CBSW Pty Ltd (“CBSW”) is committed to protecting the privacy of personal information obtained through its operation as a professional services firm.
What information do we collect?
CBSW collect the information necessary to provide the services you have engaged us to complete on your behalf and to allow us to manage our relationship with you.
The information CBSW generally collect and hold includes client’s name, date of birth, address, e-mail address, phone numbers, banking and investment details, tax file number and other accounting, financial and personal information.
We will not usually seek to collect sensitive information (e.g. data relating to professional memberships, race or ethnic origin, religious beliefs, criminal record, physical or mental health or sexual orientation) from you. If it is necessary for us to collect sensitive information, we will obtain your explicit consent to collect and use such information.
The nature of the services provided by CBSW may limit us from allowing the use of pseudonym. We will advise you accordingly where the use of pseudonym is permissible.
How do we collect the information?
The main purposes for which we collect personal information are:
- to provide our services;
- to maintain contact with clients;
- to keep clients and contacts informed of the services we offer and of current developments;
- to notify clients and contacts of events and new service offers;
- for recruitment and employment purposes;
- for administration and management purposes.
We will only collect the information by lawful and fair means.
CBSW may collect information from you in various ways, including, but not limited to:
- telephone calls;
- hard copy forms;
- contact mailboxes;
- our website.
Generally, we will collect personal information directly from you. Sometimes it may be necessary for us to collect your personal information from a third party or from a publicly available source. We will only collect personal information in that way where you have consented, you would reasonably expect us to collect personal information in that way or if it is necessary for a specific purpose in the performance of our services.
Use of our website
You do not have to provide us with any personal information if you are visitor to our website and you may choose to remain anonymous or to provide us with a pseudonym if you do not wish to reveal your identity. However, you should be aware that, in those circumstances, we will be unable to properly provide services to you or the nature of our services may be limited.
Most browsers are set up to accept cookies, however if you do not wish to receive any cookies, you may be able to change the settings of your browser.
Our website may include links to third party websites. If you access those websites via links on our website, you will be subject to their privacy policies. We do not endorse or accept the privacy policies of third party organisations by providing a link on our website.
How do we deal with unsolicited personal information?
If we obtain personal information that we did not solicit, we will, within a reasonable period after receiving such information, determine whether or not we could have collected such information should we have solicited it. If we determine that we could not have collected such information and the information is not contained in a Commonwealth record, we will, as soon as practicable but only if it is lawful and reasonable to do so, destroy or re-identify the information.
Notification of the collection of personal information
At or before the time or, if that is not practicable, as soon as practicable after we collect your personal information, we will notify you of certain matters as outlined in APP or otherwise ensure you are aware of any such matters. This includes, amongst other matters, notifying you where you may not be aware that we have collected your personal information or making you aware that such collection is required or authorised under an Australian law.
How do we use the information?
We will only use your personal information to provide professional services, respond to your requests or provide you with further information about CBSW. We will only use this information for the purpose for which you provided it to us (primary purpose) and as permitted by law. We will only use or disclose the information for another purpose (secondary purpose) in limited circumstances and in accordance with APPs.
If we believe that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body, we will make a written note of such use or disclosure.
We may use your information (other than sensitive information) to market our services where:
- you have consented to the use or disclosure of the information for that purpose; or
- where if it impracticable to obtain such consent, we have provided you with simple means by which you may easily request not to receive direct marketing communications from us and you have not made such request to us.
We may use or disclose your sensitive information to market our services only if you have explicitly consented to the use or disclosure for that purpose.
At any time, you will have the opportunity to elect not to receive further marketing information from us by emailing [email protected]We will endeavor to process your request within 5 business days. Alternatively, if we have contacted you by email, you may use the unsubscribe function in that email to notify us that you do not wish to receive further marketing information from us by email.
CBSW may store, process or back-up your personal information on computer servers or networks which are located overseas or in ‘the cloud’, including where services are performed by service providers who are located overseas. Where your personal information is provided to overseas entities, we will take all necessary steps to ensure that the security of the information is maintained and that it is used consistent with this policy and our obligations under the Privacy Act.
We will hold your personal information for only as long as is required to fulfil the purposes for which it was collected or as required by law.
How will your information be disclosed?
Staff of CBSW will have access to your personal records for use in the provision of professional services to you.
CBSW may also be required to disclose your personal information to third party organisations, including but not limited to:
- your financial advisors and their service providers;
- other individuals and organisations that represent you;
- professional advisers and experts who are contracted by us to assist in providing services to you;
- organisations authorised by Federal or State legislation;
- The Australian Taxation Office;
- The Australian Securities and Investments Commission;
- organisations that provide secure off-site storage and archiving services.
We will use or disclose government related identifiers (e.g. Tax File Numbers, Medicare Numbers etc) only for the purpose for which you have provided them to us and only in the circumstances outlined in APPs.
The nature of our business activities may occasionally require that personal information be disclosed to overseas recipients in order to provide the services covered under the terms of our engagement or prospective engagement. The location of any overseas recipients of this information will depend upon the nature of the assignment being conducted.
How is your information secured?
CBSW uses a range of procedures to protect your personal information from misuse, interference, loss and from unauthorised access, modification or disclosure. These include but not limited to:
- security procedures associated with physical access to our business premises;
- security procedures within our office;
- security procedures in relation to the client database;
- IT systems designed to ensure personal information is only available to authorised staff;
- IT security procedures including password protection, firewalls, intrusion detection and site monitoring;
- mandatory confidentiality guidelines for all staff within the business;
Accuracy, Access & Correction
Clients of CBSW may access personal information held by the firm, subject to restrictions outlined in APPs. Where restrictions exist on our ability to provide you with access we will advise you of those reasons at the time of your request.
Should you wish to view your personal information, we ask that you contact the member of CBSW staff responsible for your file or CBSW Privacy Officer and request a “Personal Information Access Form”. Upon receipt of the form, we will respond to your request for access to the personal information within a reasonable period.
While we do not charge clients for making a request to access their personal information, you should be aware that we may charge a fee in the following circumstances:
- if significant amount time is required for our staff member to search, locate, retrieve, collate and prepare the material;
- if third-party costs are incurred (e.g. off-site storage facility or archiving service).
Any charges for accessing the information will be advised prior to commencement.
In certain situations, we may not agree to a request to access personal information. If this occurs, we will advise you in writing of the reasons for the refusal and the mechanisms available should you wish to lodge a complaint about the refusal.
We aim to ensure that the information we hold is accurate, up to date, complete and relevant. We will take reasonable steps to correct the information when necessary. This includes correction of information held by third parties provided you have requested us to notify the third party of the correction.
We will respond to your request to correct personal information within a reasonable period after the request is made. We will not charge a fee for the correction.
In certain situations, we may not agree to a request to correct information we hold about you.
If this occurs, we will advise you in writing of the reasons for not agreeing to the correction request and the mechanism available should you wish to lodge a complaint about the refusal.
What do you need to do if you have a complaint?
If you wish to make a complaint about our handling of personal information, we ask that you contact CBSW Privacy Officer first. We will then follow our Internal Dispute Resolution process and will endeavour to respond within 30 calendar days after the request is made. If the matter proves to be more complex, we will advise you of a revised response timeframe in writing.
Any complaint regarding a possible breach of privacy by CBSW should be directed to the Privacy Officer at the following address:
The Privacy Officer
CBSW Pty Ltd
PO Box 1475
West Leederville WA 6901
If your complaint is not handled satisfactorily, you may refer your complaint to:
Australian Information Commissioner
GPO Box 2999
Canberra ACT 2601 Australia
Phone: 1300 363 992 Fax: (02) 9284 9666 Website: www.oaic.gov.au