1. Privacy Commitment
1.1. 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 firms commitment to your privacy.
1.2. 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.
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 (including via online enquiry forms you submit, our direct discussions with you, any emails, blogs, letters, faxes or other correspondence you send to us and when you subscribe to our online publications);
- from any entity within our Group;
- 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 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).
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, credit card 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.
2.6. 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;
- for recruitment purposes;
- 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.
3.3. We may disclose your Personal Information:
- to any other member of Shanahan Swaffield Partners or to allow them to provide you with services or to provide information about the services they provide or so they can assist us in providing applicable services to you;
- to our contractors, agents and service providers (for example, information technology contractors, debt collection agencies, event managers and recruitment and human resources consultants) but only (a) for the purpose of providing services to you, (b) as necessary to facilitate the operation of our business, and/or (c) for the purpose of storing your Personal Information;
- to other entities in our group to facilitate our and their internal business operations;
- 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 and promotions;
- as required or authorised by law or to meet our professional standards;
- to any person with your consent;
- in connection with any sale of any member of Shanahan Swaffield Partners Group; and
- 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.
3.5. Information other than Personal Information collected when you visit our Website may be used to monitor usage of and decide how to improve and promote our Website, products and services (including online advertising).
3.6. In addition, Shanahan Swaffield Partners may:
- where you have requested the provisions of services, disclose your Personal Information so your request can be considered and contact you in respect of such services; and
- where you are an employee, contractor, consultant, director or partner of Shanahan Swaffield Partners, disclose your Personal Information to our third party affiliates so the same can provide you with online and other resources.
4. Collection, Use and Disclosure of Sensitive Information
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) bank account details.
4.3. 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.
4.4. We will not disclose Sensitive Information to other members in our Group without your prior written consent.
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).
5. Direct Marketing
5.1. We may use or disclose your Personal Information for direct marketing purposes, being:
- to promote our services and provide you with information and marketing materials about other services that may be of interest to you including services provided by other members of our Group;
- to provide information relevant to your type of business or other area of expertise or interest; and
- to provide you with the opportunity to attend seminars, conferences or other events that may be of interest to you.
5.2. If you do not wish to receive direct marketing communications from us, you can ‘opt out’ by clicking the ‘Unsubscribe’ link in our emails or other electronic communications, or sending an email with your contact details requesting that you no longer receive direct marketing materials from us. We will remove you from our direct marketing database as soon as reasonably practicable after receiving a request but in any event, within 30 days of receiving such a request.
6. Requirement to Provide Information
6.1. 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.
7. Cross Border Disclosure
7.1. It is possible that some of the Personal Information we collect may be disclosed to our contractors, agents and service providers located outside of Australia for storage purposes or for the purpose of completing a portion of the services. We have engaged Frontline Accounting of Australia and Manila as well as Pacific Accounting & Business Services (PABS) to provide Shanahan Swaffield Partners with staff to assist us with the delivery of Accounting and Taxation services. We have also engaged SuperRecords Business Resourcing of Paramatta to provide SMSF Audit Services.
7.2. We take such steps as are reasonably necessary in the circumstances to ensure that any overseas third party service providers we engage do not breach the Australian Privacy Principles. You consent to your information being disclosed to a destination outside Australia for this purpose, including but not limited to Manila and India.
8.1. We will not adopt a government related identifier (including a Tax File Number) of you as our own identifier of you.
9. Holding and Security of your Personal Information
9.1. 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.
9.2. 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:
- securing our premises by requiring security passes to enter our offices;
- placing passwords and varying access levels on databases to limit access and protect electronic information;
- the use of firewalls, encryption, passwords and digital certificates;
9.3. 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 (including Personal Information), it is sent at your own risk as it may not necessarily be secure against interception.
10. Accessing and Correcting Personal Information
10.1. 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. We will try to respond to your request within a reasonable period.
10.2. 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.
10.3. 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.
11. Changes to Policy and Complaints
11.1 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 obligations under the Act, you can make a complaint by emailing or writing to us. 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.
12.1. a reference to us, our or we is to Shanahan Swaffield Partners.
12.2. Act means Privacy Act 1988.
12.3. Shanahan Swaffield Partners means S & S Accounting Services Pty Ltd (ACN 131 395 170) and any related firm operating under the Shanahan Swaffield Partners brand.
12.4. Group means each of the entities forming the Shanahan Swaffield Partners Group (Including InsureRight Risk Management, InvestRight Wealth Management and TechRight IT Solutions).
12.5. 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.
12.6. Group means the individuals, entities and/or companies defined as “the Group” in an Engagement Letter.
12.7. 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;
12.8. 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.
12.9. Website means all of the pages located on the website you are currently viewing, being www.sspaccountants.com.au which is operated and maintained by FM Studios on behalf of Shanahan Swaffield Partners.
13. Contact us
If you have any queries in respect of our Policy or to request access to your information or make a complaint, please contact us by email or in writing.
Version A: 11 January 2021