Personal information is any information or opinion (whether true or not) which either identifies you or from which your identity can reasonably be determined.
Sensitive information, on the other hand, is personal information that includes information about your:
– racial or ethnic origin;
– political opinions;
– sexual preferences or practices;
– criminal record; or
– health.
This sort of information has extra protection under the law. Upstart Advisory will only collect this information if it is necessary to do so and you have consented to its collection. We do not use or disclose your sensitive information other than as allowed by the law or with your consent.
Generally, and where possible, we will collect your personal information directly from you. Sometimes, however, personal information will be collected about you from other sources.
In addition, our website offers you an opportunity to submit other personal information which may include submitting your contact details or signing-up to receive newsletters, event information or other promotional communications from us.
When submitting any personal information about yourself on the internet, it is important to note that internet security is not absolute. Upstart Advisory takes reasonable steps as required by the Privacy Act to ensure that our website is protected from outside sources, and we encourage you to make sure your computer is adequately protected. If you post personal information on our website, we will consider that you have consented to the collection of this information.
In all instances, regardless of the method used to collect your personal information, we will deal with it in accordance with this Privacy Policy.
With your consent, we may disclose your personal information to others for the purposes of referrals to other professional service providers who may be able to help your business in specialist areas. For example, we may disclose your personal information to accountants, lawyers, tax advisors and financial planners if you are in need of these services. You are entitled to know the identities of any third party to which we disclose your personal information, and you may access these details at any time.
When you provide your personal information to us it may be transferred to our service providers, including those located outside of Australia.
Keeping your personal information up to date
It is important to us that your personal information is accurate, complete and up-to-date. So that we can deliver services as best as we possibly can, please let us know if there are any changes to your personal information. At any time after we have finished assisting you, you can contact us to tell us that any of the information previously given is now inaccurate or incomplete. We will make any amendments to your personal information upon your request.
At Upstart Advisory we take reasonable steps to safeguard your personal information. For example, our computer network has password security both internally and externally. For external purposes we also function with a firewall. Each of our offices has lockable filing cabinets. In addition, we ensure secure document destruction when discarding any document which displays your personal information or other confidential business information.
The Privacy Act does permit us to deny you access to your personal information in certain circumstances.
– there is current or pending litigation regarding the personal information;
– the request is frivolous;
– permitting access would be in breach of the law;
– providing the information would pose a threat to health or public safety; or
– providing the information would interfere with another person’s privacy.
Any denial of a request for access to personal information will be accompanied by an explanation setting out our reasons for doing so.
If providing access would reveal evaluative information generated within our organisation in connection with a commercially sensitive decision making process, we may give you an explanation for the commercially sensitive decision rather than direct access to the information.
Where we are not required to provide you with access because of one of the prescribed reasons, then we will consider whether a mutually agreed intermediary would allow sufficient access to meet our needs and yours.
Our Privacy Policy is based on the 13 Australian Privacy Principles (“APPs”) These Principles set standards for the way we must deal with personal information by regulating:
– the way we collect your personal information;
– the way we use and disclose it;
– our data quality and security for storage of your personal information;
– our openness about our Privacy Policy;
– any direct marketing we conduct;
– your right of access and correction of your personal information;
– how we handle any privacy complaints; and
– any international transfer of Information.
Upstart Advisory will not collect any information about you that is not necessary for the purpose for which you have engaged us. The primary reason why Upstart Advisory collects your personal information is so that we can provide you with consulting and advisory services.
In addition, we may collect personal information to:
– get in touch with you to organise a consultation with you regarding your business; and
– undertake various marketing activities, including direct marketing (in which case, you will be given a clear opt out from such direct marketing initiatives).
Ordinarily, Upstart Advisory will not need to collect sensitive information from you.
If you telephone to make a general inquiry about the types of services we offer at Upstart Advisory, you do not have to identify yourself. However, whilst you do have the right to seek to deal with us anonymously or using a pseudonum, if you choose us to provide you with our services, it would be impracticable to provide services to you if you do not supply us with your personal information.
If you do not wish to receive information about our products and services, you can request to be withdrawn from our Upstart Advisory marketing database at any time, either by contacting us or by using the opt out function contained in our direct marketing emails. Once you have made this request, Upstart Advisory will no longer continue to provide you with any further information. Any removal from our marketing database or particular direct marketing communications will not affect any services we are supplying to you, or will in future supply to you.
When we have no immediate use of your personal information, it is our usual practice to archive and store it securely for seven years. After the seven year period, we will oversee its destruction.
Can I access my personal information?
At any time you may request access to any of the personal information we hold about you. In order to respond to any request, we will require the following information:
– your name and address; and
– your contact telephone numbers
To access your information is a free service. Sometimes, we may ask that you send this information to us in writing to assist us.
Upstart Advisory aims to respond to requests for access to personal information within thirty (30) days.
Where any information is not accurate, up-to-date or complete, you can request that the information be amended.
In some instances it is not practical in the provision of our services to you to destroy information that you wish to update. In those circumstances we may choose to note your desired changes and place them together with the original personal information on your file.
If you believe that we have not protected your personal information as set out in this Privacy Policy, or you think we have in some other way breached an APP, you must first lodge a complaint with us.
The privacy legislation requires us to respond to your request in 30 days, and you must allow us the full 30 days to respond before you can escalate any complaint you may have. We will at first seek to deal with you via phone. If your complaint is not satisfactorily resolved after the phone call, we would meet with you in person.
If you are not satisfied with our response to your complaint after this meeting, you can refer your complaint to the Office of the Australian Information Commissioner by:
Office of the Australian Information Commissioner
tel 1300 363 992 or fax +61 2 9284 9666
Or https://forms.business.gov.au/aba/oaic/privacy-complaint-/
Upstart Advisory welcomes any feedback or questions you may have regarding our any aspect of our Privacy Policy. You will best be able to contact us at hello@upstartadvisory.com.au
From time to time our Privacy Policy may change. This Privacy Policy is current as at January 2016.