1. About this policy
WGC Business Advisors Pty Ltd (ABN 77 006 689 523) (“we”, “us”) is bound by the Australian Privacy Principles (“APPs”) under the Privacy Act 1988 (Cth) (as amended from time to time).
2. The kinds of personal information we collect and hold
2.1 “Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
2.2 We collect and hold kinds of personal information that are reasonably necessary for, or directly relate to, us doing business with you. The types of personal information that we collect about you depends on the nature of our relationship with you, and may include your name, contact details (including address, telephone number and email address), date of birth, gender, occupation and employment details, tax file number, ABN, ACN and/or ARBN, information about your businesses, and information about your assets and liabilities.
2.3 Personal information that we collect may also include “sensitive information”. Sensitive information includes personal information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, as well as health information about an individual.
3. Why we collect, hold, use and disclose personal information
3.1 We collect, hold, use and disclose personal information about you when it is reasonably necessary for our business functions and activities. These include:
(a) marketing and selling our services;
(b) communicating with you, including providing you with information (including by way of newsletter) about our business, our services, and relevant news and events that we think may be of interest to you;
(c) assessing and processing any enquiries and requests that you make (including employment enquiries and requests, and requests for services);
(d) providing you with services that you request or engage us to provide;
(e) administering and managing our relationship with you;
(f) providing you with invoices and reminder notices;
(g) undertaking research for the purpose of:
(i) understanding the needs of our clients and how best to market to them; and
(ii) improving our services, and creating new services;
(h) personalising and customising your experiences with our website; and
(i) resolving any complaints that you may have about us or our services.
3.2 If we collect government identifiers, such as your tax file number, we will not use or disclose this information other than to the extent reasonably necessary to verify your identity, as required or authorised by law, or as otherwise permitted by the APPs.
3.5 We never sell, rent or trade your personal information.
4. How we collect personal information
4.1 We collect personal information that is communicated to us in writing or orally, including by way of letters, emails, through forms, and during meetings and phone conversations. This personal information may be communicated to us when you make an enquiry about our services (including via our website), sign up to receive information from us, seek advice from us, enter a competition, participate in a survey, attend an event provided by us, or apply for employment with us.
4.2 We will only collect sensitive information about you with your consent (unless an exception applies under the APPs).
4.3 We will usually only collect personal information about you from you, however in some situations we may collect personal information about you from a third party (such as the Australian Taxation Office, or a financial institution, financial planner or solicitor). We will only collect personal information about you from a third party if it is unreasonable or impracticable for us to collect this information directly from you, or we are otherwise permitted, required or authorised by law to collect this information from the third party.
4.4 If you provide personal information to us about another person, we rely on you to make them aware (prior to, or as soon as reasonable practicable after, you provide this information to us) that you will provide or have provided their personal information to us, the types of third parties that we may provide it to, the relevant purposes we and any of the third parties will use it for, and how they can access it. If you have not or will not do this, you must tell us before you provide us with the relevant personal information.
4.5 In most circumstances it will be necessary for us to identify you in order for us to do business with you, however, where it is lawful and practicable to do so, you have the option of dealing with us anonymously or by using a pseudonym.
5. Who we may disclose your personal information to
5.1 We may disclose your personal information to our contractors, consultants and agents (including business partners, advertising partners, mailing and printing houses, IT providers and other service providers) who assist us in undertaking our business functions and activities, including running our website. In such cases we have taken steps to ensure that any third party access to personal information complies with the APPs.
5.2 We will also disclose your personal information where we are required or authorised by law to do so.
6. How we hold personal information
6.1 We hold personal information by recording and storing it in a variety of forms, including in hardcopy and electronic files and databases.
6.2 We take reasonable steps to ensure that the personal information we hold is protected from misuse, interference, loss and unauthorised access, modification or disclosure.
6.3 If we hold personal information about you that we no longer need for any purposes for which it may be used or disclosed under the APPs, we will take reasonable steps to destroy that information or to ensure that it is de-identified.
7. How you may access and seek correction of your personal information
7.1 If we hold personal information about you, you have the right to request access to that personal information, and to request its correction if you think that it is inaccurate, out-of-date or incomplete. Such request may be made by contacting us in writing in accordance with clause 11.
7.2 We will respond to your request for access or correction to your personal information within a reasonable period after the request is received (and we will endeavour to respond within 30 days after the request is received).
7.3 To the extent reasonable and practicable, we will provide you with access to your personal information in the manner requested by you.
7.4 Although we will generally grant you access to your personal information upon your request, in certain situations we may legally refuse to grant you access.
7.5 If we refuse to grant you access to your personal information or refuse to give you access to your personal information in the manner in which you request, we will provide you a written notice that sets out the reasons for our refusal (provided that it is not unreasonable in the circumstances to set out those reasons), and the complaint process that you may use if you disagree with our refusal.
7.6 If we consider it appropriate, we may charge you for giving you access to personal information that we hold about you (provided that the charge is not excessive).
8. Correction of your personal information
8.1 We take reasonable steps to ensure that the personal information we hold is accurate, up to date and complete (having regard to the purpose for which that information is held). To assist us to do this we rely on you to provide us with accurate, up-to-date and complete information in the first instance, and for you to notify us if you believe that any personal information that we hold about you is inaccurate, out-of-date or incomplete.
8.2 If we refuse your request to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (provided that it is not unreasonable in the circumstances to set out those reasons), the complaint process that you may use if you disagree with our refusal, and the fact that you have the right to request that we associate a statement with the personal information that you have requested be corrected stating that you believe that that personal information is inaccurate, out of date, incomplete, irrelevant or misleading (as the case may be).
9. How you may complain about a breach of the APPs and how we will deal with such a complaint
9.2 If you make such a complaint we will investigate your complaint, and endeavour to respond to your complaint (and notify you of the outcome of our investigation) within 30 days of us receiving the complaint.
10. Contacting us