1. Purpose and Scope
- We treat your personal information with care, transparency, and respect.
- This policy explains the types of personal information we collect, how it is used, stored, disclosed, and your rights.
- It is designed to reflect the Australian Privacy Principles under the Privacy Act 1988. See OAIC’s guide.
2. What Information We Collect
We may collect:
- Contact details: name, address, phone, email.
- Identification: documentation that allows us to satisfy the identification and verification obligations with the Anti-Money Laundering and Counter-Terrorism Financial Legislation.
- Financial & tax data: tax file numbers (TFNs), income, assets, business/company details, bank details.
- Company secretarial info: company registration details, director/shareholder records.
- Other relevant info: employee, supplier, or contractor information as needed.
This aligns with APP 3’s requirement to collect only what is necessary.
3. How We Collect Information
- Directly from you via forms, emails, meetings, and calls.
- Indirectly, e.g., from your nominated representatives and previous/current service providers (with your consent).
- Unsolicited information: If we receive information we did not ask for, we will assess whether it could lawfully be retained; otherwise it will be destroyed or de-identified promptly, in line with APP 4.
4. Why We Collect & Use It
We collect information to:
- Fulfil our business functions to provide products or services to you.
- Communicate regulatory changes or service updates.
- Meet legal and regulatory obligations.
- Support record-keeping, internal administration, and litigation or defence, if needed.
- Protect our business and other clients from fraudulent or unlawful activity.
- Manage any legal actions involving us.
- Help us improve the products and services offered to our clients and enhance our overall business.
Use and disclosure align with APP 6: only for purposes you would reasonably expect or with your consent.
5. Notification at Time of Collection
When we collect personal information, we will notify you of:
- Our identity and how to contact us.
- The purpose of collection.
- The recipient(s) or types of recipients.
- Whether providing it is optional or mandatory.
- Any consequences of refusal.
- Whether the information will be disclosed overseas (see section 7).
This is required by APP 5.
6. Direct Marketing
We will only use your information for marketing purposes (e.g. newsletters, offers) if:
- You have consented, or
- It is within your reasonable expectations and you are given a chance to opt-out.
This ensures compliance with APP 7.
7. Cross-Border Disclosure
We may store or process data overseas (e.g., cloud services like Xero, Google, etc.).
Where this occurs, we will:
- Seek your consent, or
- Ensure the overseas recipient provides similar protection to the APPs.
This aligns with APP 8 obligations.
8. Government-Related Identifiers
We will only collect or use identifiers like TFNs where specifically authorised by law. Any use will respect APP 9 requirements.
TFNs are treated with the highest confidentiality and in accordance with the Privacy (Tax File Number) Rule 2015 (“TFN Rule”) and the Australian Privacy Principles (APPs).
We follow guidance from the Tax Practitioners Board (TPB) Practice Note (PN) 4/2021, which addresses the use and disclosure of client TFN and TFN information in email communications.
9. Data Quality & Security
- We will take reasonable steps to ensure information is accurate, complete, up-to-date, and not misleading—APP 10.
- We protect information using physical, technical, and organisational measures—passwords, locked storage, secure digital systems.
10. Access and Correction
You may request access to or correction of your personal information. We will respond within a reasonable timeframe and in a reasonable format, per APP 12 and APP 13.
11. Complaints & Breaches
If you believe we have breached this policy or the APPs:
- Contact us at admin@jdadvisory.com.au with your concerns.
- We will investigate and attempt to resolve within 30 days.
- If unsatisfied, you may complain to the Office of the Australian Information Commissioner (OAIC).
12. Policy Availability & Updates
- This policy is available free of charge on our website and can be provided in another form upon request.
- We regularly review and may update it as needed—e.g., due to legislative change (like potential Privacy Act reforms or Notifiable Data Breach requirements).
- The current version is dated 1/08/2025.