2 The information RCB Advisors collects
RCB Advisors collects and uses personal information in an open and transparent way by complying with the Australian Privacy Principles, as established by the Privacy Act 1988 (Cth).
As a provider of accounting, tax, business advisory and wealth management services, we collect and hold information about our clients, associates of our clients and our business contacts that is both relevant and necessary in order for us to provide those services. The types of information we hold depends on the services provided or required to be provided. We may also collect personal information from our staff, directors and shareholders as required by law. When we collect your personal information we will, where reasonably necessary and practicable, tell you why the information is collected, who it will be shared with, and inform you of the consequences if all or part of the information is not provided to us.
3 Personal Information
Personal information is any information that could identify you or be used to establish your identity. Examples of personal information that may be collected by us include, but are not limited to, your:
- name and address;
- marital status;
- date and place of birth;
- employment details including history;
- education history;
- bank account details;
- any shareholdings or investments;
- visas, work permits and citizenship documents;
- details of your family including spouse, parents and children;
- medical reports including medical history;
- financial reports including tax returns and related registration numbers e.g. Tax File Number etc.;
- previous insurance history. We will only collect personal information that is necessary for legitimate business functions, including providing the services you have requested. We may collect personal information via various means including during personal meetings with you, over the phone, via email, snail mail or survey that you decide to participate in, through the contact us page or by direct mail out. On occasion, and in order to provide the service/s you have requested, we may have to obtain information about you from others in circumstances such as helping you to make a claim under your insurance policy – for example, your employer where they are our client, from your legal/personal representative or from a publicly available record. The people providing this information in these circumstances are also regulated by the Privacy Act. Where we collect information from a third party about you we will, where reasonably necessary in the circumstances, ensure you are aware of the circumstances surrounding the collection of that information. On occasion, we may need to collect and use sensitive information necessary to provide our services, such as when we assist you with applications for some insurance products. We may also collect sensitive information that includes information or an opinion relating to a person’s racial or ethnic origin, political views or memberships, religious beliefs or affiliations, membership of a professional or trade association or trade union, sexual orientation or practices and criminal record. This includes information about a person’s health and medical history.
4 Information about other people you may provide to us
5 Unsolicited personal information
If we are provided unsolicited personal information that we know or suspect could have been collected from you, we will ensure it is protected and treated as if we had solicited the information. Any unsolicited information that we do not believe is reasonably necessary for the functioning of our business or the provision of our services, and is not of the type or content normally collected by us for the purposes of providing our services, will be destroyed or de-identified as soon as possible, unless it is unreasonable or unlawful to do so.
6 Use and disclosure of information
RCB Advisors complies with the Australian Privacy Principles, which set out restrictions about the way sensitive information can be used.
We do not sell, trade, or rent your personal information to others.
Unless you give us your consent, or if we are required or permitted by law, we will only use or disclose personal or sensitive information for the main purposes for which it was provided.
From time to time we may share your personal information with other entities outside of RCB Advisors in order to meet our operational and legal obligations. The entities that we might share your personal information with may include:
- third party specialist advisors we engage to provide services or engage as part of the engagement with you;
- our service providers;
- our professional advisors;
- credit reporting or reference agencies or insurance investigators;
- insurers and credit providers;
- courts, tribunals and other dispute resolution bodies as required as part of a dispute;
- anyone authorised by you or to whom you have provided your consent (either expressly or impliedly), including but not limited to other wealth management services providers that we may need to deal with on your behalf;
- anyone/anybody to whom we are required or authorised by law to disclose your personal information. This may include, but is not limited to, any law enforcement agencies, national and international government and regulatory authorities, the Australian Taxation Office, the Australian Prudential Regulation Authority, the Australian Securities and Investments Commission or any international taxation department; and
- any financial services institutions necessitated to detect, investigate or prevent actual or potential fraud in connection with the products or services we provide to you. We do not disclose personal information to third parties for the purpose of them sending marketing material to you, unless it is with your express and fully informed consent. However, on occasions, we may share non personal, de-identified or aggregated information to them for research or promotional purposes.
7 Disclosure of information to overseas service providers
In order to manage our work efficiently and improve our processes, we may need to share information with service providers which may be located in, or have operations in, other countries. The current list of countries to which your personal information could be sent is set out below:
Where we do share your personal information with any external organisations for the purpose of providing our services, we will take reasonable steps to ensure those organisations comply with the Australian Privacy Principles or a similar applicable law regarding that information.
8 Security of personal information
We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
We hold the information collected from you initially in a working file, which when completed is either archived or electronically imaged and stored.
We take reasonable steps to ensure that your information is safe by protecting it from unauthorised access, modification and disclosure. We maintain physical security over our paper and electronic data and premises by using locks and security systems. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to computer systems. Your information is stored securely in a password protected off-site facility operated in the United States of America and is accessible only by RCB Advisors and their representatives.
9 Access to or correction of information held by RCB Advisors
We take reasonable steps to maintain the reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. You are entitled to access the personal information RCB Advisors holds on your behalf by request, except in circumstances where that access may be refused under the Privacy Act. We reserve the right to determine the manner in which the information is accessed.
Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate, irrelevant, out of date or incomplete.
If you wish to access or correct your personal information, please write to our Privacy Officer:
P O Box 439
Camberwell VIC 3124
We do not charge for receiving a request for access to personal information or for complying with a correction request. However, we reserve the right to charge you a reasonable administration fee for giving access to the requested information in accordance with the Privacy Act.
In some limited cases, in accordance with the Privacy Act, we may need to refuse access to your information or refuse a request for correction. We will advise you as soon as possible after your request if this is the case and the reasons for our refusal. Generally, refusal of access will only occur where it is permitted under the Australian Privacy Principles or is otherwise lawful.
10 RCB Advisors’ Website
Anonymous data – We use technology to collect anonymous information about the use of our website. For example, when you browse our website our service provider logs your server address, the date and time of your visit, the pages and links accessed and the type of browser used. It does not identify you personally and we only use this information for statistical purposes and to improve the content and function of our website so as to better understand our clients and markets and to improve our service.
Cookies – In order to collect this anonymous data we may use “cookies”. Cookies are small text files which are sent to your browser and stored on your computer’s hard drive on your first visit. This is purely to increase the function of the site. Most browsers provide you with an option to refuse or accept these cookies. Cookies alone cannot be used to discover the identity of the user and do not damage your computer. You can set your browser to notify you when you receive a cookie so that you can decide if you want to accept it. Once you leave the site, the cookie is destroyed and no personal or other information about you is stored except the domain visited, time spent and/or website address from which you accessed our website/article. This is done purely for statistical purposes and to improve our website.
Links to third party sites – Our website may contain links to other third party websites. We do not endorse or otherwise accept responsibility for the content or privacy practices of those websites or any products or services offered on them. We suggest that you check these websites’ privacy policies to find out how they may collect and deal with your personal information.
Forms – Our website allows visitors to submit information via self-service forms (Contact us) or in relation to any specific request including employment. The information submitted via the forms is not encrypted and is sent to our offices via email. This information is stored on a database that is accessible by RCB Advisors staff only (password protected). Should you be concerned about confidentiality of the information being submitted, we would suggest you contact the office directly instead.
11 Direct Marketing
We may also use your information to send your requested product information and promotional material and to enable us to manage your ongoing requirements, eg renewals, client surveys etc.
We may occasionally notify you about new services and special offers, events or articles we think will be of interest to you. We may send you regular updates by email or by post. If you would rather not receive this information or do not wish to receive it electronically, email or write to us.
12 Opt Out
If we send you any information about services or products, or you do not want us to disclose your personal information to any other organisation (including related bodies corporate) you can opt out by email, in writing to us, by telephone to our office or in case of an electronic medium, by unsubscribing.
13 Lodging a complaint
- In writing: PO Box 439, Camberwell VIC, 3124
- By telephone: +61 (0) 3 9882 0533
- By email: firstname.lastname@example.orgWe will respond to your query or complaint as soon as possible and will try to resolve any complaint within 14 working days. If this is not possible, we will contact you within that time to let you know how long we estimate that it will take to resolve your complaint. If we cannot satisfactorily resolve your concerns, you may contact the Privacy Commissioner in writing: Privacy Commissioner
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001Tel: 1300 363 992