Privacy Policy

Effective Date: 19 November 2024

Sinclair Wilson (referred to as “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, store, and disclose your personal information in compliance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the Notifiable Data Breach (NDB) scheme.

1. What Information We Collect

Personal information means information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.

We may collect the following types of personal information:

  • Personal details: Name, address, date of birth, and contact information (phone number, email address).
  • Financial details: Tax File Numbers (TFN), bank account details, superannuation information, and other financial data.
  • Business information: ABN, financial statements, and records related to your business operations.
  • Other information: Details related to interactions with our services, such as preferences or feedback, or online interactions that may include IP address, device details or identifiers, and usage and location data.

We may also collect sensitive information (e.g., health information related to taxation purposes) with your consent or as required by law.

2. How We Collect Your Information

We collect personal information directly from you through:

  • Forms you complete (online or physical).
  • Website, online services, or social media.
  • Emails, phone calls, or face-to-face meetings.
  • Documents provided for accounting or taxation purposes.
  • Third parties, such as financial institutions or government bodies, when authorised by you.

3. Unsolicited Information

If we receive personal information about you that we did not request or were not expecting, we will:

  • Determine whether the information is relevant and necessary for our business purposes and can be retained in compliance with the Privacy Act 1988 (Cth).
  • If the information is not relevant or cannot be retained, we will securely destroy or de-identify it as soon as practicable.

We will handle all unsolicited information in accordance with our obligations under the Australian Privacy Principles (APPs).

4. Why We Collect Your Information

We collect and use your personal information for the following purposes:

  • Providing accounting, taxation, and advisory services.
  • Meeting our legal and regulatory obligations.
  • Communicating with you regarding our services.
  • Improving our services and responding to feedback.
  • Direct marketing of our services (see Section 5).

Anonymity and pseudonymity

You may wish to deal with us anonymously, however, this is likely to limit the services we provide to you as our principal business relates to the provision of financial services (and in most cases, the provision of personal advice) which would require individuals to provide personal information. We are also required under Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) to conduct customer due diligence and appropriately identify clients.

5. Direct Marketing

We may use your personal information to send you marketing communications about our services, industry updates, and other information that we believe may be relevant to you.

  • Opting Out: If you do not wish to receive marketing communications from us, you can opt out at any time by:
    • Clicking the “unsubscribe” link in marketing emails.
    • Contacting us directly using the details provided in Section 14.
    • Ticking the opt out box in the Sinclair Wilson Engagement Terms and Conditions
  • Third-Party Marketing: We will not disclose your personal information to third parties (non-Sinclair Wilson related entities) for their own marketing purposes without your explicit consent.

Your privacy is our priority, and we will ensure that all marketing activities comply with the Spam Act 2003 (Cth) and other relevant laws.

6. Disclosure of Your Information

We may disclose your personal information to:

  • Government and regulatory bodies, such as the Australian Taxation Office (ATO).
  • Third-party service providers, such as cloud storage services or our service providers including auditors, under strict confidentiality agreements.
  • Sinclair Wilson related entities: To ensure efficient service delivery, we may disclose your personal information between Sinclair Wilson related entities, where relevant and necessary for providing our services.
  • Your authorised representatives or advisers.
  • Other parties as required by law or with your consent.

We will never sell your personal information.

7. Storage and Security

We take reasonable steps to ensure the security of your personal information, including:

  • Using secure servers and encrypted data storage.
  • Limiting access to authorised personnel only.
  • Regularly reviewing and updating our security measures.

If personal information is no longer required, we will securely destroy or de-identify it in accordance with our legal obligations.

8. Notifiable Data Breach Scheme

We comply with the Notifiable Data Breach (NDB) scheme under the Privacy Act 1988 (Cth).

In the event of a data breach that is likely to result in serious harm to an individual:

  • We will assess the nature and impact of the breach as soon as possible.
  • If the breach meets the threshold for notification, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC).
  • Our notification will include details about the breach, the potential impact, and steps you can take to protect yourself.

If you suspect or are concerned about a potential data breach involving your information, please contact us immediately using the details in Section 14.

9. Access to and Correction of Personal Information

You have the right to:

  • Access your personal information.
  • Request corrections to ensure it is accurate, complete, and up-to-date.

To make a request, contact us using the details provided in Section 14. We may require verification of your identity before granting access.

10. Use of Cookies and Online Tools

Our website may use cookies and similar tools to enhance user experience. Cookies help us analyse website traffic and improve our online services. You can manage cookie preferences through your browser settings. Please refer to aboutcookies.org

Sinclair Wilson (including its related entities) is the sole owner of the information collected on the Sinclair Wilson website. We are not necessarily aware of, nor are responsible for, differences in privacy statements of external websites linked to or from ours. Please refer to aboutcookies.org for further information.

11. Cross-Border Data Transfers

In some cases, your personal information may be stored or processed overseas (e.g., by our service providers including third-party cloud storage providers). We will take reasonable attempts to ensure any overseas recipients maintain appropriate data security and comply with the APPs or equivalent standards.

12. Complaints and Concerns

If you believe we have breached your privacy or the APPs, you can lodge a complaint by:

  • Contacting our Privacy Officer using the details below.
  • Providing details about your concerns.

We will investigate your complaint and respond within 30 days. If you are not satisfied, you may escalate the matter to the Office of the Australian Information Commissioner (OAIC).

13. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The latest version will always be available on our website.

14. Contact Us

If you have any questions, requests, or complaints about this Privacy Policy, please contact us:

Privacy Officer
Sinclair Wilson
Phone: 03 5564 0555

Email: privacy@sinclairwilson.com.au

By engaging and using our services, you acknowledge that you have read and understood this Privacy Policy.