Jewell Moore is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information. We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act), which govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.
1. What is Personal Information and Why Do We Collect It?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, phone and facsimile numbers, and financial information.
This Personal Information is obtained in many ways including interviews, correspondence, by telephone and facsimile, by email, via our website www.jewellmoore.com.au, from your website, from media and publications, from other publicly available sources, and from third parties. We do not guarantee website links or the policies of authorised third parties.
We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
2. Anonymity and Pseudonymity
Where practicable, you may deal with us anonymously or by pseudonym. However, in most circumstances the nature of our professional services requires us to collect and use your true identity. If it is lawful and practicable to do so, we will give you the option of not identifying yourself when interacting with us.
3. Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record, or health information.
Sensitive information will be used by us only:
- For the primary purpose for which it was obtained;
- For a secondary purpose that is directly related to the primary purpose;
- With your consent; or
- Where required or authorised by law.
4. Third Parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances it may be unreasonable or impracticable to do so, and we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
5. Direct Marketing
We may use your Personal Information to send you information about our services and promotions that may be of interest to you. We will not use your sensitive information for direct marketing without your explicit consent.
You may opt out of receiving direct marketing communications from us at any time by contacting us in writing. We will action your request within a reasonable time. If you request to know the source of information we hold about you for direct marketing purposes, we will provide this information where it is reasonable and practicable to do so.
6. Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances including the following:
- To third parties where you consent to the use or disclosure;
- To other Jewell Moore member firms (Jewell Moore ABN 66 095 054 728, Jewell Moore Assurance Pty Ltd ABN 70 654 856 827, and Jewell Moore International Ltd) where staff from those firms are involved in delivering services to you;
- To service providers and software platforms used in delivering our services (see Section 7 below); and
- Where required or authorised by law.
7. Overseas Disclosure of Personal Information
In the course of providing our services, your Personal Information may be disclosed to overseas recipients. This occurs in the following circumstances:
- Cloud storage and backup: While we endeavour to use providers with Australian-based servers, many cloud providers maintain backup infrastructure in other countries (including but not limited to the United States, United Kingdom, and European Union). Your information may be included in such backups.
- Software and service providers: We use third-party platforms that may store or process data outside Australia, including Dext (servers located in Australia and the United Kingdom), and others as notified from time to time in our engagement terms.
- Jewell Moore International Ltd: As a member firm of the Jewell Moore group, staff of Jewell Moore International Ltd may access your information in the course of providing services to you.
Before disclosing your Personal Information to an overseas recipient, we take reasonable steps to ensure the overseas recipient does not breach the APPs in relation to that information. Where you have accepted our engagement terms, you have acknowledged that your Personal Information may be stored or processed overseas, and as a consequence we are required to take reasonable steps to ensure Australian Privacy Principles are complied with by those overseas recipients.
If we are unable to ensure that an overseas recipient will comply with the APPs, we will not disclose your information to that recipient without first obtaining your express consent.
8. Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure. We employ reasonable security measures including access controls, encrypted communications, and secure storage systems.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify it as soon as practicable. However, most Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years in accordance with our professional and legal obligations.
9. Notifiable Data Breaches
We are subject to the Notifiable Data Breaches (NDB) scheme under the Privacy Act. In the event of a data breach that is likely to result in serious harm to any individual whose Personal Information is involved, we will:
- Notify the Office of the Australian Information Commissioner (OAIC); and
- Notify all affected individuals as soon as practicable.
Our notification will include the nature of the breach, the kinds of information involved, and the steps we recommend you take in response. We will also take immediate steps to contain the breach and prevent further harm.
10. Website and Cookies
Our website at www.jewellmoore.com.au may use cookies and similar tracking technologies to improve your browsing experience. Cookies are small files stored on your device that help us understand how visitors use our site. You can configure your browser to refuse cookies, though this may affect the functionality of our website.
Our website may collect technical information such as your IP address, browser type, and pages visited. This information is used for website administration and analytics and is not linked to your Personal Information unless you have provided it to us.
11. Access to Your Personal Information
You may access the Personal Information we hold about you and request that it be updated and/or corrected, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing using the details at the end of this policy.
Jewell Moore will not charge a fee for making an access request, but may charge a reasonable administrative fee for providing a copy of your Personal Information. We will respond to your access request within 30 days of receipt.
In order to protect your Personal Information we may require you to verify your identity before releasing the requested information.
We may refuse access in certain circumstances, including where granting access would pose a serious threat to the life, health or safety of any individual, or would have an unreasonable impact on the privacy of others. If we refuse access, we will provide written notice of our reasons and the mechanisms available to you to complain about the refusal.
12. Correction of Your Personal Information
It is important to us that your Personal Information is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
If you request a correction, we will respond within 30 days and, if the information is corrected, notify any third parties to whom we have previously disclosed the information where it is reasonable to do so.
If we refuse to correct your Personal Information, we will provide written notice of our reasons and advise you of your right to lodge a complaint with the OAIC. You may also request that we attach a statement to the information noting that you consider it to be inaccurate, incomplete, out of date, irrelevant, or misleading.
13. Policy Updates
This Policy may change from time to time and is available on our website. We encourage you to review this Policy periodically.
14. Privacy Policy Complaints and Enquiries
If you have any queries or complaints about our Privacy Policy please contact us at:
- Address: 1 Shore Place, 25–31 Shore Street West, Cleveland QLD 4163
- Email: [email protected]
- Phone: 07 3821 4401
Upon receiving a complaint, we will acknowledge receipt, investigate the complaint thoroughly and in good faith, provide a written response within 30 days, and advise you of the outcome and any steps taken to address your concern.
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by calling 1300 363 992.