ADX Privacy Policy

Last updated October 2023

We collect personal information in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth.) (the Privacy Act). This Privacy Policy sets out how we handle personal information.

In this Privacy Policy, ‘ADX’, ‘we’, ‘us’ and ‘our’ refer to the ADX Accounting Partnership and includes any entity carrying on business in Australia that is part of the ADX group of entities.

We may update this Privacy Policy from time to time to reflect changes in our current privacy practices or in the law, regulations and/or professional standards. When we make any changes to this Privacy Policy, we will post the updated policy on our website  adx.com.au.

 

1. PERSONAL DATA WE COLLECT

In this privacy notice, “personal data” means any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or an online identifier. Personal data also refers to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of an individual.

The types of personal information we collect depends on the nature of our engagement with you. Data is collected in 2 categories: General Personal Information and Sensitive Personal Information.

General Personal Information examples:

• General identification information such as names, job title, occupation, date of birth and gender.
• Contact details such as address, email address, phone and mobile phone number and Internet Protocol (IP) address.
• Usernames and passwords.
• Educational qualifications, employment history, salary and referee reports.
• Payment details including PAYG Payment Summaries, payslips, and other income earning information, for example payment summaries from your employer and super fund, statements from banks and financial institutions showing interest received, employment termination payment summaries, receipts for gifts, donations and work-related expenses.
• Information contained in identification documents such as passport or driver’s licence.
• Government-issued identification numbers such as tax file numbers.
• Financial information such as credit card and bank account details, shareholdings and details of investments (e.g. if you have shares, units, managed funds or other investments, details of dividend payments and distributions from managed funds, any investment gains or losses from the disposal of shares, units and rental properties, including associated income and expenditure).
• Details of superannuation and insurance arrangements.
• Visa or work permit status and related information.
• Information about immigration status.

We do not generally seek to collect sensitive data as defined below, however in some circumstances it may be necessary for us to collect some forms of sensitive information about you in order to provide specific services to you.

Sensitive Personal Information examples

• A person’s race,
• gender diversity, sexual orientation,
• disability,
• ethnic origin,
• political opinions, membership of a trade union
• health, biometric data, genetic data
• religious or philosophical beliefs
• criminal history.

Note: We will only collect and use sensitive information with your consent, in accordance with applicable laws or in a de-identified aggregated manner.

You might need to provide personal information about other individuals to us (e.g. about your spouse, dependants or other family members or employees). If so, we rely on you to have informed those individuals that you are giving their personal information to us, to have advised them about this Privacy Policy and how they can obtain a copy of it and that you have the necessary authority to provide that personal information to us.

It is important to be aware that if you access another party’s website or application using one of our products or services or via our website, that other party will deal with your personal information in accordance with its own Privacy Policy. You will need to review those websites to view a copy of the relevant Privacy Policy.

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

2.YOUR RIGHTS REGARDING PERSONAL INFORMATION

You have the following rights in relation to your personal data:

• To access the personal data held by ADX about you
• To have your personal data corrected, for example, if it is incomplete or incorrect
• To opt out of receiving marketing communications at any time
• To restrict or object to the processing of personal data or request erasing personal data (in certain circumstances and subject to applicable law)
• To receive a copy of the personal data which you have provided to ADX, in a structured, commonly used and machine-readable format (known as “data portability”) (in certain circumstances and subject to applicable law)
• Where you have provided personal data voluntarily, or otherwise consented to its use, the right to withdraw your consent
• The right to complain to a data protection authority (see section “Complaints”)
• It’s important that you make sure the personal information we hold about you is accurate, up to date and complete. If any of your details change or if you believe that any personal information ADX has collected about you is inaccurate you can contact us (via admin@adx.com.au) and we will take reasonable steps to correct it in accordance with the requirements of the Privacy Act.
• You can request access to your personal information that we hold about you, via admin@adx.com.au. We may charge reasonable costs for providing you access to your personal information.
  
  

3 COLLECTING 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 or when you subscribe to our publications.

Sometimes we will collect your personal information from outside sources. These can include marketing mailing lists and other public information (including public posts to social networking sites such as LinkedIn and Twitter) and commercially available personal, identity, geographic and demographic information. Outside sources may also include information gained from a third party. For example, we may collect your personal information from:

• your employer or previous employer
• your referees
• your personal representatives
• a financial advisor, and/or
• where you have authorised disclosure to us, from banks, or
• where you have applied for a job, from other persons, such as law enforcement agencies, the Department of Home Affairs, education or other institutions or professional organisations.

We may also collect personal information about you from your use of our websites and social media and information you provide to us through contact mailboxes.

4. HOW WE STORE AND HOLD PERSONAL INFORMATION

We hold personal information in both hard copy and electronic formats. We may transfer or disclose the personal data we collect to external support providers. We engage third parties to host electronic data (including data in relation to the services we provide) on our behalf.

It is our policy to only use third-party support providers that are bound to maintain appropriate levels of data protection, security and confidentiality, and that comply with any applicable legal requirements for transferring personal data. We take security measures to protect the personal information we hold which includes physical controls (for example, storage of physical records in lockable cabinets) as well as technological controls (for example, restriction of access, firewalls, the use of encryption, passwords and digital certificates).

We also have policies and processes which govern document retention and data breach incidents. We endeavour to ensure that personal information is kept as current as possible, and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. However, some personal information may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.

5. HOW DO WE USE YOUR PERSONAL INFORMATION

We will only use your information if we have a lawful reason to do so such as when it’s our legal duty or if we have your consent. Such as:

• To provide our services to you in accordance with the terms of any engagement letter, service agreement or employment agreement including any related reasons such as payroll, tax, superannuation and accounting services.
• To provide, improve and properly manage our products and services including:
  • responding to requests or queries,
  • verifying your identity,
• To maintain contact with you, and keep you informed of our services, industry developments, seminars and other events.
• For administrative purposes, including:
  • processing payment transactions,
  • charging and billing,
  • detecting or preventing fraud, and
  • identifying breaches of our terms and conditions of engagement.
• For governance and compliance purposes including:
  • managing any quality, conduct or risk management issues including conflict of interest or independence (including auditor independence) obligations or situations,
  • meeting regulatory obligations, and
  • where we are required to or authorised by legislation or industry code, direction or standard to do so.
• For business purposes such as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business or entering into an alliance, joint venture or referral arrangement.
• For development and analytics purposes to develop our expertise and know how.

We may also use non-personal, de-identified and aggregated information for several purposes including for data analytics, research, submissions and promotional purposes. Any output is anonymised or aggregated so that no personal information or information relating specifically to you is reasonably identifiable.

ADX may also use your personal information for the purpose of marketing its services to you. This may include products, services and offers provided by our partners. 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;
• for hard copy communications, you can email UNSUBSCRIBE or
• through direct contact admin@adx.com.au
  
  

6. SHARING PERSONAL INFORMATION

We may share your personal information with other parties including:

• Your authorised representatives, advisors and referees,
• Personnel within ADX and our professional advisors,
• Experts or other third parties contracted as part of an engagement,
• Our agents, third party contractors and suppliers that assist us with providing our business processes and products and services,
• Nominated superannuation funds,
• Third parties as part of an actual or proposed acquisition, disposition, merger or de-merger of a business or to enter into an alliance, joint venture or referral arrangement,
• Other parties including government or regulatory bodies (for example, the Australian Taxation Office, the Australian Securities Investment Commission and The Department of Home Affairs), professional or industry bodies or agencies, as part of an engagement or as required by or in accordance with any industry code or industry standard including foreign authorities or regulators relevant or applicable for the purposes of our provision of services, or
• Other parties when you ask us to do so or when you consent to that disclosure.

Where 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.

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, development, analytics or promotional purposes other than direct marketing.

7. VISITING OUR WEBSITE AND ONLINE
   

7.1 Automatic collection of personal information

Together with our service providers we use cookies, web beacons and other technologies on some of our websites and through email to automatically collect certain types of information. The collection of this information allows us to customise and personalise your online experience (including tailoring our online presence) and enhancing your future online experience. We may also use this information for development and analytics purposes. You can tailor your experience with these technologies via the privacy and browser settings on your device or by rejecting the associated cookies.

7.2 Analytics Tools

We use analytics tools, such as Google Analytics and Adobe Analytics. To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. More information about how we use Google Analytics can be found at https://www.google.com/analytics/terms/us.html.

Adobe also provides a range of opt-out options for Adobe Analytics.

7.3 Social media widgets and applications

Some of our websites and services may include 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 our websites. 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 us and are subject to 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.

Any personal information that you provide on any ADX social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

8. CHILDREN

We understand the importance of protecting the privacy of children, especially in an online environment. In particular, our websites, products and services are not intentionally designed for, or directed at, children under the age of 16.

It is our policy to never knowingly collect or maintain information about any person under the age of 16, except as part of a specific engagement to provide services which necessitates such personal information be collected, for example, for the purposes of ensuring compliance with our auditor independence policies, or as otherwise required by law.