- how and when Pilot Partners collects personal information;
- how Pilot Partners uses and discloses personal information;
- how we keep personal information secure, accurate and up-to-date;
- how an individual can access and correct their personal information; and
- how Pilot Partners will facilitate or resolve a privacy complaint.
If you have any concerns or complaints about the manner in which your personal information has been collected, used or disclosed by us, we have put in place an effective mechanism and procedure for you to contact us so that we can attempt to resolve the issue or complaint. Please see paragraph 11 for further details.
We can be e-mailed at email@example.com or write to us at PO Box 7095 Brisbane Qld 4001 and our privacy officer will then attempt to resolve the issue.
We recommend that you keep this information for future reference.
1. What is personal information?
The Privacy Act 1988 (Cth) defines “personal information” to mean information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is reasonably identifiable, from the information or opinion.
2. Sensitive Information
2.1. What is Sensitive Information?
- Sensitive information is a subset of personal information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
- In general, we attempt to limit the collection of sensitive information we may collect from you, but depending on the uses you make of our products this may not always be possible and we may collect sensitive information from you in order to carry out the services provided to you. However, we do not collect sensitive information from you without your consent.
- The type of sensitive information we may collect from you or record about you is dependent on the services provided to you by Pilot Partners and will be limited to the purpose(s) for which it is collected. We do not use sensitive information to send you Direct Marketing Communications (as defined in paragraph 7 below) without your express consent.
2.2. Consent to collection of certain types of sensitive information
We may collect certain types of sensitive information where you have consented and agree to the collection of such information.
Generally speaking, we will obtain this type of consent from you at (or around) the point in time in which we collect the information, but the main type of sensitive information that we may collect (if any) will usually relate to:
- the criminal record of an individual, should you apply for a position with Pilot Partners; and
- the health or medical information about an individual, should you be employed by Pilot Partners,
but only to the extent that where you volunteer such information or if it is necessary for, or incidental to, the purposes of collection set out in paragraph 4.
3. Collection of your personal information
3.1. We only collect personal information that is necessary for what we do and we hold the personal information we collect within our own data storage devices or with a third party provider of data storage. The type of information we may collect from you includes depends ultimately upon the purpose of collection.
3.2. The type of information we may collect from you includes (but is not limited to) the following:
- your contact information such as full name (first and last), e-mail address, current postal address, delivery address (if different to postal address) and phone numbers;
- details relating to your employment (if applicable) or your previous employment, which shall include, but is not limited to, obtaining your tax file number, superannuation details and, if necessary, confirmation of your right to work in Australia;
- details relating to your education, if applicable;
- your date of birth and proof of your date of birth (including, but not limited to, driver’s licence, passport, birth certificate);
- your income and financial information, including but not limited to any bank account details, personal assets, investments, liabilities, child support details, taxable deductions and other related expenses, whether related to your personal income or any companies you may be associated or involved with, or otherwise;
- any other financial information including but not limited to previous tax returns, financial and bank statements, valuation reports (whether for property, personal items or otherwise), whether related to your personal income or any companies you may be associated or involved with, or otherwise;
- any sensitive personal information listed in paragraph 2.2;
- your opinions, statements and endorsements collected personally or via surveys and questionnaires, including but not limited to your views on the products and services offered by Pilot Partners; and
- if you are requesting products or services from us or we are purchasing goods or services from you, then any relevant payment or billing information (including but not limited to bank account details, direct debit, credit card details, billing address, repayment information and invoice details).
- we have collected this information from publically available sources;
- we have taken reasonable steps to ensure the organisation who has provided us with this information has complied with the Australian Privacy Principles; or
- as otherwise required by law.
3.4. When you engage in certain activities, such as entering a contest or promotion, filling out a survey or sending us feedback, we may ask you to provide certain information. It is completely optional for you to engage in these activities.
3.5. Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory data or any other information we require in order for us to provide our services to you, we may be unable to effectively provide our services to you.
3.6. If you use our website, we may utilise “cookies” which enable us to monitor traffic patterns and to serve you more efficiently if you revisit our website. A cookie does not identify you personally but may identify your internet service provider or computer. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance.
3.7. We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.
4.Our Insolvency Services
4.1. In the event we are engaged to provide our insolvency services to you or any companies you may be associated or involved with, we will be required to comply with the provisions of the Privacy Act in addition to other relevant Australian law or, if applicable, a court or tribunal order.
4.2. When acting in the capacity of an administrator, receiver, trustee or liquidator (or similar) (Insolvency Services), we are permitted to:
- collect personal information about you, either directly from you or, in some circumstances without notice to you, from any other relevant third parties (such as creditors);
- use that personal information and to disclose that personal information to relevant third parties (such as creditors),
in the manner permitted by, or in order to comply with our obligations under, Australian law.
4.3. Personal information about you or any companies you may be associated or involved with, may be collected from, without limitation, personal or company records or any proof of debt forms which are completed by a creditor. The information collected as a result of our Insolvency Services will be used for the purposes of the liquidation, administration or scheme of arrangement and will be disclosed to the relevant authorities and third parties, such as other creditors or as a result of a public notice in relation to the bankruptcy, liquidation or administration.
5. How we may use and disclose your personal information
5.1. We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to and/or as set out below.
5.2. You consent to us using and disclosing your personal information to facilitate a purpose in connection with:
- if required, the verification of your identity;
- the verification of your date of birth, if applicable;
- reference checks relating to the employment or potential employment with Pilot Partners, whether as a contractor, employee or otherwise;
- the provision of our services to you
- the verification of any information you have provided us, including in the provision of our professional services to you, including but not limited to accounting, financial advisory, insolvency, administration and corporate advisory services;
- the administration and management of our services, including billing, credit card authorisation and verification, checks for financial standing, credit-worthiness (including but not limited to undertaking an assessment for credit loss and obtaining credit references, if applicable), fraud and collecting debts;
- reference checks from third parties, which shall include but is not limited to financial credit checks and other checks as referred to in paragraph 5.2(f) and personal financial credit checks;
- reporting to external administrators, creditors, shareholders or stakeholders, if applicable;
- any statutory reporting requirements to the Institute of Chartered Accountants, Australian Securities & Investments Commission and the Australian Financial Service Authority; and
- to offer you updates, or other content or products, services and events that may be of interest to you;
- to facilitate the administration and management of Pilot Partners, including but not limited to:
- the use of your personal information collected in accordance with paragraph 3.1 in the administration and management of Pilot Partners;
- any statutory reporting requirements to the Institute of Chartered Accountants. Australian Securities & Investments Commission and the Australian Financial Service Authority;
- any reporting requirements to Nexia International Group, of which we are a member;
- the improvement of our services (including to contact you about those improvements and asking you to participate in surveys about our products and services);
- the maintenance and development of our products and services, business systems and infrastructure;
- marketing and promotional activities by us and our related bodies (including by direct mail, telemarketing, email, SMS and MMS messages) such as our customer loyalty programs and newsletters;
- to provide customer service functions, including handling customer enquiries and complaints;
- our compliance with applicable laws;
- the sale, and matters in connection with a potential sale, of our business or company to a third party; and
- any other matters reasonably necessary to continue to provide our products and services to you.
5.3. We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:
- when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose;
- if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
- if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
- if it is required or authorised by law.
5.4. In the event we propose to use or disclose such personal information other than for reasons in 5.1, 5.2, and 5.3 above, we will first seek your consent prior to such disclosure or use.
5.5. If you have received communications from us and you no longer wish to receive those sorts of communications, you should contact us via the details set out at the top of this document and we will ensure the relevant communication ceases.
6.The types of organisations to which we may disclose your personal information
6.1. We may disclose your personal information to organisations outside of Pilot Partners. Examples of organisations and/or parties that your personal information may be provided to include:
- offshore service providers, if any;
- related entities and subsidiaries of Pilot Partners, including but not limited to the Nexia International Group, of whom we are a member;
- our accounting and insurance partner Accounting Insurance Pty Ltd;
- third parties, such as the Institute of Chartered Accountants. Australian Securities & Investments Commission and the Australian Financial Security Authority;
- third parties such as external administrators, creditors, shareholders or stakeholders, if applicable; and
- our contractors and agents, including but not limited to our IT service provider, third party data and file sharing facilities, financial information storage facilities and other companies who assist us in providing our products and services to you.
7. Direct Marketing
7.1. You expressly consent to us using your personal information, including any email address you give to us, to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) (Direct Marketing Communications) which we consider may be of interest to you.
7.2. Without limitation clause 7.1, if it is within your reasonable expectations that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.
7.3. If at any time you do not wish to receive any further Direct Marketing Communications from us, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the email or by contacting us via the details set out at the top of this document.
8.Cross Border Disclosure
8.1. Any personal information provided to Pilot Partners may be transferred to, and stored at, a destination outside Australia, including but not limited to the United States of America, Ireland, Japan, Singapore and Sao Paolo where we may utilise overseas website data and file sharing facilities to assist Pilot Partners with providing our goods and services to you. Personal information may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.
8.4. If you do not agree to the transfer of your personal information outside Australia, please contact us by via the details set out at the top of this document.
9.Data quality and security
9.1. We have taken steps to help ensure your personal information is safe. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information, especially where the Internet is involved.
9.2. Notwithstanding the above, we will take reasonable steps to:
- make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
- protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
- destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.
9.3. However, the accuracy of personal information depends largely on the information you provide to us, so we recommend that you:
- let us know if there are any errors in your personal information; and
- keep us up-to-date with changes to your personal information (such as your name or address).
10. Access to and correction of your personal information
10.1. You are entitled to have access to any personal information relating to you which we possess, except in some exceptional circumstances provided by law. You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.
10.2. If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out at the top of this document.
11. Resolving Privacy Complaints
11.1. We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.
11.2. If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information, please contact us by:
Telephone: 07 3023 1300
Post: PO Box 7095, Brisbane Qld 4001
11.3. Please mark your correspondence to the attention of the Privacy Officer.
11.4. In order to resolve a complaint, we:
- will liaise with you to identify and define the nature and cause of the complaint;
- may request that you provide the details of the complaint in writing;
- will keep you informed of the likely time within which we will respond to your complaint; and
- will inform you of the legislative basis (if any) of our decision in resolving such complaint
11.5. We will keep a record of the complaint and any action taken in a Register of Complaints.