TJD Accounting Services Pty. Ltd.

This Policy applies to TJD Accounting Services and covers all operations and functions of this organisation. We recognise the importance of ensuring the confidentiality and security of your personal information and we are committed to treating the personal information we collect and manage in accordance with Australian Privacy Principles (‘APPs’), the Credit Reporting Privacy Code (‘the Code’) and the Privacy Act 1988 (‘Privacy Act’).  This Policy also outlines a number of TJD Accounting Services practices, procedures and systems that ensure compliance with the Privacy Act, APPs and the Code.
In this Privacy Policy:
• ‘Disclosure’ of information means providing information to persons outside TJD Accounting Services;
• ‘Individual’ means any persons whose personal information we collect, use or disclose;
• ‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual;
• ‘Sensitive information’ is personal information that includes information relating to a person’s racial or ethnic origin, political opinions, religion, professional or trade association membership, and criminal record, also including health information; and
• ‘Use’ of information means use of information within TJD Accounting Services
WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We may collect and hold various forms of personal information about individuals, including:
• name;
• address;
• phone numbers;
• email addresses;
• occupation;
• bank account details;
• drivers’ licence details;
• other information that is relevant to the services that we provide.
HOW WE COLLECT PERSONAL INFORMATION
We generally collect your personal information by the following methods:
• directly from client forms, questionnaires and other forms you complete when you use our services or apply for a position with us;
• from information disclosed to us by you on the phone, or by sending us correspondence (including letters, faxes and emails) or visiting us in person;
• from a variety of third party sources, including our business contacts, identity verification service providers, financial institutions and fund recipients.
The above list is not exhaustive.
In some instances, we may be provided with personal information about you from a third party. When provided with personal information from a third party, we will take reasonable steps to ensure that you are or have been made aware of the matters set out in this Privacy Policy.
TJD Accounting Services will not collect sensitive information unless the individual has consented or an exemption under the APPs applies. These exceptions include if the collection is required or authorised by law or deemed necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
If personal information requested is not provided by an individual, we may not be able to provide you with the benefit of our services, or meet your needs appropriately.
TJD Accounting Services does not give individuals the option of dealing with them anonymously, or under a pseudonym. It is impractical, and in some circumstances illegal for TJD Accounting Services to deal with individuals who are not identified.
UNSOLICITED PERSONAL INFORMATION
At times we receive personal information about you when we have taken no active steps to collect such information. This is known as ‘unsolicited’ personal information. We destroy all unsolicited personal information unless the personal information is relevant to TJD Accounting Services purposes for collecting personal information.
WHO DO WE COLLECT PERSONAL INFORMATION ABOUT?
Personal information collected and held includes (but is not limited to) personal information about:
• clients;
• potential clients;
• service providers or suppliers;
• prospective employees, employees and contractors; and
• other third parties with whom we come into contact.
WEBSITE COLLECTION
We collect personal information from our web site (https.tjdaccounting.com.au) when we receive emails and online forms.  We may also use third parties to analyse traffic at that web site, which may involve the use of cookies. Information collected through such analysis is anonymous.  
WHY DOES TJD ACCOUNTING SERVICES COLLECT AND HOLD PERSONAL INFORMATION?
We may use and disclose the information we collect about you for the following:
• to assist TJD Accounting Services in providing a product or service to you;
• completion of documentation and forms;
• to consider and assess your request for a product or service;
• to protect ourselves, our business and other clients from fraudulent or unlawful activity;
• to conduct our business and perform other management and administration tasks;
• to consider any concerns or complaints an individual may have;
• to manage any legal actions involving TJD Accounting Services;
• to comply with relevant laws, regulations and other legal obligations; and
• to assist us in improving the products and services offered to our clients.
HOW MIGHT WE USE AND DISCLOSE PERSONAL INFORMATION?
TJD Accounting Services may use and disclose personal information for the purposes for which it is collected, for reasonably expected secondary purposes and in other circumstances authorised by the Privacy Act.
We use and disclose personal information for the purposes outlined in section 7. Clients Sensitive information will be used and disclosed only for the purpose it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or where certain other limited circumstances apply (e.g. if required by law).
At time we engage other people to perform services for our business, which may involve that person handling personal information.  In these situations, we forbid that person from using personal information about you except for the specific purpose for which we supply it. We also forbid that person from using your information for purposes of direct marketing their products or services.
In relation to sensitive information held by us, where possible, TJD Accounting Services will attempt to de-identify the information.  We also undertake to take all reasonable steps to delete personal information about you when it is no longer needed.
WHO MIGHT WE DISCLOSE PERSONAL INFORMATION TO?
We may disclose personal information to:
• a related entity of TJD Accounting Services;
• an agent, contractor or service provider  we authorise to carry out our functions and activities, such as our lawyers, financial advisors, debt collectors, advisers or other service providers;
• institutions involved in a transfer or sale of all or part of our assets or business;
• institutions involved in managing payments, including payment merchants and other financial organisations such as banks;
• regulatory bodies, government agencies, law enforcement bodies and courts;
• financial product issuers and credit providers; and
• anyone else to whom the individual enables us to disclose it to or is required by law.
We may also collect personal information from these institutions and individuals, dealing with the information in accordance with this Policy.
We may disclose personal information to credit reporting bodies to comply with our obligations under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (AML/CTF obligations). To comply with our AML/CTF obligations, we may disclose:
• name;
• date of birth; and
• residential address
to credit reporting bodies, in order to verify whether the personal information matches the identification information held by the credit reporting body. We may, upon request, provide you with an alternative method of verification, however, any alternative verification method must also comply with the AML/CTF legislation.

SENDING INFORMATION OVERSEAS
We do not send personal information to recipients outside of Australia without:
• having taken reasonable steps to ensure the recipient doesn’t breach the Act, the APPs and the Credit Reporting Privacy Code;
• the recipient being a part of an information privacy scheme similar to the Privacy Act; or
• the individual has given consent to the disclosure.
If consent has been provided to having your personal information disclosed to an overseas recipient, and the recipient breaches the APPs, we are not accountable for that breach under the Privacy Act, and you will not be able to seek redress under the Privacy Act.
MANAGEMENT OF PERSONAL INFORMATION
TJD Accounting understands the importance around security of personal information related to our clients. We at all times seek to ensure that the personal information collected and held is protected from interpretation, misuse or loss and unapproved access, modification or disclosure. TJD Accounting Services employees must respect the confidentiality of personal information collected.
Personal information is generally held in client files and our computer database. All paper files are stored in secure areas and computer information is protected through the use of access passwords and software protection codes.
In relation to our computer information, we apply the following guidelines:
• data ownership is clearly defined within TJD Accounting Services;
• passwords are routinely checked;
• employees’ access capabilities are altered when they are assigned to a new position;
• restricted employee access to certain sections of the system;
• the system automatically logs and reviews all access attempts;
• only authorised employees are able to update and edit personal information;
• network data is encrypted during transmission;
• TJD Accounting Services has procedures in place for the disposal of personal information
DIRECT MARKETING
TJD Accounting Services does not use personal information in direct marketing, unless:
• it does not include sensitive information;
• it is reasonable to use or disclose the information for the purpose of direct marketing;
• a simple way of withdrawing from direct marketing has been disclosed; and
• you have not requested to withdraw from receiving direct marketing from us.
If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented.  We will not use your credit information for the purposes of direct marketing.
TJD Accounting Services may only use or disclose sensitive information about an individual for the purpose of direct marketing if you have consented to the use or disclosure of the information for that purpose.
You have the right to request to withdraw from direct marketing and we must give effect to the request within a reasonable period of time.

IDENTIFIERS
We will not use client identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own recording purposes, unless one of the exemptions in the Privacy Act applies.  TJD Accounting Services aims to avoid data-matching, (comparing data collected and held for two or more separate purposes in order to identify common features of individuals), to be used in further investigation or action relating to those individuals.
HOW DO WE KEEP PERSONAL INFORMATION ACCURATE AND UP-TO-DATE?
TJD Accounting Services commits to ensuring that personal information collected, used and disclosed is relevant, accurate, complete and up-to-date.
We encourage you to contact us to update your personal information.  If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable time frame.
UPDATES TO THIS POLICY
This Policy will be reviewed on occasion to account for new laws and technology, and changes to operations in our business.
RESPONSIBILITIES
It is the responsibility of management to keep employees and other relevant third parties apprised of the TJD Accounting Services Privacy Policy.  Management must ensure that employees and relevant third parties are made aware of changes to the Privacy Policy.
It is the responsibility of all employees and relevant parties to ensure they understand and comply with this Privacy Policy.
PRIVACY TRAINING
All new employees are provided with access to TJD Accounting Services Privacy Policy.  All employees are provided with opportunities to attend privacy training covering TJD Accounting Services obligations under the Act and the APPs. Employees must ensure that they have read and understand the Privacy policy that could adversely affect TJD Accounting Services and its clients if not properly adhered to.
NON-COMPLIANCE AND DISCIPLINARY ACTIONS
Privacy breaches must be reported to management by employees and third parties. TJD Accounting Services does not accept ignorance as an excuse for non-compliance. Employees and third parties that do not comply with TJD Accounting services Privacy Policy may be subject to disciplinary action.
INCIDENTS/COMPLAINTS HANDLING
TJD Accounting Services adheres to a strict complaints handling process to manage privacy risks and issues.
The complaints process involves:
• identifying (and addressing) any fundamental compliance problems;
• increasing client confidence in TJD Accounting services privacy procedures; and
• building and preserving TJD Accounting Services reputation and business.
Complaint to TJD Accounting Services about the treatment or handling of your personal information can be made to admin@tjdaccounting.com.au.
CONTRACTUAL ARRANGEMENTS WITH THIRD PARTIES
TJD Accounting Services ensures all contractual arrangements with third parties adequately address privacy issues and have read and understood our Privacy Policy.
Third parties are required to implement policies relating to the management of clients personal information in accordance with the Privacy Act.  These policies include:
• Monitoring the collection, use and disclosure of personal and sensitive information;
• de-identifying personal and sensitive information where possible;
• Personal and sensitive information is to be kept secure at all times, with access only by authorised employees or agents of the third parties; and
• Personal and sensitive information is safe guarded by only disclosing to organisations approved by TJD Accounting Services.
INQUIRIES AND COMPLAINTS
If you have queries about our privacy procedures or wish to make a complaint about how we have dealt with your personal information (including credit information) a complaint can be lodged with us by either
• telephoning – 03 9379 4040
• by writing to – TJD Accounting Services 319 Keilor Road, Essendon Vic 3040
• by emailing – admin@tjdaccounting.com.au
WHAT IF I AM NOT SATISFIED WITH THE RESPONSE?
If you are not satisfied with the result of your complaint to TJD Accounting services have the option of referring your complaint to the Office of the Australian Information Commissioner.
• by telephoning – 1300 363 992
• by writing to – Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
• by emailing – enquiries@oaic.gov.au

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