This Policy applies to Kennedy Barnden Chartered Accountants & Business Services Pty Ltd (referred to as KBCA’, ‘we’, ‘our’, ‘us’) and extends to and covers all operations and functions of those organisations. We recognise the importance of ensuring the confidentiality and security of your personal information.
This Policy outlines KBCA’s obligations to manage and protect personal information. KBCA is bound by the Australian Privacy Principles (‘APPs’), the Credit Reporting Privacy Code (‘the Code’) and the Privacy Act 1988 (‘Privacy Act’). This Policy also outlines a number of KBCA’s practices, procedures and systems that ensure compliance with the Privacy Act, APPs and the Code.
We may collect and hold the following kinds of personal information about individuals, including:
We generally collect your personal information by the following methods:
The above list is not exhaustive.
KBCA will not collect sensitive information unless the individual has consented or an exemption under the APPs applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
If the personal information we request is not provided by an individual, we may not be able to provide you with the benefit of our services, or meet your needs appropriately.
KBCA does not give individuals the option of dealing with them anonymously, or under a pseudonym. This is because it is impractical, and in some circumstances illegal, for KBCA to deal with individuals who are not identified.
We may receive personal information about you when we have taken no active steps to collect that information. This is known as ‘unsolicited’ personal information. KBCA’s employees are required to notify the Privacy Officer of all unsolicited personal information received by them. We destroy all unsolicited personal information, unless the personal information is relevant to KBCA’s purposes for collecting personal information.
The personal information we may collect and hold includes (but is not limited to) personal information about:
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
We may also collect information about how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We may use third-party Service Providers to monitor and analyse the use of our Service.
Links To Other Sites
We may use and disclose the information we collect about you for the following purposes:
KBCA may use and disclose personal information for the primary purposes for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act.
We use and disclose personal information for the purposes outlined in section 7 above. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or where certain other limited circumstances apply (e.g. if required by law).
We engage other people to perform services for us, which may involve that person handling personal information we hold. In these situations, we prohibit that person from using personal information about you except for the specific purpose for which we supply it. We prohibit that person from using your information for the purposes of direct marketing their products or services.
In relation to sensitive information held by us, wherever possible, KBCA will attempt to de-identify the information. We also undertake to take reasonable steps to delete all personal information about you when it is no longer needed.
We may disclose personal information to:
We may also collect personal information from these organisations and individuals, and will deal with that information in accordance with this Policy.
We may disclose personal information to credit reporting bodies, in order to comply with our obligations under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (AML/CTF obligations). To comply with our AML/CTF obligations, we may disclose your:
to credit reporting bodies, in order to verify whether the personal information matches the identification information held by the credit reporting body. We may, upon request, provide you with an alternative method of verification, however, any alternative verification method must also comply with the AML/CTF legislation.
We may disclose personal information to our cloud service providers such as Microsoft, DropBox, Xero, Intuit, Reckon Hosted, MYOB and BGL Corp that are located outside Australia in some circumstances. These recipients may be located in the following countries:
We will not send personal information to recipients outside of Australia unless:
If you consent to your personal information being disclosed to an overseas recipient, and the recipient breaches the APPs, we will not be accountable for that breach under the Privacy Act, and you will not be able to seek redress under the Privacy Act.
KBCA recognises how important the security of personal information is to clients. We will at all times seek to ensure that the personal information we collect and hold is protected from inference, misuse or loss, and unauthorised access, modification or disclosure. KBCA employees must respect the confidentiality of the personal information we collect.
Personal information is generally held in client files. Information may also be held in a computer database. All paper files are stored in secure areas. Computer-based information is protected through the use of access passwords.
In relation to our computer-based information, we apply the following guidelines:
KBCA performs all employment procedures, including application and termination processes, in a confidential manner. All individual job attributes, such as classification information and salaries, are confidential.
Where we no longer require the personal information for a permitted purpose under the APPs, we will take reasonable steps to destroy it.
KBCA does not use personal information for the purposes of direct marketing, unless:
If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications. We will not use your credit information for the purposes of direct marketing.
In relation to sensitive information, KBCA may only use or disclose sensitive information about an individual for the purpose of direct marketing if you have consented to the use or disclosure of the information for that purpose.
You have the right to request to opt out of direct marketing and we must give effect to the request within a reasonable period of time.
You may also request that KBCA provides them with the source of your information. If such a request is made, KBCA must notify you of the source of the information free of charge within a reasonable period of time.
We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes, unless one of the exemptions in the Privacy Act applies. KBCA endeavours to avoid data-matching, being the comparison of data collected and held for two or more separate purposes in order to identify common features in relation to individuals, as a basis for further investigation or action in relation to those individuals.
KBCA is committed to ensuring that the personal information it collects, uses and discloses is relevant, accurate, complete and up-to-date.
We encourage you to contact us to update any personal information we hold about you. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge you for correcting the information.
Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information that we hold about you by contacting the KBCA Privacy Officer. We will provide access within 30 days of the individual’s request. If we refuse to provide the information, we will provide reasons for the refusal.
We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged for providing access.
This Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment. Changes to this policy are approved by the Directors/Partners.
KBCA has an effective complaints handling process in place to manage privacy risks and issues.
The complaints handling process involves:
You can make a complaint to KBCA about the treatment or handling of your personal information by lodging a complaint with the Privacy Officer.
Third parties will be required to implement policies in relation to the management of an individual’s personal information in accordance with the Privacy Act. These policies include:
KBCA will conduct periodic privacy audits in order to ensure that it is continuing to comply with its obligations under the APPs.
If you have any questions about our privacy procedures, or if wish to make a complaint about how we have dealt with your personal information (including credit information) you may lodge a complaint with us in any of the following ways:
If you are not satisfied with the result of your complaint to KBCA you can also refer your complaint to the Office of the Australian Information Commissioner.
You can contact the Office of the Australian Information Commissioner: