1. Privacy Commitment​

 

Thank you for visiting our website and for reviewing our Policy. We respect the importance of your privacy and the Personal Information in our care. We have created this Policy in order to demonstrate our firm commitment to your privacy.

We are subject to and seek to ensure that all Personal Information we collect is handled in compliance with the Australian Privacy Principles contained in the Act. This Policy sets out how we collect, hold, use and disclose information (including Personal Information) that we obtain from you.

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2. Collection of personal information

 

2.1. We collect Personal Information as well as non-personally identifiable information that you voluntarily provide.

 

2.2. We will only collect Personal Information about you:

• from you (our direct discussions with you, any emails, letters, or other correspondence you send to);

• from any person authorised by you to provide such Personal Information to us (such as your professional advisors or personal representatives);

• if you are part of a Group, from any other member of that Group for so long as you have provided consent to the same and have not revoked that consent by written notice to us;

• from third party contractors and suppliers we engage to help us provide services;

• from external sources where the information is publicly and readily available; and

• from third parties (for example, your spouse) where it is otherwise unreasonable or impractical to collect such Personal Information from you directly. In such cases, we will inform you before, or as soon as reasonably practicable after, we collect such Personal Information.

 

2.3. As an example, and without limiting the types of Personal Information we collect, we may collect the following Personal Information (a) name, address, and contact details such as telephone number and email address, (b) details of your interests in or ownership of entities or control of trusts, and (c) accounting information such as your tax file number, bank account details and details of your investments.

 

2.4. We will only collect information relating to your tax file number for purposes authorised by law. You are not obliged to provide your tax file number to us but if you fail to do so, there may be financial consequences.

 

2.5. Where you provide us with Personal Information of third parties (for example, your spouse) you warrant to us that the relevant individuals have consented to you disclosing their Personal Information to us. 

 

3. Use and disclosure of Personal Information

 

3.1. How we use your Personal Information varies based on the services we are providing. Generally, we may use your Personal Information:

• as necessary to provide services to you;

• to perform due diligence and conflict checks prior to agreeing to provide services to you;

• for customer relationship management purposes and to respond to your queries;

• to analyse client needs and improve the services we provide;

• for audit, regulatory and compliance purposes;

• for industry accreditation purposes;

• for accounting and administrative purposes (including to process transactions, provide accounting services, facilitate our internal business operations and comply with our legal or regulatory obligations); and

• for other purposes related to our provision of business advisory services to you.

 

3.2. We will not use or disclose your Personal Information for a purpose other than for that which it was collected unless you have provided your consent or you would reasonably expect us to use or disclose the Personal Information for that other purpose. If you are part of a Group and have consented to our use of your Personal Information so we can perform the services in the Engagement Letter in respect of each and any Group member, we may use your Personal Information as part of performing those services for any Group member unless and until you provide us with a written notice revoking such consent.

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3.3.  We may disclose your Personal Information:

• to the Australian Taxation Office, the Australian Securities and Investments Commission and other government bodies as required by law or as necessary to provide services to you;

• to third parties with whom we are affiliated for the purpose of those third parties providing you with information about their services;

• as required or authorised by law or to meet our professional standards;

• to any person with your consent;

• to our professional advisers but only so they can advise us in respect of the same.

 

3.4. If you are part of a Group and have consented to our use of your Personal Information so we can perform the services in the Engagement Letter in respect of each and any Group member, we may disclose your Personal Information to any other Group member as part of performing those services (including disclosure in any document, financial reports or tax returns prepared by us) unless and until you provide us with a written notice revoking such consent.

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4. Collection, use and disclosure of Sensitive Information

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4.1. We will only collect Sensitive Information from you directly as reasonably necessary to provide services to you and with your consent.

 

4.2. As an example, and without limiting the types of Sensitive Information we collect, we may collect the following Sensitive Information (a) tax file number and (b) medical history.

 

4.3. We will not collect your tax file number unless you have signed our Terms of Engagement letter. You may revoke your consent at any time if you are no longer our client, in which case, we will only retain your tax file number for any purpose required by law or under any contract with its licensee.

 

4.4. We will only disclose Sensitive Information in accordance with the Act as follows: (a) for the primary purpose for which it was collected, (b) for a secondary purpose that is directly related to the primary purpose, or (c) as required by law.

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4.5. Information regarding your tax file number will only be disclosed to you personally and according to relevant laws (including, where you are an individual, in compliance with the Privacy (Tax File Number) Rule 2015 made under section 17 of the Act).

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5. Requirement to provide information

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In general, you are not required to provide personal information to us. However, if you wish to receive information about our services, events, industry updates or to apply for employment, you acknowledge that it may not be practical for you to use a pseudonym or otherwise not identify yourself and that we may require you to provide certain Personal Information. If you do not provide some or all of the Personal Information requested, we may not be able to provide you with some or all of the services you request.

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6. Identifiers

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6.1 We will not adopt a government related identifier (including a Tax File Number) of you as our own identifier of you.

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7. Holding and security of your Personal Information

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7.1. We may store your Personal Information in hard copy or electronic format, in storage facilities that we own and operate ourselves, or that are owned and operated by our service providers.

 

7.2. We take reasonable steps to:

• ensure that any Personal Information we hold or disclose about you is up to date, complete and correct; and

• protect your Personal Information from misuse, interference, loss, and unauthorised access, modification and disclosure using electronic and physical security measures such as:
  (a) securing our premises;
  (b) placing passwords and varying access levels on databases to limit access and protect electronic information;
  (c) the use of firewalls, encryption, passwords and digital certificates;
  (d) providing locked cabinets and rooms for the storage of physical records; and
  (e) requiring our staff to undertake privacy and data protection training.

 

7.3. We will destroy or delete any of your Personal Information which we no longer need to retain noting that we are required by law to retain certain information for a number of years after we have ceased providing the services.

If you email us any information, it is sent at your own risk as it may not necessarily be secure against interception.

 

8. Accessing and correcting Personal Information

 

8.1. On your request, except to the extent that we are lawfully able to refuse such a request, we will provide you with access to Personal Information that we hold about you. All requests about the Personal Information that we hold should be made by email or in writing to us (see clause 12 of this Policy for our contact details). We will try to respond to your request within a reasonable period.

 

8.2. If you satisfy us that Personal Information that we hold about you is misleading, inaccurate, out of date or incomplete, except to the extent that we are lawfully able to refuse such a request, we will correct the Personal Information that we hold about you. If it is reasonable and practicable to do so, we will give you access to your Personal Information in the manner that you request. We do not generally charge for providing such access but may do so in certain circumstances.

 

8.3. In the event that we deny access to or refuse to correct your Personal Information that we hold, we will provide you with written reasons and the mechanisms available to complain about such refusal.

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9. Third party websites

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When you leave our Website, you will be going to websites that are beyond our control. Our Policy does not apply to third party websites. We encourage you to read the privacy policies of third party websites before disclosing any Personal Information.

 

10. Changes to policy and complaints

 

We may amend this Policy from time to time without notice to you. The revised Policy will take effect when it is uploaded on our website. If you believe that we have breached our privacy reporting obligations under the Act, you can make a complaint by emailing or writing to us (see clause 12 of this Policy for our contact details). We will attempt to complete our investigation and resolve your complaint within 14 days from the date you lodge your complaint. If we think it will take longer to resolve your complaint, we will inform you. If we do not resolve your complaint to your satisfaction or you are dissatisfied with the action we have taken, you can make a complaint to the Office of the Australian Information Commissioner. For further information about how to do this, please contact the Office of the Australian Information Commissioner on 1300 363 992 or visit www.oaic.gov.au.

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11. Meanings

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In this Privacy Policy (Policy):

 

11.1. Act means Privacy Act 1988.

 

11.2. DCJ Financial Services operates under Brinsley Pty Ltd (ABN 82 010 215 362)

 

11.3. Engagement Letter means the letter of engagement issued by us outlining the services to be provided by us to members of a Group which is accepted by a member of the Group.

 

11.4. Group means the individuals, entities and/or companies defined as “the Group” in an Engagement Letter.

 

11.5. Personal Information means information (including an opinion) about an individual whose identity is apparent or can reasonably be ascertained from the information whether true or not and whether or not recorded in a material form;

 

11.6. Sensitive Information has the meaning given by the Act and includes Personal Information which relates to an individual’s racial or ethnic origins, religious beliefs or affiliations, trade association, trade union membership, sexual orientation, criminal record and information as to an individual’s health or biometric information.

 

11.7. Website means all of the pages located on the website you are currently viewing, being www.dcjfinancialservices.com.au which is operated and maintained by DCJ Financial Services.

 

12. Contact us

 

If you have any queries in respect of our Policy or request access to your information or make a complaint, please contact us by email or in writing the applicable privacy officer, detailed in Annexure A.

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Annexure A – DCJ Financial Services

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DCJ Financial Services:
Brinsley Pty Ltd (ABN 82 010 215 362)
Privacy Officer:
Attention: Deborah McWilliam
PO Box 1404 Noosa Heads QLD 4567
T: +61 7 5455 6724
E: deb@dcjfinancialservices.com.au

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