1. Purpose of the policy
JM SARICH & CO is committed to protecting the privacy of personal information obtained through its operations as a professional services firm. JM SARICH & CO is bound by the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs) and any relevant privacy code registered under the Privacy Act.
2. Policy Statement
The Australian Privacy Principles apply to personal information, that is, information or an opinion (whether true or not) relating to an identified individual or which can be used to identify that individual. Please note that information about companies is not personal information. However the principles will apply to an individual who is carrying on a business as a sole trader.
3. The kinds of personal information we collect and hold
JM SARICH & CO collects personal information that is reasonably necessary for, or directly related to, its functions or activities, e.g. audit services, taxation advice and services and similar business activities. As set out below, JM SARICH & CO also collects certain information that is not directly and specifically provided by third parties, such as an IP address, browsing pattern on the site, click stream, and the status of cookies placed on a computer. JM SARICH & CO does not collect any personal information other than information reasonably necessary for, or directly relating to, the primary purpose for which JM SARICH & CO has been engaged or may be engaged, or its other functions and activities.
4. How we collect personal information
JM SARICH & CO 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).
By way of 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 (for example, their spouse, de-facto partner or their children) where we are satisfied that the associate would not object to the provision of that information to us in order for JM SARICH & CO to provide services involving that associate.
5. How we use your personal information
JM SARICH & CO 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 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 Our policy is that we do not collect sensitive information about our clients or prospective clients. If any of our clients or prospective clients elects to provide us with any sensitive personal information, we will take all reasonable steps to ensure that the sensitive information is securely protected.
6. 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 JM SARICH & CO 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: Tax File Number Declaration to the Australian Taxation Office;
where JM SARICH & CO is required by law to provide personal information so that JM SARICH & CO complies with court orders, subpoenas or other legislation that requires us to provide personal information (for example, a garnishee order).
In certain circumstances, JM SARICH & CO may also disclose personal information to third party service providers (such as IT service providers) who assist us to administer our business.
We may also provide a client’s or prospective client’s personal information to credit reporting bodies and other credit providers. Should it be necessary for JM SARICH & CO 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.
7. How we store your personal information
JM SARICH & CO 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 JM SARICH & CO 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 de-identify these records.
8. Accuracy of personal information
JM SARICH & CO will take all reasonable steps to make sure that any personal information collected, used or disclosed is accurate, complete and up to date.
If a person believes that the information we hold is inaccurate or out of date, they may contact us and we will update the relevant information accordingly.
9. Access to personal information
Under the Australian Privacy Principles, a person has the right to request access to any personal information that we may hold about them 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 a request, we will provide the person with a written notice that sets out the reasons (unless it would be unreasonable to provide them). Subject to our right to refuse access, JM SARICH & CO will provide the person with a report that lists any personal information that we may hold. 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.
10. Privacy Enquiries
If you wish to make an enquiry about your personal information at JM SARICH & CO, 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 do not hesitate to contact us by phone or email..
If a party has lodged a complaint with JM SARICH & CO and is not satisfied with our response, they may contact the Commonwealth Information Commissioner.