Privacy Policy
General
We understand that the privacy of your personal details is of the utmost importance to you and this policy sets out the rules we will abide by when dealing with personal information we collect from individuals in the course of our business. This policy is consistent with the Australian Privacy Principles (APP) of the Privacy Act 1988 and the Office of the Australian Information Commissioner’s (OAIC) APP guidelines.
Personal Information
In this policy personal information means information from which an individual is either identified or reasonably identifiable.
What Information is Collected and Held
Clients or Potential Clients
The personal information we collect includes your name, address details, date and place of birth, telephone numbers, email address and other information specific to the services provided. This can include, but is not limited to, tax file number, Australian business number, bank account and credit card details, business and financial information. This information is used in the provision of accounting, taxation and other professional financial services.
Website and Client Portal Users
When using our website or client portal you may provide us with personal information. We will use all reasonable measures to protect any such information from being used for any other purpose, other than the purpose for which it was intended.
As well as the information you specifically provide above, we may gather statistics on its web site to collect information about the number of visitors coming to the site and their location. No identifying information is collected during this process. We use this information for statistical purposes only.
We may also use ‘cookies’. Cookies are small files which are stored on a user’s computer. They are designed to hold a modest amount of data about a user’s preferences. This allows the website to deliver a page tailored for a particular user, or the page itself can contain some script which is aware of the data in the cookie and so is able to carry information from one visit to the website (or related site) to the next. It is possible to have your internet browser refuse cookies, but that may reduce the functionality.
Employees and Potential Employees
When recruiting and employing staff, we collect personal information such as your name, address details, telephone numbers, email address and other information specific to the recruiting/ employment activities. This can include, but is not limited to previous work experience, education, references, tax file number and superannuation details.
How Information is Collected
If it is reasonable and practical to do so, we will collect personal information directly from the individual(s) concerned with their consent. This may be through emails, over the telephone, over the internet or in person.
We may need to collect personal information from another person or entity such as the Australian Taxation Office, ASIC, your bank, your financial adviser, your employer, your lawyer or other sources as required. We do not collect personal information without your consent.
When you provide personal information to us about other individuals, we rely on you to have made them aware that you will or may provide the information to us and the relevant purposes for which we will use this information. You also need to inform them how they can access this information.
How the organisation will keep personal information accurate and up-to-date
We seek to maintain the quality of the information we hold by taking reasonable administrative and technical steps to make sure that the information collected, used and disclosed is accurate, complete and up-to-date. If the information we hold about you is incorrect, you may inform us and we will correct it for you.
How the organisation will keep information and data secure
The organisation utilises up-to-date techniques and processes, which meet current government requirements to protect personal information from misuse, loss and unauthorised access, modification or disclosure.
Paper documents are protected from unauthorised access or use through the various security systems that we have over our physical premises including secured storage of files and security patrols of the premises.
We also maintain up-to-date computer and network security systems with appropriate firewalls, access controls and passwords to protect electronic copies of personal information.
The only people who are permitted to access personal information are those employees or contractors who need personal information to do their jobs. All employees and contractors are contractually bound by the confidentially agreements in place on how personal information must be treated.
We take all reasonable steps to ensure that all personal information we hold is secure from any unauthorised access, misuse or disclosure, however we cannot guarantee that unauthorised access will not occur.
Destroying personal information
Any personal information we hold will be maintained in order to comply with legislative and professional requirements, after which time the information will be securely destroyed. Where the information is paper based, it will be shredded and if held electronically will be deleted from our on-site and off-site storage systems.
Access to personal information we hold and to correction of that information
Our policy is to provide you with access to your own personal information, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (i.e. by providing copies or permitting a file to be viewed), provided it is reasonable and practical for us to do so.
Complaints
Should you have a complaint about any of our privacy procedures, please contact us by email at info@marzolholloway.com.au or by telephone on (07) 5593 3555. We will deal promptly with your complaint. If we cannot resolve the complaint to your satisfaction within a reasonable time, you or we may refer the complaint to the Office of the Australian Information Commissioner.
Disclosure of Your Information to Third Parties
There are occasions when we may be requested to provide your personal information to third parties such as the Australian Taxation Office, Australian Securities Commission, your bank or other parties in order to provide our services to you. This is done with your consent to using your personal information in this way, unless we are required by legislation to disclose information.
Disclosure of personal information to overseas recipients
Our firm may from time to time use the services of third party contractors to perform some of the services we are engaged to perform for you. Each client in the Group hereby authorises us to disclose information relating to that client’s affairs to all such third party contractors as we may choose to engage to perform such work.
Where we use the services of third party contractors, we are nevertheless responsible for the conduct and activities of those contractors and for the delivery of the services we are engaged to perform for you. We take care to ensure that any overseas recipient does not breach the Australian Privacy Principles in relation to personal information and have confidentiality agreements in place with all personnel who access personal information.
Acceptance of our services in conjunction with this engagement document indicates your acceptance of the use of third party contractors.
Use or disclosure of Government related identifiers
We will not use a government identifier as your unique identifier within our systems. We will not disclose any of your Government related identifiers without your express consent, or if we are required under the Law.
Privacy Collection Notice
This privacy collection notice from Marzol, Holloway & Associates outlines why we collect your personal information, what we collect, how we collect it and who we share it with.
Why we need to collect your information
We collect your personal information to comply with the ‘Customer Due Diligence’ requirements in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). This includes to:
- establish and verify your identity before providing certain services to you or the person you are acting on behalf of
- assess and manage potential money laundering, terrorism financing, proliferation financing risks or related compliance risks associated with the provision of our services
- make reports required by law under the AML/CTF Act
- meet record keeping obligations under the AML/CTF Act.
What personal and sensitive information we collect
We collect the following types of personal information:
- your full name, date of birth, residential address
- photo ID and unique identifier, such as a passport or driver’s licence number
- your contact details, including email address and phone number
- business details, including your ABN and business structure
- tax file number – This is not collected for customer due diligence purposes, but so that we can provide tax agent services to you. Tax file numbers are subject to additional protections under Australian law and we will only use or disclose yours for a lawful taxation purpose.
How we collect your information
We generally collect your personal information directly from you.
When you become a client, we send you a secure onboarding form through Content Snare, an online platform we use to request and receive client information. You complete the form and upload the requested documents directly through that platform.
We also use Content Snare to verify your identity, either by:
- collecting a copy of your identity document (such as your driver’s licence); or
- completing an electronic identity verification check through the platform, where this is required to meet our obligations under Australian anti-money laundering and counter-terrorism financing (AML/CTF) laws.
We may also collect personal information from you by email, over the phone, or in person during meetings.
If we collect personal information about you from someone else, for example, from another member of your family group, from your business partner, or from a previous accountant, we will take reasonable steps to let you know we have done so.
Who we may share your information with
We may disclose your personal information, including your name, date of birth, residential and postal address, and tax file number, to the following government agencies, so that we can act on your behalf:
- the Australian Transaction Reports and Analysis Centre (AUSTRAC), where we are required to make a report or provide information under the AML/CTF Act;
- third-party service providers who assist us with our AML/CTF obligations, including electronic identity verification, and the secure collection and storage of client information;
- the Australian Taxation Office (ATO), for the purpose of preparing and lodging tax returns, business activity statements and other required forms, and communicating with the ATO about your tax affairs; and
- the Australian Securities and Investments Commission (ASIC), for the purpose of company registrations, annual reviews, and lodging company and officeholder details.
We do not sell your personal information, and we do not disclose it for marketing purposes.
We may also disclose your information where you have asked us to (for example, to your bank, financial planner or solicitor), or where we are required or authorised to do so by law.
What happens if we cannot collect your information
If you do not provide us with your personal information, we may not be able to verify your identity and provide you (or the person you are acting on behalf of) with the services you have requested.
How long we keep your information
We are required under the AML/CTF Act to keep records of the information and documents we collect for customer due diligence for seven years after our relationship with you ends. We may hold some information for longer where other laws require it.
Your privacy rights and our privacy policy
Our Privacy Policy contains further information about how we will handle your personal information and how you can access and correct your personal information. It also outlines how to lodge a complaint and how that complaint will be managed if you are concerned about how we handled your information. You can read our Privacy Policy above, or request a copy from us at any time by contacting our office.
How to contact us about your privacy
If you have any questions about this notice, want to access or correct the personal information we hold about you, or wish to make a complaint about how we have handled your information, you can contact us:
Email: tax@marzolholloway.com.au
Phone: 07 5593 3555
Post: PO Box 848, ROBINA DC QLD 4226
We will acknowledge your enquiry or complaint within 5 business days and aim to respond in full within 30 days.
If you are not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or by calling 1300 363 992.