Purpose
LBW Business + Wealth Advisors (LBW) recognises the importance of privacy in respect to personal information. LBW is committed to handling personal information in accordance with the Australian Privacy Principals (APPs) detailed in the Privacy Act 1988 (Cth).
This policy describes for clients, employees of client and potential clients how LBW manages personal information. It relates to LBW’s collection and handling of personal information covered by the Privacy Act. It is not intended to cover categories of personal information not covered by the Privacy Act.
Relevant legislation
The services that LBW provide are governed by legislation, this includes:
- Taxation Administration Act 1953 (Cth)
- Corporations Act 2001
- Tax Agent Services Act 2009
- Tax Agent Services Regulations 2009
- Bi-laws of Institute of Chartered Accountants
- Bi-laws of CPA Australia
The kinds of personal information we collect
LBW collects a range of personal information to ensure that we provide high quality, professional advice. This information will be collected for the primary purpose of conducting professional advice. This may include:
- Personal identification details including your name, date of birth and gender
- Personal information about your spouse and/or dependants
- Contact details include postal and residential addresses, telephone and email
- Tax File Numbers and other government-issued identifiers
- Employment details and related history
- Details of investments, bank accounts and shareholdings
- Details of superannuation and insurance
It may also be necessary under certain circumstances for LBW to collect sensitive information to provide specific advice. This may include information such as health information, professional qualifications or memberships.
Should you elect not to provide this information it may limit the extent or range of services that LBW can provide. LBW usually needs to use your personal information to provide specific advice therefore it is generally not practical to remain anonymous or to use a pseudonym when dealing with LBW.
How we collect and hold personal information
In most cases LBW will collect your personal information directly from you. This may be face to face, via written correspondence (including email), over the phone or when you complete a form, survey, contact us on our website or subscribe to an LBW publication.
In some cases LBW may collect personal information from an authorised third party such as your employer where they are the client or from your personal representative.
LBW takes measures to protect the security and confidentiality of the personal information we hold – both hard copy information and electronic (soft) form.
This includes physical measures such as alarmed and monitored offices with access passes for staff only, secure storage of physical files and technology security measures such as passwords, restriction of accesses, firewalls, encryption and digital certificates to protect electronic information.
The purpose for collecting, holding, using & disclosing personal information
LBW collects, holds and uses personal information to enable us to conduct professional services. More specifically this may include:
- To maintain contact with our clients and associates
- To inform clients and associates of LBW’s services and industry developments
- To respond to queries or requests
- To conduct surveys and/or seek feedback
- For compliance with regulatory requirements
- For general management and reporting or business related purposes
- Engaging service providers, contractors or suppliers
LBW does not routinely disclose personal information to other organisations unless:
- Required by law
- Use or disclosure is permitted by this policy
- It is necessary to provide professional advice which you have requested
- You give your consent
We may also use the personal information you provide for the purpose of providing you with marketing material such as newsletters or articles that we believe may be of interest to you. However you may request not to receive such information by contacting our Privacy Officer.
We may share non-personal, de-identified and aggregated information for research or promotional purposes. We do not however, disclose personal information to third parties for the purpose of allowing them to send marketing material to you.
The types of third parties to who we may disclose personal information to include:
- Our service providers
- Our professional advisers
- As part of providing agreed services
- Government or regulatory bodies or agencies (for example the Australian Taxation Office)
Access to personal information
Individuals may, at any time, request access to personal information that LBW holds about them. We will provide you with access to this information on request, except in the limited circumstances it is permitted for us to withhold this information; for example, where granting access would infringe on another person’s privacy.
You will be required to provide some form of identification so we can verify that you are the person the information pertains to. For example, this may be your driver’s licence if making the request face to face or if over the phone or email, you may be asked to provide your full name, date of birth and address.
LBW may charge reasonable costs for providing such information.
Keeping personal information up to date
LBW will take reasonable steps to ensure that the personal information we hold about you is accurate, up to date and complete. This may include asking you to confirm details such as an entity name, your role/title, your business or residential address, your email address and other personal details required to provide professional services to you.
If you believe that we hold information about you that is incorrect or is out of date please contact us as soon as possible to update or correct that information.
Disclosure of personal information to overseas recipients
LBW may store, process or back-up some of your personal information on servers that are located overseas including through third party service providers. These servers are commonly located in the United States, Canada, Singapore, Malaysia, India, the Philippines, and New Zealand.
If we are required to transact with, or send information on your behalf to an overseas organisation for any other reason we will seek your consent.
Privacy on our website
This policy also applies to personal information we collect via our website www.lbwca.com.au. The types of personal information that we collect from you will depend on how you use our website.
We look at the number of unique site visitors, ‘hits’ the website receives and keep track of the domains from which our website is accessed. To determine what our users are interested in, we may also look at the frequency of search words used in connecting you to this website.
If you log onto our website and read or download information our Internet Service Provider will record your server address, domain name, the date and time of your visit and the pages you viewed and information downloaded.
We do not collect or use any personal information on visitors to our website, through the use of “cookies” or other software or hardware techniques.
A registered user of the LBW Client Portal is identified by their unique user name and password when they log in. The information we collect is for measuring site performance and in assisting to resolve service and technical difficulties.
To provide relevant and useful information the website may contain links to other websites, external to our website. It is the responsibility of the user to make their own decision about the accuracy, currency and reliability of information contained in linked external websites. LBW is not responsible for the privacy practices of those sites. Nor is a link to a non-LBW website an express or implied endorsement, promotion or warranty of the product or services offered by or accessible through that site.
Contacting the Privacy Officer if you have concerns
If you have concerns about how we are handling your personal information please contact us and we will try to resolve those concerns.
Ongoing concerns or issues relating to our privacy practices will be treated seriously and we will endeavour to address such matter promptly. Should you have concerns relating to this privacy policy please contact our Privacy Officer, in writing, via our online contact form or PO Box 4115, Geelong 3220.
If you are not satisfied with the outcome you may refer the matter to the Office of the Australian Information Commissioner.