How Trinity Business Consulting Solutions collects, uses, discloses and protects personal information.
This Policy applies in relation to the collection, retention, management, use and disclosure of personal information by Trinity Business Consulting Solutions (ACN [INSERT ACN]), an incorporated business operating in Australia, herein also referred to in this Policy as we, us and our.
Trinity Business Consulting Solutions is committed to respecting the privacy of an individual’s personal information, including personal information relating to our clients, visitors to our website and other members of the public.
In this Policy, personal information generally means information about an identifiable individual, or an individual who is reasonably identifiable, regardless of whether the information or opinion is true or recorded in a material form (for example, a person’s name, address, phone number or bank account number).
If information does not disclose your identity or enable your identity to be ascertained, or if information is not “about” an individual but may incidentally enable an individual to be identified, it will in most cases not be classified as “personal information” and it will not be subject to this Privacy Policy.
Trinity Business Consulting Solutions will comply with the privacy laws applying in Australia where it operates, including the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles established under that Act.
Trinity Business Consulting Solutions may sometimes deal with personal information relying on exemptions under applicable laws, examples of which may include (in relevant circumstances) dealing with employee records, sharing of information with related bodies corporate, and in connection with providing services to relevant authorities. Any permitted handling of personal information under such exemptions will, to the extent of such permission, also be permitted under this Policy.
Trinity Business Consulting Solutions provides professional services to its clients in full compliance with the law, professional standards, ethical duties and codes of conduct. In Australia, for our registered chartered accountant(s), the key governing framework is that of Chartered Accountants Australia and New Zealand (CA ANZ), including APES 110 Code of Ethics for Professional Accountants, as applicable in the Australian jurisdictions in which they are registered to practise.
Rigorous security and data protection protocols ensure that client files and records are maintained separately and matters are conducted separately. There is no disclosure of confidential information relating to the conduct of professional services matters unless:
In the course of conducting our business, we may collect personal information from numerous sources, including clients and potential clients, visitors to our website, business associates, and suppliers of goods and services. For example:
Generally, this is collected directly from the individual; however, sometimes it may be collected from publicly available sources, including social media platforms, information brokers and third parties. For example, in providing us with instructions on a professional matter, a person who is the authorised contact for a client matter may provide us with their own personal information, as well as information in relation to other members of their organisation which may be relevant to the conduct of the matter.
Some information that we collect may, depending on the circumstances, be classifiable as “personal information”. This may in some instances include, for example, names, dates and places of birth, contact details such as phone number, address and email, and banking and credit card details. We may conduct reference checks, and collect superannuation details or family contact details in connection with considering applications for employment or contract roles.
Some information may be “sensitive”, as defined in the Australian Privacy Act 1988 (Cth), such as health information, dietary requirements, details of any disability, details of political or religious affiliations and details of any criminal record. Sensitive information of this nature is only collected with your consent and only to the extent it is directly relevant to a service which we are offering you, subject to certain exceptions described in applicable laws. For example, Australian law permits the collection of personal information, including sensitive information, if the collection is required or authorised by or under an Australian law or a court/tribunal order.
Generally, Trinity Business Consulting Solutions will collect personal information in order to provide services which a client has requested. The personal information collected will generally assist us to provide more accurate advice and a better service.
Trinity Business Consulting Solutions may also use personal information to help identify and inform you about potentially beneficial services which we can provide, to invite you to events such as training sessions and networking events, or to inform you about developments in accountancy and tax laws. We aim to provide information and invitations that we consider to be of interest and relevance to you and your business, and will only use your personal information for this purpose if we have collected such information directly from you and if it is material of a type which you would reasonably expect to receive from us. These contacts may take place by telephone, email and other electronic means.
If you use our services, or if we have any form of business relationship with you, we will assume you consent to receiving direct marketing material. If you do not wish to be contacted for these purposes, please let us know using the contact details provided below. In addition, all marketing materials will include an “unsubscribe” process.
Trinity Business Consulting Solutions may also use personal information for normal business purposes, such as internal accounting and administration, human resources management, risk management, planning, investigating complaints or queries from clients or investors, or in connection with obtaining products and services from other parties.
By voluntarily providing us with information about yourself, you are consenting to our use of that data in the manner described in this Policy.
Depending on the nature of the work which we are undertaking, we may, with our clients’ agreement, instruct local or overseas specialists, such as foreign associates (to assist with obtaining advice or a service or opinion in an overseas jurisdiction), chartered accountants, forensic auditors or investigators, experts, or other relevant agents. In the course of doing this, we may disclose personal information relating to a client or their representatives, to enable the specialist to provide the necessary service, or to determine whether a conflict of interest exists.
In some situations, such as emergencies or where required by law, Trinity Business Consulting Solutions may be required to assist government agencies, such as law enforcement agencies or the Australian Taxation Office, by providing access to certain personal information that we hold.
We may share personal information where permitted by law with third parties including our clients, your employer or place of business, or other service providers, including organisations that assist us by providing archival, auditing, professional advisory (including legal, accounting, financial and business consulting), mailhouse, graphic design, printing, delivery, technology, website, research, banking, payment, customer contact, data processing and security services.
Notwithstanding the foregoing, any transfer of personal information from Australia to any related body corporate located overseas will comply with the requirements of the Australian Privacy Principles with respect to cross-border disclosures.
Your personal information may be transferred overseas or stored overseas for a variety of reasons, including obtaining professional services at a client’s request in relation to an overseas jurisdiction, or disclosure to a government agency administering accounting services in an overseas jurisdiction. Our technology and other service providers may be located overseas or use overseas assets. It is not practical to identify each country to which your personal information may be transferred as part of our normal business operations.
If your personal information is sent to a recipient in a country with data protection laws which are substantially similar to the Australian Privacy Principles, and where there are mechanisms available to you to enforce protection of your personal information under that overseas law, we will not be liable for a breach of the Australian Privacy Principles if your personal information is mishandled in that jurisdiction.
If your personal information is transferred to a jurisdiction which does not have data protection laws as comprehensive as Australia’s, we will take reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the Australian Privacy Principles. Alternatively, we may seek your consent after providing you with all relevant information about data protection laws in the destination jurisdiction.
In some circumstances, the European Union General Data Protection Regulation (GDPR) provides additional protection to individuals located in Europe. Where this is the case, there may be additional rights and remedies available to a person in respect of whom Trinity Business Consulting Solutions holds personal information. If your personal information is being transferred to us from within a Member State of the European Union and without your consent, we will, if requested by the transferring entity, commit to Standard Protection Clauses of the European Commission whereby we undertake to handle your personal information in a manner consistent with European laws.
Irrespective of whether personal information is stored electronically or in hard copy form, Trinity Business Consulting Solutions will take reasonable steps to protect the personal information it holds from misuse, interference and loss, and from unauthorised access, modification or disclosure.
If an individual visits our website to read, browse or download information, our systems may record information such as the date and time of the visit to the website, the pages accessed and any information downloaded. This information is used for statistical, reporting and website administration and maintenance purposes only.
The information about an individual which may be collected by us through the website includes:
Like many websites, our website may use “cookies”, which are small text files that are transferred to a computer’s hard drive through a web browser to enable its systems to recognise an individual’s browser. Cookies may also be used to record non-personal information such as the date, time or duration of a visit, or the pages accessed, for website administration, statistical and maintenance purposes. The default settings of some browsers allow cookies, but users can easily erase cookies from their hard drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of our website may not function fully for users that disallow cookies.
We may engage third-party services from time to time for website monitoring, reporting and analysis purposes, for example Google Analytics. Those services may also use cookies and gather anonymous web usage information through our website. Cookies and the anonymous web usage information referred to above will not be used to identify individuals unless required by law, or where the website is accessed via links in an email that we have sent which specifically refers to the fact that clicking on links from the email may be tracked.
While Trinity Business Consulting Solutions takes great care to protect personal information on its website, unfortunately no data transmission over the internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information sent to us or received from us online. This is particularly true for information sent via email. Once information is received, we will use all reasonable endeavours to ensure its security whilst in our possession. If an individual is concerned about providing sensitive or confidential information online, please contact us by phone or mail.
From time to time, some sections of our website may protect personal information by requiring an individual to use a password. For an individual’s own protection, we require the password to be kept confidential and changed regularly.
Please note that in some emergency or law enforcement situations, government agencies may have the authority to review our web server’s records. Our website may contain links to other sites. We are not responsible for the privacy practices or policies of those sites.
Individuals should be aware that there may be video or other surveillance of lift lobbies and other areas in premises occupied by us. This is predominantly a security precaution and may assist us and others to identify security threats within the premises. Trinity Business Consulting Solutions reserves the right to use the surveillance outputs if it reasonably suspects that an individual may be involved in misconduct or illegal activity. In some instances, this may necessarily involve the identification of individuals who are mere bystanders.
If you wish to seek access to, or to request correction of, any of your personal information held by Trinity Business Consulting Solutions, please contact us at the details below, and provide as much detail as possible about the particular information sought, in order to help retrieve it.
We will deal with your request in a reasonable time — usually within 14 days of receipt of your request. We will not charge you for making such a request, but we may recover from you our reasonable costs incurred in supplying you with access to this information.
In some cases, Trinity Business Consulting Solutions may not be required by law to provide access to, or to correct, personal information, and if that is the case, we will give you reasons for such a decision. If you ask us to correct personal information which you consider to be inaccurate, but we decline on the basis that we consider it to be accurate, we will, if requested, include a notation on the record regarding your views as to the accuracy of that information.
Trinity Business Consulting Solutions will take reasonable steps to make sure that personal information it collects, uses and discloses is accurate, complete, relevant and up-to-date. If we are holding personal information which we no longer need and which we are not otherwise required by law to retain, we will destroy or de-identify that information.
We reserve the right to change and modify this Privacy Policy at any time without prior notice. Your continued use of our website or services, or further provision of personal information following the posting on our website of changes to these terms, will signify your acceptance of these changes. You will always have access to the most recent version of our Privacy Policy on our website.
If you have a question, complaint or request concerning the privacy of your personal information, please contact us at:
In relation to a complaint, we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner (OAIC).
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