1. Introduction

Weston Woodley & Robertson Chartered Accountants and Consultants (“Weston Woodley & Robertson”) is committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth)(Privacy Act). This commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles (APPs). The APPs set out the way in which personal information must be treated.

This Privacy Policy sets out how Weston Woodley & Robertson handles personal information.

This policy applies to any person for whom we currently hold, or may in the future collect, personal information.

This policy does not apply to acts and practices which relate directly to the employee records of our current and former employees.

This Privacy Policy does not apply to personal information collected by Weston Woodley & Robertson that is exempted under the Privacy Act, for example employee records.

In this Privacy Policy, ‘Weston Woodley & Robertson’, ‘we’, ‘us’ and ‘our’ is a reference to Weston Woodley & Robertson and includes any entity carrying on business in Australia that forms part of the Weston Woodley & Robertson group of entities.

Weston Woodley & Robertson may modify this Privacy Policy from time to time to reflect its current privacy practices.

2. Personal information we collect

We are a full service Chartered Accountants firm and hold different information depending on the accounting and audit services provided to clients or, in the case of prospective employees, the information needed to assess future employment with us.

Generally, the types of information that we may collect and hold include:

(a) Names, job titles, contact and address details;

(b) Information in identification documents (e.g. passport, driver’s licence);

(c) tax file numbers and other government-issued identification numbers;

(d) Date of birth and gender

(e) Bank account details, shareholdings and details of investments;

(f) Details of superannuation and insurance arrangements;

(g) Educational qualifications, employment history and salary;

(h) Visa or work permit status;

(i) Personal information about your spouse and dependants;

(j) Financial information;

(k) Business circumstances;

(l) Family circumstances;

(m) Information about assets and investments;

(n) Information otherwise required by law; and

(o) Any other personal information required to perform the accounting and audit service to the individual.

It may be necessary in some circumstances for Weston Woodley & Robertson to collect sensitive information about you in order to provide specific services, examples of the types of sensitive information that may be collected in such circumstances include professional memberships, ethnic origin, criminal record and health information.

We will not collect sensitive information without the individual’s consent to which the information relates unless permitted under the Privacy Act.

It is generally not practical to remain anonymous or to use a pseudonym when dealing with Weston Woodley & Robertson as usually we need to use your personal information to provide specific services to you or which relate to or involve you.

3. How we collect and manage personal information

3.1 How we collect personal information

Generally we collect your personal information from you directly (e.g. when we deal with you in person or over the phone, when you send us correspondence (including via email), when you complete a questionnaire, form or survey.

However, we have a large referral network and also collect personal information from numerous other sources. It is not possible to provide an exhaustive list of these sources, but they may include:

(a) Professional advisors or agents for individuals who we act for;

(b) Banks and financial institutions;

(c) Government bodies;

(d) Insurance companies’

(e) Businesses about their employees, contractors, customers or suppliers;

(f) Barristers and other solicitors;

(g) Feedback surveys; and

(h) From paid search providers.

3.2 Where you provide us with personal information about someone else

Where you provide us with personal information about someone else, you should only do so if you have their authority or consent to provide us with their personal information. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy or any Privacy Collection Statement we give you.

3.3 Holding personal information

We hold your personal information either:

(a) physically,

i. on our premises; and/or

ii. at a third party specialist provider of records and document management services.

(b) Electronically,

i. Through internal servers and websites and secure cloud services;

ii. On electronic storage devices;

iii. By a third party data storage providers;

iv. By an off-side replication provider in Australia; and

v. By an external email filtering host based in Australia.

Some of the methods we use to store and secure information include:

(a) using security cards to access floors after hours;

(b) having designated areas to meet with clients and non-Weston Woodley & Robertson employees that do not contain personal information;

(c) using unique usernames, passwords and other protections on systems that can access personal information;

(d) using our document retention system; and

(e) using lockable filing cabinets for storing more sensitive information, other important documents or financial records.

Overseas Disclosures

We may also back-up your personal information on servers that are located overseas through third party service providers.  These servers are commonly located in the United States of America, Singapore and New Zealand.

We will take all reasonable steps to ensure that all personal information we, including third party service providers, hold is secure from any unauthorised access, misuse or disclosure. However, we do not guarantee that personal information cannot be accessed by an unauthorised person (e.g. a hacker) or that unauthorised disclosures will not occur.

3.4 The purpose for collecting holding using and disclosing personal information

Weston Woodley & Robertson collects, holds and uses personal information for a number of purposes including:

(a) to provide professional services;

(b) to provide technology services and solutions;

(c) to respond to requests or queries;

(d) to maintain contact with our clients and other contacts;

(e) to keep our clients and other contacts informed of our services and industry developments;

(f) to notify of seminars and other events;

(g) for administrative purposes;

(h) for recruitment purposes;

(i) for purposes relating to the employment of our personnel, providing internal services or benefits to our partners and staff and for matters relating to the partnership;

(j) when engaging service providers, contractors or suppliers relating to the operation of our business;

(k) to manage any conflict of interest or independence (including auditor independence) obligations or situations;

(l) for seeking your feedback;

(m) to meet any regulatory obligations;

(n) as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including Weston Woodley & Robertson business) or entering into an alliance, joint venture or referral arrangement; or

(o) for any other business related purposes.

If you do not provide us with the personal information we have requested, we may not be able to complete or fulfil the purpose for which such information was collected, including providing you or our clients with the services we were engaged to perform.

The types of third parties to whom we may disclose your personal information include:

(a) experts or other third parties contracted as part of an engagement;

(b) our service providers

(c) our professional advisers, including solicitors, valuers or other accountants;

(d) as part of an engagement, if you are a client, an employee, a contractor or supplier of services to one of our clients, then we may disclose your personal information as part of providing services to that client;

(e) as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including Weston Woodley & Robertson business) or to enter into an alliance, joint venture or referral arrangement; or

(f) government or regulatory bodies or agencies, as part of an engagement or otherwise, (for example, the Australian Taxation Office).

We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you.

3.5 Disclosure of personal information overseas –

We may store, process or back-up your information on external servers based in Australia. These external server providers may or may not host these functions overseas.

In some circumstances, Weston Woodley & Robertson also uses third party service providers to carry out its functions and provide services. These service providers may be members of our international association around the world.

4. Direct Marketing

Weston Woodley & Robertson may also use your personal information for the purpose of newsletter distribution. If you do not want to receive these you can contact us as detailed below:

(a) you can email gmn@wwr.com.au

(b) through our contact details below

5. Privacy of our Website

5.1 Your choices

You have several choices regarding your use of Weston Woodley & Robertson website. In general, you are not required to provide personal information when you visit our website. However, if you apply to receive information about our services, events and industry updates or wish to apply for a job, provision of certain personal information will generally be required.

5.2 Links to third party websites

Weston Woodley & Robertson website may contain links to third parties’ websites. Those other websites are not subject to our privacy policy and procedures. You will need to review those websites to view a copy of their privacy policy. Weston Woodley & Robertson also does not endorse, approve or recommend the services or products provided on third party websites.

6. Children

We understand the importance of protecting children’s privacy, especially in an online environment. In particular, our website is not intentionally designed for or directed at children under the age of 13. It is our policy to never knowingly collect or maintain information about anyone under the age of 13, except as part of a specific engagement to provide professional services which necessitates such personal information be collected or for the purposes of ensuring compliance with our independence policies.

7. Gaining access to personal information we hold

You can request access to your personal information, subject to some limited exceptions permitted or required by law. Such request must be made in writing to the Privacy Officer. Please see the How to contact us’ section for details.

Weston Woodley & Robertson may charge reasonable costs for providing you access to your personal information.

We may deny access to personal information if;

(a) The request is impractical or unreasonable;

(b) Providing access would have an unreasonable impact on the privacy of another person;

(c) Providing access would pose a serious and imminent threat to the life or health of any person; or

(d) There are other legal grounds to deny the request.

8. Keeping personal information current

It is important the information we hold about individuals is up-to-date. Individuals should contact us if their personal information changes.

If you believe that any personal information Weston Woodley & Robertson has collected about you is inaccurate, not up-to-date, incomplete, irrelevant or misleading, you may request correction. To do so, please contact the Privacy Officer and we will take reasonable steps to correct it in accordance with the requirements of the Privacy Act. Please see the ‘How to contact us’ section for details as to how to contact the Privacy Officer.

9. Complaints

If you wish to make a complaint to Weston Woodley & Robertson about our handling of your personal information, you can contact the Privacy Officer as set out in the ‘How to contact us’ section. You will be asked to set out the details of your complaint in writing in a form provided.

Weston Woodley & Robertson will endeavour to reply to you within 30 days of receipt of the completed complaint form and, where appropriate, will advise you of the general reason for the outcome of the complaint. In some circumstances, the Privacy Officer may decline to investigate the complaint, for example if the complaint relates to an act or practice that is not an interference of the privacy of the person making the complaint. If you are not satisfied with the outcome of your complaint, you can refer your complaint to the office of the Australian Information Commissioner.

10. How to contact us

If you have a query in relation to this Privacy Policy or you would like to notify Weston Woodley & Robertson that you no longer wish to receive marketing material from us, access or correct your personal information or to make a complaint about Weston Woodley & Robertson handling of your personal information, please contact Weston Woodley & Robertson as follows:

Privacy Officer