Socials

Introduction

This privacy policy applies to SW Accountants & Advisors (ABN 48 005 273 496) (SW, We, Us) and any entity owned or controlled by SW (Related Entity) in relation to SW’s and its Related Entities (together SW) operations in Australia. The SW Privacy Policy sets out how we may collect, store, use and disclose your personal information. Your privacy is important to SW and we are committed to handling your personal information in a responsible way in accordance with the Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles in the Privacy Act.

What information will we collect?

SW collects and holds personal information from clients, customers, employees, contractors and other individuals necessary for business purposes.

The main types of information SW generally collects and holds will include:

  • an individual’s name, address, e-mail address, phone numbers, date of birth and other similar contact or identity details;
  • investment details, payroll details, taxation details, banking details, job titles and other accounting and financial services related information regarding an individual; and
  • information about an individual’s financial circumstances and objectives, including the individual’s assets, liabilities, income, expenditure and investment preferences.

Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. If we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law.

Cookies

Cookies are small files that are placed on your device by websites which collect information about your use of those websites. Different types of cookies are used for different purposes. There are cookies that are active for a single session which, for example, help to facilitate the completion of application forms or surveys. On the other hand, persistent cookies are stored on your device and help websites remember your information and settings when you visit them in the future.

SW uses cookies for various purposes including:
• Determining if your browser has previously visited the website; and
• remembering your settings/preferences and tracking and reporting on website usage.

You can choose to change your browser’s cookie settings via your browser privacy settings, including blocking the use of cookies. If you choose to delete or block cookies, your experience on may be limited.

How do we use this information?

SW collects most information directly from you when we deal with you. The personal information SW collects may be provided in forms filled out by you, face to face meetings, where you use our websites or other online services, email messages, telephone conversations or if you post on our social media sites. If you contact SW, a record of that contact may be kept. We may also from time to time collect information about you from a third party, such as your other advisors or from publicly available databases or registers.  On all occasions, your information is collected, held, used and disclosed by us in accordance with this Privacy Policy.

The nature of the services provided by SW may limit us from allowing the use of pseudonym or otherwise dealing with you on an anonymous basis (including where it is not practical to do so or where we are required by law to deal with identified individuals).  However if you would like to deal with us using a pseudonym or otherwise on an anonymous basis please let us know and we will seek to accommodate this where we are able to.

How do we use this information?

SW collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities. If you choose not to provide us with personal information, SW may be unable to do such things. Some examples of the purposes for which SW collects, holds, uses and discloses your personal information include:

  • enable us to supply you with information you request from us;
  • supply our services to you, including our accounting and other financial advisory related services;
  • to manage and improve our website;
  • personalise your experience with our services;
  • undertake direct marketing (as detailed below);
  • analyse information we collect so that we can administer, support, improve and develop our business and the products and services we offer; and
  • comply with the obligations of SW under any applicable laws.

SW may collect, hold and use personal information about individuals to market its services, including by email. However, individuals always have the opportunity to elect not to receive further marketing information from SW by contacting our Privacy Officer (see the contact details below). Please allow for 28 days for your request to be processed. Alternatively, if SW contacts you by email, you may use the unsubscribe function in that email to notify SW that you do not want to receive further marketing information by email.

SW will only use your information for the purpose for which you provided it to us, related purposes, the purposes set out in this Privacy Policy and as permitted or required by law.

In addition to the purposes listed above, SW may use your personal information for other purposes which we notify you of when we collect the information.

How will your information be disclosed?

Staff of SW will have access to personal information in relation to client matters, for use in the provision of services to SW clients. Other SW staff will have access to personal information relevant to the performance of their roles and tasks.

SW discloses your personal information for the purpose for which SW collects it. That is, generally, SW will only disclose your personal information for the purpose carrying out our business functions and activities. This may include disclosing your personal information to third parties engaged to perform administrative or other business management services, as well as to our Related Entities. This disclosure is always on a confidential basis or otherwise in accordance with law. SW may also disclose your personal information with your consent or if disclosure is required or authorised by law.

SW may also need to disclose your personal information to one or more of the third party organisations which may include (but is not limited to):

  • A client’s personal financial advisor and their service provider;
  • Individuals or organisations that are your representatives including a client’s legal advisors;
  • Organisations authorised by Federal or State legislation;
  • Other organisations where a client has given their express consent;
  • The Australian Tax Office;
  • The Australian Securities and Investments Commission;
  • Off-site third-party organisations providing storage and archiving services; and
  • Other third parties as required by us in performing the functions and activities of the service.

Overseas disclosure

Our business is affiliated with other businesses located overseas. In the course of doing business with you, we may disclose some of your personal information to overseas recipients. However, we will only do so where:

  • It is necessary to complete the transaction you have entered into; and
  • You have provided consent; or
  • We believe on reasonable grounds that the overseas recipient is required to deal with your personal information in a way that complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme; or
  • It is otherwise permitted by law.

At present, some of our network entities may exchange data with our overseas affiliate located in India. However, any such exchange does not change any of our commitments to safeguarding your privacy and the data remains subject to existing confidentiality obligations.

How is your information secured?

SW utilises a range of procedures to protect your personal information. These may include:

  • Security procedures associated with access to our business premises;
  • Security procedures within our offices;
  • IT systems designed to ensure personal information is only available to those staff who require access;
  • IT security procedures including password protection, firewalls, intrusion detection and site monitoring;
  • Mandatory confidentiality guidelines for all staff and data processors within the business.

SW will endeavour to take all reasonable steps to keep secure any information which it holds about you, whether electronically or in hard-copy, and to keep this information accurate and up to date.

We will retain your personal information whilst it is required for any of our business functions, or for any other lawful purpose and we will also retain your personal information for the time periods required by law. Personal information no longer required to be retained by us will be deleted or destroyed in accordance with our document deletion and retention policies and procedures.

Here are some of things we do to protect your information:

Staff training

  • Confidentiality requirements and privacy training of our employees; and
  • Only giving access to personal information to a person who is verified to be able to receive that information.

Secure handling of Information

  • When we send information overseas or use third parties that handle or store data, we put arrangements in place to protect your data; and
  • Mandatory confidentiality guidelines for all staff and data processors within the business.

Building Security

  • We use a mix of alarms, camera’s and other controls in our buildings to prevent unauthorised access.

Destroy or de-identifying data when no longer required

  • We aim to keep your information as long as it’s needed. When we no longer need information, we take reasonable steps to destroy or de-identify it.

System Security

  • Security procedures within our offices;
  • IT systems designed to ensure personal information is only available to those staff who require access; and
  • IT security procedures including password protection, firewalls, intrusion detection and site monitoring.

Third Parties

  • Ensuring third parties and Joint Venture partners meet SW’s privacy obligations.

SW will endeavour to take all reasonable steps to keep secure any information which it holds about you, whether electronically or in hard-copy, and to keep this information accurate and up to date.

Access

SW will provide access to personal information held by SW upon request, except in limited circumstances in which it is permitted to withhold this information (for instance, where granting access would infringe on another person’s privacy). 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 the personal information held on you, you should contact the member of staff responsible for your file or the Privacy Officer of SW, and request a “Personal Information Access Form”. We may require you to provide some form of identification (such as a driver’s licence or passport) so the necessary verification can occur.

While we do not charge a client for making a request to access their personal information, you should be aware that SW may charge an administration fee for time and cost in the following circumstances:

  • Staff costs: if an extended amount of time is required in searching for, locating, retrieving, collating and preparing the material; and
  • Costs associated with using an intermediary.

Any charges for accessing the information will be advised prior to commencement (estimated time and cost).

If you are dissatisfied with SW’s refusal to grant access to your personal information, you may make a complaint to the Office of the Australian Information Commissioner.

Accuracy & Correction

In the event that you wish to advise us of changes to the personal information we hold, please contact your SW Representative by phone, email, mail or fax, and we will amend your file accordingly.

If you wish to have your personal information deleted, please contact the Privacy Officer and we will take reasonable steps to delete it (unless we needs to keep it for legal, auditing or internal risk management reasons).

In certain situations, we may not agree to a request to correct information we hold about you. If this occurs, we will advise you of this and our reason for not agreeing to the correction request and you have the right to complain about the refusal in the manner set out in the next section.

If you are dissatisfied with SW’s refusal to correct your personal information, you may make a complaint to the Office of the Australian Information Commissioner.

What do you need to do if you have a complaint?

If you want to make a complaint about our handling of personal information we ask that you contact SW first. We will then follow our internal dispute resolution process and we will endeavour to respond within a reasonable period after the request is made (not exceed 30 calendar days). If the matter proves to be more complex we will advise you of a revised response timeframe in writing.

If your complaint is not handled satisfactorily, you may refer your complaint to the Office of the Australian Information Commissioner (www.oaic.gov.au). If you have any further queries relating to our privacy policy, or you have a problem or complaint, please contact our Privacy Officer. Any complaint regarding a possible breach of privacy by SW should be directed to SW in writing; mail or e-mail to the Privacy Officer at the following address:

The Privacy Officer

SW
Level 10, 530 Collins Street
Melbourne VIC 3000
E [email protected]

T 61 8635 1800

If your complaint is not handled satisfactorily, you may refer your complaint to the:

The Office of the Australian Information Commissioner

T 1300 363 992
E [email protected]
www.oaic.gov.au/privacy

Australian Financial Complaints Authority

The Australian Complaints Authority (AFCA) provides fair and independent financial services complaint resolution that is free to consumers. ACFA can be contacted at:

W www.afca.org.au
E [email protected]
P 1800 931 678 (free call)
In writing to: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001

Privacy Policy Updates

This Privacy Policy is not a static document. SW may from time to time make changes and update this Privacy Policy. The current SW Privacy Policy will always appear on our website.

The amended policy will apply between us whether or not we have given you specific notice of any change.

This policy was last updated 1 November 2018.