Open and Transparent Management of Personal Information

Slomoi Immerman Partners is committed to providing high quality professional services whilst also protecting the privacy of our current, prospective and past clients, contacts and employees. Slomoi Partners abides by the Australian Privacy Principles established under the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and the Privacy Act 1988.

For the purposes of this policy, “personal information” is information from which identity is apparent or can be reasonably ascertained.  This Privacy Policy sets out our approach with respect to the way in which we obtain, hold, maintain, use and disclose information about clients and/or other business contacts and employees. Slomoi Partners aims to manage personal information in an open and transparent way.

Anonymity and Pseudonymity

When dealing with Slomoi Immerman Partners, individuals have the option of not identifying themselves or may use a fictitious name. It is important to note however that due to the nature of our business it is generally impractical for us to deal with individuals on an anonymous basis or through the use of a pseudonym. However, if identification is not required by Slomoi Immerman Partners, individuals may request that we deal with them anonymously or by using a pseudonym.

Collection of Personal and Sensitive Information

In order to provide a service, we often require personal information. Slomoi Immerman Partners collects personal information from prospective and current clients, employees, contractors and other individuals that is reasonably necessary for business purposes.

Slomoi Immerman Partners collects personal information voluntarily provided:

• By the completion of forms
• Over the phone
• Through a facsimile
• By sending an email
• By sending us information via the ‘contact us’ or ‘online application’ pages on our website
• Through a third party such as a recruitment agency
• Through publicly available sources such as websites

Types of personal information collected may include:

Name and contact details including address, email, phone number
Date of birth and gender
Bank account details
Details of current financial circumstances including assets and liabilities, income, expenditure, investments, insurance cover and superannuation
Government identifiers such as Tax File Numbers and Australian Business Numbers
Documentation used for identification and verification purposes
Education details and employment history through CVs and reference checks

Slomoi Immerman Partners rarely needs to collect sensitive information (such as health, ethnicity, and membership of professional associations) and will only do so when reasonably necessary and with the relevant individual’s express consent.

Clients, contacts and candidates are not obliged to provide personal information. However, if the choice is made not to provide Slomoi Partners with personal information, Slomoi Immerman Partners may be unable to provide the services requested or assess whether one is suitable for a position.

Slomoi Immerman Partners uses Google Analytics to track information on visitors to our website and the content that they are reading. This allows us to make better decisions about the services that you are most interested in. Whilst statistics are collected on the number and activity of visitors to this website, no personal identifying data is included. All activity falls within the bounds of the Google Analytics Terms of Service.

Dealing with Unsolicited Personal Information

Unsolicited personal information is personal information Slomoi Immerman Partners has received but taken no active steps to collect the information. When Slomoi Immerman Partners receives unsolicited personal information that we know could have been collected from an individual, we will afford that information the same privacy protection as if we had solicited it. If the information is not reasonably necessary for one or more of Slomoi Immerman Partners business functions or activities, we will aim to destroy or de-identify the information as soon as practicable unless it is unlawful or unreasonable to do so.

Notification of Collection

Where Slomoi Immerman Partners collects personal information, we will take reasonable steps to notify the individual of certain matters regarding the collection including:

• The purpose and circumstances surrounding the collection
• Slomoi Immerman Partners usual disclosures of information of this kind
• Whether Slomoi Partners is likely to disclose the information to overseas recipients
• Whether the information is required or authorised by law
• The consequences if personal information is not collected
• Access to Slomoi Immerman Partners Policy

Slomoi Immerman Partners will endeavour to collect personal information directly from an individual however there may be times where collection of personal information is required from a third party and when this occurs the individual will be informed.

Use and Disclosure of Personal Information

With regards to our current, past and prospective clients, Slomoi Immerman Partners uses personal information of and incidental to supplying our services as requested by our clients. With regards to candidates, we use personal information to assess suitability against a vacant position. With regards to employment, we maintain this information on file in the HR department for reference as/when it is required throughout the duration of employment with Slomoi Partners and beyond.

The main purposes for the collection of personal information include:

• To provide accounting services as requested and required
• To maintain contact with clients
• Keep clients informed of industry developments, service offerings and events
• For general management and reporting purposes such as invoicing
• For recruitment
• For employment

Slomoi Immerman Partners will only use or disclose information for the primary purpose for which it was collected unless; i) it would be reasonably expected for us to use and disclose the information for a secondary purpose and/or ii) consent has been obtained to use the information for an additional purpose.

Given the provision of service to clients, Slomoi Immerman Partners may disclose personal information in the below circumstances as required:

• To insurers, suppliers, the Australian Tax Office, the Australian Securities and Investments Commission and other government bodies where relevant to enable the provision of services as requested by clients.
• To certain bodies, as and if required by law. For example, to comply with credit report obligations, tax legislation, employment legislation and any other relevant body of legislation applicable to our business as chartered accounting advisors.
• Of or incidental to the sale of our business to a third party.
• Where we outsource duties, including enforcing the terms and conditions of our engagement with an external service provider for purposes of rendering the required services is granted.
• In order to service family groups and/or a company where there are two or more directors. Unless consent is otherwise withheld, information will be divulged to the authorised client representative.

Clients must inform their relevant Director should there be a change in personal circumstances that may impact our approach to client service and the disclosure of personal information.

Slomoi Immerman Partners will not sell or trade any personal information to any third party without consent.

Direct Marketing

Slomoi Immerman Partners may store personal information on a database and use it to market related services, provide clients with educative information and information regarding Slomoi Immerman Partners events. Slomoi Immerman Partners will only use or disclose personal information for marketing purposes if the individual has consented or has a reasonable expectation that their personal information will be used for such a purpose. However, on each communication, we will give contacts the opportunity to elect not to receive further marketing information.

Cross Border Disclosure

Slomoi Immerman Partners may transfer or store personal information to recipients overseas. Slomoi Immerman Partners may need to do this of or incidental to the services Slomoi Immerman Partners provides. Any such transfer does not alter our commitment to safeguard personal information and if there are no suitable privacy protection laws in the country of the recipient, Slomoi Immerman Partners will take all reasonable steps to make arrangements that provide for privacy protection of your personal information.

Adoption, Use or Disclosure of Government Related Identifiers

Slomoi Immerman Partners will not adopt, use or disclose government agency identifiers such as tax file numbers as our primary means of identifying individuals unless required or authorised by or under Australian law or a court/tribunal order.

Quality of Personal Information

Slomoi Immerman Partners will take reasonable steps to ensure that personal information it collects, uses and/or discloses is accurate, up-to-date and complete. We encourage all individuals to contact their relevant Director, the Marketing Manager or HR should they become aware or believe that any personal information we hold is inaccurate, incomplete or out of date.

Security

Slomoi Immerman Partners takes reasonable steps to protect personal information it holds from misuse, interference and loss, and from unauthorised access, modification or disclosure. Slomoi Immerman Partners has controls and procedures to ensure that Personal Information provided remains confidential. All employees are made aware of Slomoi Immerman Partners’ privacy procedures and are bound by strict duties of confidentiality to clients and to Slomoi Immerman Partners.

Candidates’ personal information may be held for up to six months, after which time it may be archived or destroyed. If an applicant is unsuccessful, Slomoi Immerman Partners may seek consent from the candidate to reconsider the applicant against suitable future vacancies and allows the candidate the right of response.

All other personal information is usually held indefinitely. Tax and other records are only kept as long as is required by law. Destruction of all personal information is completed in a secure manner to protect privacy.

All client personal information is stored on a database. The Slomoi Immerman Partners’ server is equipped with “firewall” software, which prevents unauthorised access to company systems, and protects any personal information, which is submitted via email.

Whilst Slomoi Immerman Partners take all due care and diligence in protecting the security, confidentiality and privacy of the information submitted, we cannot guarantee that systems will be completely free from third party interception or damage to information transmitted by email which is caused by viruses. However, Slomoi Immerman Partners does all it can to prevent security breaches such as regularly updating company security software.

The Slomoi Immerman Partners website may have links to other sites of interest. However, it makes no warranties or representations as to the quality, currency and accuracy of information on any other site to which it provides a link. Slomoi Immerman Partners encourages clients/contacts/employees to view the terms and conditions of use, privacy policies and security statements on those sites.

Access to Personal Information

Clients/contacts/employees may at any time, request in writing access to personal information held by Slomoi Immerman Partners. Slomoi Immerman Partners endeavours to treat all requests for access seriously, promptly and in a confidential manner. Requests to access personal information will not affect existing obligations or affect the commercial arrangements between clients/contacts and Slomoi Immerman Partners or contractual agreement between employees and Slomoi Immerman Partners.

We will provide access by allowing clients/contacts/employees to inspect, take notes of or receive copies or print outs of their personal information held by Slomoi Immerman Partners. Access will only be denied in cases where it is permitted under the Australian Privacy Principles or is otherwise unlawful.

We may choose to provide access to the appropriate parts of the record or by using an appropriate intermediary.

Requests should be made to the relevant Director Slomoi Immerman Partners will take all reasonable steps to provide access as soon as practicable, usually within 21 days of your request, depending on the volume of information that you have requested. To obtain access to personal information we may require proof of identity.

Slomoi Immerman Partners reserves the right to impose fees for the provision of access, including for photocopying, retrieval from off-site premises and sourcing from electronic databases.

Correction of Personal Information

Slomoi Immerman Partners relies on the accuracy of the information provided to us and will take reasonable steps to correct personal information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. Slomoi Immerman Partners will look to correct personal information which it knows to be incorrect and will also respond to requests from clients/contacts/employees to correct personal information held. If a third party is relying on this information, at your request we will also notify them unless it is impractical or unlawful to do so.

Should Slomoi Immerman Partners refuse to make a correction, it will be clearly outlined as to why and complaint mechanisms will be available. If we continue to use this information, you may request us to associate a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.

Privacy Complaints

If a formal complaint is sought to be made, clients/contact/employees should do so in writing to their relevant Director, the Marketing Manager or HR department. All complaints will be recorded appropriately and dealt with in a serious, prompt and confidential manner. The privacy complaint will not affect existing obligations or the commercial arrangements that exist between the client/contact and Slomoi Immerman Partners or Employee and Company.

Slomoi Immerman Partners aims to achieve an effective resolution of any complaint within approximately 30 days or as soon as reasonably practicable after all information requested by Slomoi Immerman Partners is provided.

Should a complainant feel that Slomoi Immerman Partners has not adequately handled a complaint they should forward their concerns to the Office of the Australian Information Commissioner.

Changes to our Privacy Statement

Nothing contained in this Statement is intended to create a contract or agreement. Slomoi Immerman Partners reserves the right to modify or amend this Statement at any time and will endeavour to post any changes on our website including updates and amendments to wording. Slomoi Immerman Partners encourages clients/contacts/employees to review the Policy Statement so that all remain informed regarding how Slomoi Immerman Partners protects personal information.

Slomoi Immerman Partners welcomes questions and comments regarding this Statement by contacting our office on 8376 1600 or admin@www.slomoipartners.com.au.