1. Purpose

FinCare is committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act).

FinCare may modify this Privacy Policy from time to time to reflect its current privacy practices.

2. Scope

This Policy sets out how FinCare handles personal information.  It does not apply to personal information collected by FinCare that is exempted under the Privacy Act, for example, employee records.

3. Definitions

Personal information

Information or an opinion about an identified individual, or an individual who is reasonably identifiable:a)   whether the information or opinion is true or not; and b)   whether the information or opinion is recorded in a material form or not.

Sensitive information

Information or opinion about an individual’s personal characteristics, for example (but not limited to) racial or ethnic origin, political opinion, religious beliefs, health, sexual orientation or criminal record.

4. Policy Statement

4.1 The Personal Information we Collect

The types of personal information we collect depends on the nature of our engagement with you. Examples of personal information we may collect include:

• names, job titles, contact and address details
• information in identification documents (for example: passport or driver’s licence)
• tax file numbers and other government-issued identification numbers
• date of birth and gender
• bank account details, shareholdings and details of investments
• details of superannuation and insurance arrangements
• educational qualifications, employment history, salary and referee reports
• visa or work permit status
• your Internet Protocol (IP) address
• payment details and
• personal information about your spouse and dependants.

It may be necessary in some circumstances for FinCare to collect sensitive information about you in order to provide specific services or for recruiting purposes. Examples of the types of sensitive information that may be collected in such circumstances include ethnic origin, criminal record, and health information.

It is generally not practical to remain anonymous or to use a pseudonym when dealing with FinCare as usually, we need to use your personal information to provide specific services to you, or which relate to or involve you.

4.2  Collecting and Managing Personal Information

4.2.1 How we collect personal information

Generally we collect your personal information from you directly (for example, when we deal with you in person or over the phone, when you send us correspondence (including via email), when you complete a questionnaire, form, or survey, when you subscribe to our publications or when you use our website or our social media).

Sometimes it may be necessary for us to collect your personal information from a third party. For example, we may collect your personal information from your employer where they are our client, from your personal representative, another FinCare entity, or a publicly available record.

We may also collect personal information about you from your use of our websites and information you provide to us through contact mailboxes or through the registration process on our websites.

4.2.2  Where you provide us with personal information about someone else

If you provide us with someone else’s personal information, you should only do so if you have their authority or consent to provide us with that information. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy or any Privacy Collection Statement we give you.

4.2.3 Holding personal information

FinCare holds personal information in hard copy and electronic formats. We take physical and technological security measures to protect the personal information we hold including restriction of physical and virtual access, firewalls, the use of encryption, passwords and digital certificates.

We also have policies and processes which govern document retention and data breach incidents. In some cases, FinCare engages third parties to host electronic data (including data in relation to the services we provide) on our behalf.

4.2.4 Purpose for collecting, holding, using and disclosing personal information

FinCare collects, holds and uses personal information for a number of purposes including:

• to provide and enhance our services
• to respond to requests or queries
• to maintain contact with our clients and other contacts (including alumni), and keep them informed of our services, industry developments, seminars and other events
• to verify your identity
• for administrative purposes, including processing payment transactions
• for recruitment purposes
• for purposes relating to the employment of our personnel, providing internal services or benefits to our partners and staff and for matters relating to the partnership
• when engaging service providers, firms, contractors or suppliers relating to the operation of our business
• to manage any conflict of interest or independence (including auditor independence) obligations or situations
• to conduct surveys
• to seek feedback
• to meet any regulatory obligations
• as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including FinCare’s business) or entering into an alliance, joint venture or referral arrangement or
• to develop our expertise and know-how, for benchmarking purposes, analytics, quality assurance and thought leadership, and other purposes related to our business.

As part of an engagement, if you are a customer, an employee, a contractor or supplier of services to one of our clients, then we may disclose your personal information as part of providing services to that client.

The types of third parties to whom we may disclose your personal information include:

• experts or other third parties contracted as part of an engagement
• our agents, third party contractors and suppliers
• our professional advisers
• other businesses in the FinCare Group (which includes entities they wholly or dominantly own and control)
• third parties as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including FinCare’s business) or to enter into an alliance, joint venture or referral arrangement or
• government or regulatory bodies or agencies, as part of an engagement or otherwise, (for example, the Australian Taxation Office).

We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you. However, we may share non-personal, de-identified or aggregated information with select third parties for research or promotional purposes other than direct marketing.

4.2.5 Disclosure of personal information overseas and sharing personal information amongst and within FinCare entities

In some circumstances, FinCare uses third-party contractors and suppliers to carry out its functions and provide services. These contractors and suppliers are typically located in the Philippines and Vietnam.

Depending on the nature of the engagement or the circumstances of collecting your personal information, we may disclose your personal information to such third-party contractors and suppliers overseas to fulfill the purpose for which the personal information was collected, or a related or ancillary purpose or otherwise in accordance with the Privacy Act.

Appropriate data handling and security arrangements are in place when personal information is disclosed to our third-party contractors and suppliers overseas, and they are required to take physical and technological security measures to protect your personal information.

4.3 Direct Marketing

FinCare may use your personal information for the purpose of marketing its services to you.

If you do not want to receive marketing material from us, you can contact us as detailed below:

• for electronic communications, you can click on the unsubscribe function in communications; or
• email us: brenda@fincare.com.au

4.4 Privacy on our Website

4.4.1 Automatic collection of personal information

Cookies, web beacons and other technologies are used by FinCare on its website and through email to automatically collect certain types of information. The collection of this information allows us to customise your online experience (including tailored FinCare marketing), to improve the performance, usability and effectiveness of FinCare’s online presence and to measure the effectiveness of our marketing activities.

If you register or log into the FinCare website and provide information about your preferences, we may use your information to personalise your user experience. If you register or log into the FinCare website using a third-party account (such as LinkedIn, Google, or Twitter), we may collect any information you have permitted the third party service to share, including your name and email address, depending on the privacy settings you have set with the third party service and their privacy policy.

4.4.2 IP address

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another.

Public IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis and to enhance user experiences.

4.4.3 Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu).

You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our websites’ features.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including public IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends and is not used to identify individual visitors.

4.4.4 Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computers such as an IP address, the time that content was viewed, a browser type, and the existence of cookies previously set by the same server.

FinCare or its service providers may use web beacons to track the effectiveness of third-party websites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

4.4.5 Location-based tools

FinCare may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

4.4.6 Social media widgets and applications

The FinCare website includes the functionality to enable information sharing via third party social media applications, such as the Facebook Like button and Twitter widget.

These social media applications may collect and use information regarding your use of the FinCare website. Any personal information that you provide via such social media applications may be collected and used by members of that social media application separate to FinCare.

Such interactions that are monitored by social media applications are governed by the privacy policies of the relevant companies that provide the applications. We do not have control over, or responsibility for, those companies or their use of your information.

4.4.7 Links to third-party websites

The FinCare website may contain links to third-party websites. Third-party websites are not subject to our privacy policy and procedures. You will need to review those websites to view a copy of the relevant privacy policy.

Unless expressly advised, FinCare does not endorse, approve or recommend the services or products provided on third-party websites.

4.4.8 Your choices

You have several choices regarding your use of the FinCare website. In general, you are not required to provide personal information when you visit our website. However, if you make an inquiry or subscribe to receive information about our services, events and industry updates or wish to apply for a job, the provision of certain personal information will generally be required to facilitate such requests.

4.5 Children

We understand the importance of protecting the privacy of children, especially in an online environment. Our website is not intentionally designed for, or directed at, children under the age of 13.

It is our policy to never knowingly collect or maintain information about any person under the age of 13, except as part of a specific engagement to provide services which necessitates such personal information be collected, for the purposes of ensuring compliance with our auditor independence policies, or as otherwise required by law.

4.6 Gaining Access to Personal Information we Hold

You can request access to your personal information, subject to some limited exceptions as permitted or required by law. Such request must be made in writing to our Office Manager.

FinCare may charge reasonable costs for providing you access to your personal information.

4.7 Keeping Personal Information Current

If you believe that any personal information FinCare has collected about you is inaccurate, not up-to-date, incomplete, irrelevant or misleading, you may request a correction. To do so, please contact our Office Manager and we will take reasonable steps to correct it in accordance with the requirements of the Privacy Act.

4.8 Complaints

If you wish to make a complaint to FinCare about our handling of your personal information, you can contact our Office Manager on +61 2 9542 4655 or via email brenda@fincare.com.au. Following your initial contact, you will be asked to set out the details of your complaint in writing.

FinCare will endeavour to reply to you within 30 days of receipt of the written complaint and, where appropriate, will advise you of the general reasons for the outcome of the complaint.

In some circumstances, FinCare may decline to investigate the complaint (for example if the complaint relates to an act or practice that is not an interference with the privacy of the person making the complaint).

If you are not satisfied with the outcome of your complaint, you can refer your complaint to the Office of the Australian Information Commissioner.

4.9 How to Contact Us

If you have a query in relation to this Privacy Policy, or would like to notify FinCare that you no longer wish to receive marketing material from us, want to access or correct your personal information or would like to make a complaint about FinCare’s handling of your personal information; please contact us at brenda@fincare.com.au

5. Monitoring and Evaluation

This Policy will be reviewed whenever there is a modification to the Privacy Act or Regulations, or every 18 months, whichever occurs sooner.

6. Legislation

Privacy Act 1988 (Cth)