Privacy Policy – Freedom Advisory

Freedom Advisory is an accounting firm located in the Shoalhaven Region of New South Wales. In this Privacy Policy, “Freedom Advisory”, “we”, “us” and “our” mean the professional services firm of Freedom Advisory NSW Pty Ltd carrying on business under the name of Freedom Advisory and includes all associated entities.

Purpose of the policy

The purpose of this policy is to generally inform people of:

• how and when we collect personal information and personal data;

• how we use and disclose personal information and personal data;

• how we keep personal information and personal data secure, accurate and up-to-date;

• how an individual can access and correct their personal information and personal data; and

• how we will facilitate or resolve a privacy complaint.

Freedom Advisory respects your privacy and is committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (“Privacy Act”) and APES 110 Code of Ethics for Professional Accountants (including Independence Standards).

The kinds of personal information we collect and hold

Freedom Advisory collects personal information for the following purposes: Enquiries from clients; taxation and business advisory services and other similar business activities.

Freedom Advisory also collects personal information that is reasonably necessary for, or directly related to those purposes.

The specific types of personal information Freedom Advisory may collect and hold includes the following:

• Name;

• Company name;

• Residency;

• Date of birth;

• Country of residence;

• Job title and employer;

• Tax File Number;

• Employee record information;

• Contact details such as address, email address;

• Business/mailing address;

• Title;

• Nature of business;

• Bank account and credit or debit card details;

• Advice received from the client or prospective client that may contain additional personal information, such as family relationships and other business-related connections;

• Financial records;

• Online interactions with our website, publications, alerts and social media activity;

How we collect personal information

As much as possible, Freedom Advisory 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).

Freedom Advisory may from time to time collect personal information from alternative sources. Some examples of these alternative collection events are:

• 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;

• when we collect personal information about you from third parties;

• personal information collected from your business card;

• when we collected personal information about you from a referee provided by you on an application made with us;

• when we collect information from you in order to provide you with services, a quote for services or our invoices in relation to services rendered;

• when we collect personal information about you when you register to attend or attend an event; or

• when we collect personal information about you from publicly available sources including but not limited to, court judgments, directorship and bankruptcy searches, Australia Post, White Pages directory, and social media platforms (such as LinkedIn, Facebook, Twitter, Google, Instagram etc.).

Also, our website uses cookies to identify site users and their interests and to track usage of the site. Cookies are small pieces of text stored on a computer that help us to know which browser the operator is using, where they have been on the site and any web sites to which they may link in order to use some of our features. By acceptance of our cookie, the user will be permitted access to certain pages of the site without having to log in each time they visit. A user who does not accept the cookie from the site may not be able to access certain areas of the site.

Unsolicited information

In the event Freedom Advisory collects personal information from you, or a third party, in circumstances where we have not requested or solicited that information (known as unsolicited information), and it is determined by Freedom Advisory (in its absolute discretion) that the personal information is not required, we will destroy the information or ensure that the information is de-identified. 

How we use your personal information

Freedom Advisory 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 abovementioned purposes, 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 collected by tax agents and accountants;

• can be used only to conduct client’s affairs; and

• can be disclosed only to client and the Australian Tax Office.

Sensitive information

Some of the personal information that we collect is ‘sensitive information’ as defined by the Privacy Act. Sensitive information includes health information, information about your race, ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preference(s) and criminal record. We will only collect such 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).

Disclosure of Personal Information

Freedom Advisory will ordinarily make the following disclosures of your personal information where it is necessary to support the delivery of the client services or other related activities:

• third party service providers utilised in connection with any administrative matters;

• service providers (including IT service providers and consultants) who assist Freedom Advisory in providing or marketing our services;

• related entities and related bodies corporate of Freedom Advisory;

• third parties in connection with the sale of any part of Freedom Advisory’s business;

• our contractors and agents;

• superannuation details to a fund administrator;

• Tax File Number Declaration to the Australian Taxation Office;

• where Freedom Advisory is required by law to provide personal information so that Freedom Advisory complies with court orders, subpoenas or other legislation that requires us to provide personal information (for example, a garnishee order).

• your superannuation company; and

• the Australian Taxation Office.

We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:

• when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose;

• if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;

• if we have reason to suspect that unlawful activity has been, or is being, engaged in; or

• if it is required or authorised by law.

Should it be necessary for Freedom Advisory 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.

In the event we propose to disclose such personal information other than for the reasons set out in this policy, we will first notify you or seek your consent prior to such disclosure.

Direct marketing

You give your express and informed consent to us using your personal information set out in Section 3 where that information relates to the provision of services to you or marketing activities to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications)

If you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.

If at any time you do not wish to receive any further Direct Marketing Communication, you may ask us not to send those to you or disclose your information to other organisations for that purpose by using the “unsubscribe” facility in the Direct Marketing Communications. 

How we store your personal information

Once we collect your personal information, we will either hold it securely and store it on infrastructure owned or controlled by us or with a third party service provider who have taken reasonable steps to ensure they comply with the Privacy Act.

Freedom Advisory will take all reasonable steps to protect against the loss, misuse and/or alteration of the information under its control, and that the information it holds is accurate, complete and up to date including through appropriate physical and electronic security strategies.

Only authorised Freedom Advisory personnel are provided access to personal information, and these employees 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 permanently de-identify these records.

Our policy is that all electronic records are only stored within Australia whenever this is commercially feasible. However, on occasion, a limited number of specialist software applications may involve the storage of personal data at an overseas location where a suitable alternative is not available.

Freedom Advisory will only store data with an external provider if a technical assessment of a service provider’s security protocols is considered to meet or exceed the level of security that Freedom Advisory could apply if the electronic data were to be stored in Freedom Advisory’s own in-house systems and where we are satisfied that Freedom Advisory is able to meet its commitments under Australian Privacy Legislation.

Accuracy of personal information

Freedom Advisory will take all reasonable steps to make sure that any personal information collected, used or disclosed is accurate, complete and up to date. As the accuracy of personal information largely depends on the information that you provide to us, we request that you advise us of any errors in or updates require to your personal information. If you believe that the information we hold about you is inaccurate or out of date, they may contact our Privacy Officer (refer Section 10) and we will update the relevant information accordingly.

Access to personal information

Under the Australian Privacy Principles, you have the right to request access to any personal information that we may hold about you and to advise us if the information should be corrected. The Australian Privacy Principles set out the circumstances when we can refuse those requests. If we do refuse your request, we will provide you with a written notice that sets out the reasons (unless it would be unreasonable to provide them to you).

Subject to our right to refuse access, Freedom Advisory will provide you with a report that lists any personal information that we may hold about you.

Our policy is to provide written acknowledgement of our receipt of any request for access to personal information or a request for correction of personal information within 7 days of the request being received. We will then provide a written response within 30 days of our receipt of the request.

Complaints

We take complaints very seriously and will respond shortly after receiving written notice of your complaint. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to the email address below.

Contact Details

Freedom Advisory
Suite 7, 48 Berry Street
Nowra NSW 2541
(02)44 132 452
admin@freedomadvisory.com.au