Privacy Policy
 

1. Purpose of this Policy

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Accord Accountants & Advisors Pty Ltd (Accord, we, us or our) is committed to protecting the privacy and confidentiality of personal information obtained through our operations as a professional accounting and advisory firm.

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We handle personal information in accordance with applicable privacy, taxation, professional and regulatory obligations. Where the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) apply to our activities, we comply with those requirements.

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The purpose of this Policy is to explain:

• the kinds of personal information we collect and hold;

• how we collect personal information;

• how we use and disclose personal information;

• how we store and protect personal information;

• how you may access or correct personal information we hold about you; and

• how you may make a privacy enquiry or complaint.

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2. Personal information

 

Personal information generally means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

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Information solely about a company, trust or other entity will not generally constitute personal information. However, information concerning individuals associated with those entities may constitute personal information.

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The types of personal information we collect and hold will depend on the nature of our relationship with you and the services we provide.

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3. The kinds of personal information we collect and hold

 

Personal information we may collect or hold includes:

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• name;

• residential, postal and business addresses;

• telephone number and email address;

• date of birth;

• country of residence and residency information;

• occupation, employer and job title;

• Tax File Number and Australian Business Number;

• identification information and documents;

• bank account details;

• financial and taxation information;

• accounting records;

• income and expenditure information;

• details of assets and liabilities;

• property and investment information;

• superannuation information;

• employment and payroll information;

• details of companies, trusts, partnerships and other entities with which you are associated;

• information concerning directors, shareholders, trustees, beneficiaries and related parties;

• family and relationship information where relevant to the services we provide;

• business interests and ownership structures;

• correspondence, instructions and other communications;

• information provided to us in connection with our professional services;

• information obtained through identity verification, client due diligence or regulatory searches;

• professional qualifications and memberships;

• information relating to prospective or existing employees or service providers; and

• other information reasonably necessary for our professional services or business activities.

Sensitive information

Sensitive information may include information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, professional or trade association membership, trade union membership, health information, criminal record and certain other information recognised as sensitive under applicable privacy legislation.

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We do not ordinarily seek to collect sensitive information unless it is reasonably necessary for the services we provide or for a legal, professional, employment or regulatory purpose.

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Where sensitive information is held, we take reasonable steps to protect its confidentiality.

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4. How we collect personal information

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Where practical, we collect personal information directly from you.

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Information may be provided to us verbally, electronically or in writing, including through:

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• meetings and telephone conversations;

• email and other correspondence;

• client onboarding;

• proposals and engagement documentation;

• forms, questionnaires and information requests;

• client portals;

• accounting and taxation systems;

• documents provided to us; and

• other communications in connection with the services we provide.

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We may also collect personal information from third parties where reasonably necessary or appropriate.

These may include:

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• spouses and family members;

• associated businesses or entities;

• directors, shareholders, trustees and beneficiaries;

• employers;

• previous accountants or advisers;

• lawyers;

• financial advisers;

• finance brokers;

• financial institutions;

• superannuation funds;

• auditors;

• government agencies;

• other professional service providers;

• publicly available registers and databases; and

• publicly available online sources.

 

For example, in providing accounting and taxation services to a family or business group, we may receive information concerning individuals associated with that group even though those individuals did not provide the information directly to us.

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5. Information collected through our website

 

When you use our website, certain information may be collected automatically depending on the technology being used.

 

This may include information such as:

• IP address;

• browser and device information;

• pages viewed;

• date and time of access;

• referring websites; and

• information collected through cookies or similar technologies.

 

Cookies may be used to support website functionality and help us understand how our website is used.

 

You may be able to restrict or disable cookies through your browser settings. Doing so may affect the functionality of some parts of the website.

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6. Unsolicited personal information

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We may occasionally receive personal information that we have not requested.

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Where unsolicited personal information is not reasonably necessary for our professional services, business activities or legal obligations, we may securely destroy or de-identify it where appropriate and permitted by law.

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Where the information is relevant to an existing or prospective engagement, employment matter, regulatory obligation, complaint or other legitimate purpose, we may retain it in accordance with this Policy.

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7. How we use personal information

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We generally use personal information for the purpose for which it was collected or for related purposes reasonably connected with our professional services or business activities.

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This may include:

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• providing accounting and taxation services;

• preparing financial statements and taxation documents;

• preparing and lodging income tax returns and business activity statements;

• providing taxation advice and tax planning;

• providing business, structuring and related advisory services;

• providing SMSF administration services;

• establishing and administering companies, trusts and other structures;

• providing corporate secretarial services;

• communicating with clients and associated parties;

• responding to enquiries;

• onboarding prospective clients;

• verifying identity;

• assessing whether we can accept or continue a professional engagement;

• meeting client due diligence and regulatory requirements;

• maintaining client and engagement records;

• issuing invoices and managing accounts;

• managing professional and legal obligations;

• managing complaints and disputes;

• managing professional indemnity and risk matters;

• managing our employees and business operations; and

• providing information about our services where appropriate.

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We may also use personal information for another purpose where you have consented, where you would reasonably expect us to do so, or where the use is otherwise permitted or required by law.

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8. Tax File Numbers

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As a registered tax agent and accounting practice, we may collect and use Tax File Numbers where authorised and reasonably necessary in connection with taxation, superannuation and related professional services.

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Tax File Numbers are treated as confidential information and are only used or disclosed where permitted by law.

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9. Disclosure of personal information

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We may disclose personal information where reasonably necessary to provide our professional services or operate our business.

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Depending on the circumstances, recipients may include:

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• the Australian Taxation Office;

• the Tax Practitioners Board;

• the Australian Securities and Investments Commission;

• Australian Business Registry Services;

• AUSTRAC where applicable;

• other government agencies and regulators;

• financial institutions;

• superannuation funds;

• auditors;

• lawyers;

• financial advisers;

• finance brokers;

• other accountants and professional advisers;

• professional indemnity insurers and brokers;

• information technology, software and cloud service providers;

• identity verification providers;

• authorised service providers and personnel;

• contractors and agents where appropriate; and

• other parties authorised by you.

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We may also disclose personal information where:

• required or authorised by law;

• required by a court order, subpoena or regulatory notice;

• necessary to meet a professional or regulatory obligation;

• necessary in connection with a professional indemnity or legal matter;

• reasonably necessary to prevent or address unlawful activity or serious misconduct; or

• you have otherwise consented to the disclosure.

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Where personal information is disclosed to another party, we seek to limit the information provided to that which is reasonably necessary for the relevant purpose.

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10. Overseas access and disclosure

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Our professional services and technology arrangements may involve personal information being accessed, processed or supported from locations outside Australia.

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Personal information may be accessed or processed by authorised service providers and personnel located outside Australia, including in the Philippines, where reasonably necessary to support the provision of our services.

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We also use cloud-based software, technology and infrastructure providers whose systems, support operations, data centres or backup arrangements may be located outside Australia.

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The location in which information is stored or processed may vary depending on the service provider and the technology being used.

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We take reasonable steps to use reputable service providers and to maintain appropriate confidentiality and information-security arrangements.

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11. Direct marketing

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We may use your contact details to provide you with information about:

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• our services;

• accounting and taxation updates;

• professional information;

• events;

• Firm news; and

• other information we reasonably believe may be relevant to you.

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Communications may be made by email, telephone, SMS or other appropriate means.

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You may ask us to stop sending marketing communications at any time by using an unsubscribe facility contained in the communication or by contacting us directly.

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We may continue to send communications that are necessary in connection with an existing professional relationship.

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12. How we store and protect personal information

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Personal information may be held electronically or, where appropriate, in physical form.

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We primarily use cloud-based systems and electronic document-management systems to store and manage information.

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We take reasonable steps to protect personal information from:

• loss;

• misuse;

• interference;

• unauthorised access;

• unauthorised modification;

• unauthorised disclosure; and

• other inappropriate use.

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Our security measures include appropriate electronic, administrative and organisational safeguards.

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Access to personal information is restricted to authorised persons who require that information for legitimate business or professional purposes.

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We may be required to retain records for extended periods due to taxation, professional, legal, regulatory or other record-keeping obligations.

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Where personal information is no longer reasonably required and we are not required to retain it, we may securely destroy or de-identify it.

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13. Accuracy of personal information

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We take reasonable steps to ensure that personal information we collect, use and disclose is accurate, complete and current having regard to the purpose for which it is used.

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The accuracy of much of the information we hold depends on information provided to us by clients and other persons.

We encourage you to notify us if:

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• your contact details change;

• information previously provided to us is no longer accurate; or

• you believe information we hold about you requires correction.

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Where appropriate, we will take reasonable steps to update or correct the information.

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14. Access to and correction of personal information

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You may contact us to request access to personal information we hold about you or to request that information be corrected.

 

Where applicable law gives you a right to access or correct personal information, we will deal with the request in accordance with those requirements.

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We may ask you to provide information sufficient to confirm your identity before providing access to personal information.

 

There may be circumstances where we are unable to provide access to some or all of the information requested, including where providing access would:

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• unreasonably affect the privacy of another person;

• reveal confidential information relating to another client;

• breach a legal or professional confidentiality obligation;

• disclose legally privileged information;

• prejudice an investigation or regulatory matter;

• be unlawful; or

• otherwise be inappropriate under applicable law.

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Where appropriate and required by law, we will explain the basis for refusing or limiting access.

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If you believe personal information we hold about you is inaccurate, incomplete, out of date or misleading, you may ask us to correct it.

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We will consider the request and take reasonable steps to correct the information where appropriate.

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15. Privacy enquiries and complaints

 

If you have an enquiry, concern or complaint about the way we have handled your personal information, please contact:

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Joshua Tilley

Managing Director

Accord Accountants & Advisors Pty Ltd

 

We will seek to understand the nature of your enquiry or complaint, obtain any additional information reasonably required and investigate the matter where appropriate.

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We aim to respond within a reasonable period having regard to the nature and complexity of the matter.

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Where the Privacy Act applies to the relevant matter, you may also have rights to raise a privacy complaint with the Office of the Australian Information Commissioner.

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16. Changes to this Privacy Policy

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We may amend this Privacy Policy from time to time to reflect changes to our business, services, technology or applicable legal and regulatory requirements. 

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The current version of this Privacy Policy is available on our website.

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