Virtue Private Advisory Pty Ltd is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.
Our commitment to safeguarding your personal information
The Privacy Act includes a set of 13 harmonised privacy principles that regulate the handling of personal information by Australian and Norfolk Island Government agencies and some private sector organisations. These principles are called the Australian Privacy Principles (APPs). They replace both the Information Privacy Principles (IPPs) that applied to Australian Government agencies and the National Privacy Principles (NPPs) that applied to some private sector organisations.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au.
What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include names, addresses, and contact details such as telephone number and email address, details of your interests in or ownership of entities or control of trusts, and accounting information, such as your tax file number, bank account details, credit card details and details of your investments.
We will only collect information relating to your tax file number for purposes authorised by law. You are not obliged to provide your tax file number to us but if you fail to do so, we may be unable to provide you with the best possible service.
This Personal Information is obtained in many ways including client interviews, correspondence, by telephone, by email, via our website, from your website (where applicable), from media and publications, from other publicly available sources, from cookies and from third parties. We cannot guarantee website links or policy of authorised third parties.
We collect your Personal Information for the primary purpose of providing our services to you, including:
in administering our Website;
in order to enable your access to our Website services;
to perform due diligence and conflict checks prior to agreeing to provide services to you;
to send you marketing communications;
for customer relationship management purposes and to supply to you the services which you have requested;
to send you statements and invoices and collect payments from you;
for recruitment purposes;
to analyse client needs and improve the services we provide;
for audit, regulatory and compliance purposes;
for industry accreditation purposes;
for accounting and administrative purposes (including to process transactions, provide accounting services, facilitate our internal business operations and comply with our legal or regulatory obligations); and
for other purposes related to our provision of business advisory services to you.
We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
Where you provide us with personal information of third parties (including that of your spouse, other family members, directors and employees, where relevant) you warrant to us that the relevant individuals have consented to you disclosing their personal information to us.
We will not collect personal information by unlawful means or means that are unfair or intrude to an unreasonable extent upon your personal affairs.
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. The kinds of sensitive information we may collect from you can include (but is not limited to) your tax file number, medical history or affiliations. We will only collect sensitive information in circumstances where you have consented to the collection and if the information is reasonably necessary for us to provide our services.
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties, including banks and advisers. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Your information may be held in cloud- based servers located in Australia and abroad. Your information may also be accessible to our contractors, agents, affiliates and service providers located in India and the Philippines via external access.
You agree to such cross-border transfers of your personal information.
Virtue Private Advisory Pty Ltd also uses software and tools for storing and sharing your information to other affiliated offices, third party service providers, contractors or agents. This can include, but is not limited to, the use of internal search engines, electronic file transfer systems and online payment facilities.
Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances including the following:
• Third parties where you consent to the use or disclosure; and
• Where required or authorised by law.
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
We have a strong emphasis on the security of your information. Virtue Private Advisory Pty Ltd has security measures designed to protect against the loss, misuse and/ or alteration of the information under its control. These security measures include:
Firewalls – to prevent the hacking of our database.
Clauses in employment agreements requiring confidentiality.
Non-disclosure agreements with third parties.
Appropriate security access to our business premises.
Security bins for the disposal of written information.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 5 years.
Access to your Personal Information
You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
We will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information. In order to protect your Personal Information we may require identification from you before releasing the requested information.
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
This Policy may change from time to time and where changes are made they will be published on our website.
The Privacy Officer
Virtue Private Advisory Pty Ltd
PO Box 701
Williamstown VIC 3016
Virtue Private Advisory Pty Ltd will, within fourteen days, respond to you and attempt to resolve with you your issues as they pertain to your personal information.
If you are still unsatisfied, you may wish to direct your complaint to the Office of the Australian Information Commissioner at www.oaic.gov.au/or alternatively:
By telephone: 1300 363 992
In writing: The Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001