Over 25 years experience across many industries

Our Privacy Policy

Last Revised: February 2018

Introduction

Tilbrook Rasheed Pty Ltd and those entities controlled by Tilbrook Rasheed Pty Ltd, being Tilbrook Rasheed Services Pty Ltd, TR Financial Services Pty Ltd, Tilbrook Rasheed Audit Services Pty Ltd and Tilbrook Rasheed (together, ‘Tilbrook Rasheed’ ‘TR’) (referred to below as “we,” “us,” and “our”) respect and are committed to protecting your privacy and handling personal, sensitive and special categories of information in an open and transparent way.

This Policy outlines the obligations TR has in managing the personal information we hold about our clients, potential clients, contractors and others, in order to comply with the Privacy Act. The Privacy Act does not apply to acts or practices that are directly related to employee records of current or former employees. In summary, ‘personal information’ is information or an opinion relating to an individual which can be used to identify that individual.

We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles set out in that Act. We also maintain an internal privacy policy, engagement letters and standard terms and conditions governing the delivery of professional services which also describe how we handle personal, sensitive and special categories of information.By providing your personal information to TR you are agreeing to bound by our Privacy Policy. If you have any questions or concerns regarding this privacy statement, please contact the Privacy Officer using the contact details below.

Collection

The main types of information we may collect and hold includes (but is not limited to) personal information about:

  • clients, business associates and potential clients and their employees
  • suppliers and their employees
  • prospective employees
  • contractors, and
  • other people who come into contact with us.

We may also collect sensitive and special categories of personal information directly from clients to provide professional services. The types of special categories of personal and sensitive information that we may collect includes, but is not limited to, tax file numbers, health records, information regarding racial or ethnic origins, criminal convictions, and membership of a political association or membership of a trade union.

Sensitive and special category information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or where certain other limited circumstances apply (e.g. where required by law).

In some instances it may be necessary to collect personal, sensitive and special categories of information from clients that relates to their employees, members, customers, third parties their spouse and dependants to provide professional services. In those circumstances we rely on clients to only provide us with information that they have handled in accordance with the Privacy Act, including obtaining any necessary consent for TR to collect, use and disclose that information.

We may also collect personal information from suppliers, contractors and third party service providers to operate our business such as contact details and account details.

We may also collect personal information that is publicly available.

As a provider of accounting, business and taxation advisory services we are subject to certain legislative and regulatory requirements which necessitate us obtaining and holding detailed information which personally identifies you and/or contains information or an opinion about you.

In general, the main types of personal information we collect and hold includes (but is not limited to):

  • Names
  • Contact Details
  • Genders
  • Dates of Birth
  • Employment Details and Employment History
  • Tax File Numbers
  • Details of your financial circumstances, including bank account details, your assets and liabilities (both actual and potential), income, expenditure, insurance cover and superannuation
  • Health information (for some types of insurance cover)
  • Details of your investment preferences and aversion or tolerance to risk (if a wealth advisory client).

We collect personal information in a number of different ways, for example:

  • directly via face to face meetings or over the phone
  • through correspondence with us or when you subscribe electronically to our publications
  • you provide it to us via business cards
  • a third party provides it to us, for example, a report provided by a medical professional, fund manager, superannuation and other product issuer, or
  • reference from another person, your personal representative or a publicly available record.

You have the right to make general enquires about the services we provide, while remaining anonymous and therefore provide either little or no personal information, however without the personal information we request we will be unlikely to be able to provide our services to you.

You have a right to refuse us authorisation to collect information from a third party.

From time to time you may provide us with someone else’s personal information, e.g. other members of your family group. You must not do this unless you have their consent to do so. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy.

There may be times when we receive personal information that we do not solicit. If this occurs we will determine if you have given your consent and the information is necessary for us to provide our services, or whether the collection is required or authorised by or under an Australian law or a court/tribunal order. If it is, the information will be dealt with in accordance with the Australian Privacy Principles as if the information had been solicited. If it is determined that we should not have obtained this information, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.

Website Collection

As a visitor to our website www.trca.com.au, you do not have to submit any personal information in order to use it. This website only collects personal information that is specifically and voluntarily provided by visitors. We may collect personal information from the web site through receiving subscription applications and emails. We may from time to time also use third parties to analyse traffic at our web site, which may involve the use of cookies. Cookies are primarily used to enhance the website capability.

Much of the information we collect is statistical and not personally identifiable.

Our website may also show links to third party websites who are not subject to our privacy policies and procedures. If you use these links you will need to review those websites directly to view a copy of their privacy policies.

Use

We use personal, sensitive and special categories of information to provide agreed services to our clients and to operate our business, and all purposes related to the agreed services. We will only use your information for the purposes for which it was collected for, if this use would be reasonably expected by you, or otherwise, with your consent.

We may also use personal information to send promotional materials, or communications regarding services provided by us that we feel may be of interest. We may also seek feedback on our services or for market or other research purposes.

Personal information may also be used to protect our rights and that of our users and, where appropriate, to comply with legal process.

Disclosure

In the delivery of professional services we may disclose personal, sensitive and special categories of information to other organisations where they are providing related services. Where this is to occur, and where possible, we may seek prior approval to do so.

TR may also be required to disclose personal and sensitive information to law enforcement, regulatory, or other government agencies, or to other third parties, to comply with legal or regulatory obligations or requests.

Information provided to third parties will be dealt with in accordance with that entity’s privacy policy.

It may be necessary, in certain limited situations, in order to perform our services to send your personal information to recipients such as third party software providers who outsource elements of their services to external service providers outside of Australia, in the United States, Singapore, India, the Philippines, New Zealand and other countries. In this case we will take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to the information.

Information Security

We have in place reasonable commercial standards of technology and operational security to protect all information provided from misuse, unauthorized access, disclosure, alteration, or destruction for example by use of physical security and restricted access to electronic records, firewalls, the use of encryption, passwords and digital certificates.

Our employees are required to respect the confidentiality of personal information and the privacy of individuals, and privacy and data protection training is undertaken. All employees are required to read this policy and understand their obligations in regard to personal information.

Holding Personal Information

We hold personal, sensitive and special categories of information in hard copy and electronic formats. We have in place reasonable commercial standards of technology and operational security to protect the information we hold.

Access

You may access your personal, sensitive and special categories of information, which we hold, and seek to correct that information where necessary. Your access to this information is subject to the exceptions set out in the Privacy Act.

These exceptions would include where:

  • it is a frivolous or vexatious request
  • information relates to a commercially sensitive decision making process
  • access is unlawful
  • information would prejudice enforcement activities relating to criminal activities and other breaches of law, or
  • denial of access is required or authorised by or under law.

If access is denied we will explain the reason why it is denied.

To request access to or correct your personal information, you can contact TR’s Privacy Team (privacy@trca.com.au). We will require you to verify your identity and to specify what information you require. A reasonable fee may be charged for providing access.

Changes to our Privacy Statement

We may modify or amend this privacy statement from time to time as required, and at our discretion, and may be supplemented or amended by privacy statements that are specific to certain areas of this website (e.g. recruitment, social media etc). When we make changes to this statement, we will amend the revision date at the top of this page. You will be notified of any amendments to this Privacy Policy by posting an updated version to our website and accordingly we encourage you to periodically review our website and our policy to be informed about how we are protecting your information.

Children’s Privacy Protection

We understand the importance of protecting children’s privacy in the interactive online world. This website is not designed for or intentionally targeted at children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.

Questions

If you have any questions or concerns regarding your privacy, or you would like to make a comment on the effectiveness of this policy, please direct them to the Privacy Officer at:

Privacy Officer
Tilbrook Rasheed Pty Ltd
GPO Box 1243
ADELAIDE SA 5001
Phone: +61 (08) 8378 9500
Fax: +61 (08) 8378 9599
privacy@trca.com.au

For all other enquiries, please contact us at:

Tilbrook Rasheed Pty Ltd
GPO Box 1243
ADELAIDE SA 5001

If you believe that the Privacy Officer has not adequately handled your query or issue, you may complain to the Complaints Officer whose contact details are as follows:

Complaints Officer
Quality & Risk
Tilbrook Rasheed Pty Ltd
GPO Box 1243
ADELAIDE SA 5001
Phone: +61 (08) 8378 9500
Fax: +61 (08) 8378 9599
complaints@trca.com.au

If you believe that Tilbrook Rasheed has not adequately handled your privacy complaint, you may complain to the Office of the Australian Information Commissioner whose contact details are as follows:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
1300 363 992
enquiries@oaic.gov.au

Additional Information

For further information about privacy and the protection of privacy, visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.

Policy Review

Annual Review: February 2019