSE PERSONAL INFORMATION OUTSIDE AUSTRALIA?

7.1 We do disclose some limited personal information to former employees located in Asia and the United Kingdom who we engage for limited functions from time to time. Otherwise, we do not usually disclose personal information to overseas recipients.

7.2 We take reasonable steps to ensure that the overseas providers are accessing the information in a secure manner, and in a way that is compliant with the APPs.

8.HOW DO WE MANAGE YOUR CREDIT INFORMATION?

What kinds of credit information may we collect?

8.1 In the course of providing accounting or financial services to you, we may collect and hold the following kinds of credit information:

(a) your identification information;

(b) information about any credit that has been provided to you;

(c) your repayment history;

(d) information about your overdue payments;

(e) if terms and conditions of your credit arrangements are varied;

(f) if any court proceedings are initiated against you in relation to your credit activities;

(g) information about any bankruptcy or debt agreements involving you;

(h) any publicly available information about your credit worthiness; and

(i) any information about you where you may have fraudulently or otherwise committed a serious credit infringement.

8.2 In some circumstances, we may collect credit information and personal information from credit reporting bodies (e.g. Veda). The kinds of information we collect may include any of those kinds of information mentioned above in sections 3.1and 8.1.

8.3 We may also collect personal information from other credit providers (e.g. banks) that collect information, which may affect your credit worthiness, from credit reporting bodies. The kinds ofpersonal information we collect may include any of those kinds of information mentionedabove in section3.1.

How and when do we collect credit information?

8.4 In most cases, we will only collect credit information about you if you disclose it to us and it is relevant in providing you with the accounting or financial service.

8.5 In limited circumstances, we may collect credit information from credit reporting bodies.

8.6 Other sources we may collect the credit information from include:

(a) banks and other credit providers;

(b) other individuals and entities via referrals; and

(c) your suppliers and creditors.

How do we store and hold the credit information?

8.7 We store and hold credit information in the same manner as outlined in section 3 of this policy.

Why do we collect the credit information?

8.8 Our usual purpose for collecting, holding, using and disclosing credit information about you is to enable us to provide you with the accounting or financial service.

8.9 We may also collect the credit information:

(a) to process payments;

(b) to assess eligibility for credit; and

(c) for other purposes incidental to our services as professional accountants.

Overseas disclosure of the credit information

8.10 We may disclose some limited credit information to former employees located in Japan and China, if it is necessary for them to have the information to provide the service to us.

8.11 Otherwise, we will not disclose your credit information to entities without an Australian link unless you expressly request us to.

How can I access my credit information, correct errors or make a complaint?

8.12 You can access and correct your credit information, or complain about a breach of your privacy in the same manner as set out in section 9 of this policy.

9.HOW DO YOU MAKE COMPLAINTS AND ACCESS AND CORRECT YOUR PERSONAL INFORMATION OR CREDIT INFORMATION?

9.1 It is importantthat the information we hold about you is up-to-date. You should contact us if your personal information changes.

Access to information and correcting personal information

9.1 You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.

9.2 We will grant you access to your personal information as soon as possible, subject to the request circumstances.

9.3 In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.

9.4 We may deny access to personal information if:

(a) the request is unreasonable;

(b) providing access would have an unreasonable impact on the privacy of another person;

(c) providing access would pose a serious and imminent threat to the life or health of any person;

(d) providing access would compromise our professional obligations; or

(e) there are other legal grounds to deny the request.

9.5 We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.

9.6 If the personal information that we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, where it is appropriate to do so.

Complaints

9.7 If you wish to complain about an alleged privacy breach, they you must follow the following process:

(a) The complaint must be firstly made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint.

(b) In the unlikely event the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.

Who to contact

9.8 A person may make a complaint or request to access or correct personal information about them held by us. We will take reasonable steps to ensure the personal information we hold is accurate and complete. Such a request must be made in writing to the following address or contact officer:

Contact  Anita Cohen (Privacy Officer)

Postal Address  GPO Box 7066, Sydney NSW 2001

Telephone number  (02) 9232 5111

Email address  info@hillrogers.com.au

10.Changes to the policy

10.1 We may update, modify or remove this policy at any time without prior notice. Any changes to the privacy policy will be published on our website.

10.2 This policy was last updated in December 2016. If you have any comments on the policy, please contact the privacy officer with the contact details in section 9 of this policy.