Waterhouse Chartered Accountants 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 policy sets out how Waterhouse Chartered Accountants handles personal information.

This privacy policy does not apply to personal information collected by Waterhouse Chartered Accountants that is exempted under the Privacy Act, for example employee records.

Our privacy policy will be reviewed regularly to take account of changes in legislation, technology, and our operations and practices. We aim to ensure the policy is appropriate to the changing environment. We will inform you of any changes we make to this privacy policy as necessary.

Our privacy policy is based on openness about how we use and protect your information.

1. Purposes for which Waterhouse Chartered Accountants collects, holds, uses and discloses personal information

We only collect, hold, use and disclose personal information which is reasonably necessary to ensure that we are able to provide you with the products and services that are appropriate to your needs. We will outline to you when you engage our services the purposes for which we will collect, hold, use and disclose your personal information.

2. Kinds of personal information Waterhouse Chartered Accountants collects

Due to the nature of the products and services we provide, and the requirements of legislation and regulations, we ask for a range of personal information from our customers.

The types of personal information we may collect can include details such as:

• Names, employment titles, contact details;
• Date of birth and gender;
• Information in identification documents (e.g. passport, driver’s licence);
• Tax file numbers and other government related identifiers;
• Assets and liabilities;
• Educational qualifications and employment history;
• Personal income;
• Visa and work permit status;
• Bank account details;
• Shareholdings and details of investments;
• Superannuation details;
• Tax and financial statements;
• Information regarding insurance;
• Personal information about your spouse and dependants.

It may be necessary in some circumstances for Waterhouse Chartered Accountants to collect sensitive information about you in order to provide specific services. The types of sensitive information we may collect include:

• Health status;
• Ethnic origin;
• Details of any membership/s to professional associations;
• Criminal record.

You have a right to refuse to provide us with your personal information or to anonymity or the use of a pseudonym. However, if you do refuse to provide such information, or request the use of anonymity or a pseudonym we may be unable 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.

3. Collection, holding, using and disclosing of personal information

3.1 Collection – General

When we collect, hold, use and disclose personal or sensitive information it must be done through lawful and fair means. Consent must be obtained to collect, hold, use and disclose personal information. We are not required to obtain your consent to collect, hold, use of disclose your personal or sensitive information if the collection is required or authorised by or under an Australian law or a court/tribunal order. There are other exceptions to the requirement of obtaining your consent in accordance with the Australian Privacy Principles. If you would like more information on these requirements, please contact our Privacy Officer.

3.2 Methods of collection

Waterhouse Chartered Accountants use a variety of formats for the collection of personal and sensitive information. These include:

• Requiring clients to complete a Client Profile or other forms;Receipt of emails, letters and other correspondence;
• Telephone calls;
• Appointments in person;
• Publicly available records;
• Through a customer’s personal representative;
• Through use of our website, such as via contact mailboxes or online enquiry forms, or through the registration process.

In every circumstance we will attempt to obtain such personal and sensitive information directly from you. If that is unreasonable or impracticable, we will attempt to obtain such information from other sources in accordance with our process described below.

3.3 Collection of someone else’s personal information.

You should only provide us with someone else’s personal information where you have their express consent to do so and it is for the purpose of us providing services to you. Matters in this policy should be communicated to any person whose information you collect and provide to us. In providing such information you agree that you have obtained the revenant consent and this is authorised to do so.

3.4 Unsolicited personal information.

There may be circumstances where we are provided with personal information which we did not actively seek. An example may be misdirected mail, or an excess of documents provided to us by clients.

In such situations, our Privacy Officer will make a determination on whether we could have obtained the information lawfully in accordance with the APPs. If the information was not lawfully obtained it will be destroyed or de-identified. We will try to notify the relevant person, whose information has been mistakenly received, if this situation arises.

4. Security of personal information

Safeguarding the privacy of your information is important to us. We hold personal information in a combination of secure computer storage facilities and paper based files, and take steps to protect the personal information we hold from misuse, loss, interference, unauthorised access, modification or disclosure.

Waterhouse Chartered Accountants trains its employees carefully on handling personal information and confidentiality of such information.

Once we have no purpose for holding your personal information, we will take all reasonable steps to destroy or de-identify the information.

5. Disclosure of personal information to associated companies

5.1 Disclosure to associated companies

Waterhouse Chartered Accountants and Waterhouse Wealth Management may share information to meet the purposes for which your personal information has been collected and to complete work on your behalf.

5.2 Disclosure to third party service providers.

Waterhouse Chartered Accountants utilises third party providers (such as IT providers and insurance professionals) for its business and to deliver services to you. It may be necessary for us to disclose non-sensitive personal information to these providers from time to time. Such disclosure will be in accordance with this Privacy Policy and the APPs.

6. Privacy on our websites

The Waterhouse Chartered Accountants website uses Google Analytics or other third party software to analyse aggregate user behaviour. Google Analytics and such other software uses first party cookies, which are text files placed on your computer for the purpose of anonymously identifying your session. These cookies are not used to grant access to your personally identifiable information. Non-identifiable information (such as the pages you visit) may be tracked. By directing your browser to delete your cookies, this data will be erased.

We will not associate any data gathered from our website with any personally identifiable information, unless you explicitly submit that information (e.g. your email address) via our online information form.

Any links to third party websites on Waterhouse Chartered Accountants website are not covered by our privacy policy.

7. Communicating with you

Waterhouse Chartered Accountants may send information to you from time to time. in the form of newsletters, updates and announcements our latest news, products or services. This information will normally be provided by email and will always allow you to opt out of receiving any future communications.

8. Access to personal information

You have the right to access any personal information regarding you that Waterhouse Chartered Accountants holds. This is subject to some limited exceptions, which the Privacy Officer can provide further information on. Such requests should be made in writing to the Privacy Officer. We will acknowledge your request within 14 days and respond to it within a reasonable time.

A fee may be charged only to cover the cost of locating, retrieving, reviewing and copying any material requested. We do not charge any fee to make or acknowledge the request.

9. Correction of personal information

Waterhouse Chartered Accountants endeavours to ensure that the personal information it holds is accurate and up-to-date. You are able to make a request to correct the information by contacting our Privacy Officer, or by telephoning or emailing us with your corrected information. In some limited circumstances your request may be refused or partially refused.

If this occurs we will give you a written notice that sets out:

• The reasons for the refusal, including the reasons why access cannot be granted in an alternative way (except where it would be unreasonable to provide those reasons);
• How to make a complaint about the refusal;
• Any other matter as prescribed by the regulations.

If your request to correct is refused you have the option of submitting a statement associated with your personal information. For more information contact the Privacy Officer.

10. How to make a complaint

If you consider that any action of Waterhouse Chartered Accountants breaches this policy or the Australian Privacy Principles, you are able to make a complaint. Once we have received your complaint, it will be assessed and acted upon within a reasonable time.

To make a complaint please contact our Privacy Officer. If you are not satisfied with our response to your complaint, you may contact the Office of the Privacy Commissioner.

11. Privacy Officer contact details

If you have a query relating to this Privacy Policy or wish to make a complaint, please contact us using the following contact details:

Privacy Officer
Waterhouse Chartered Accountants
Suite 12 Level 3, Gateway Building
1 Mona Vale Road
Mona Vale NSW 2103
admin@waterhouseca.com.au