This policy was last updated in February 2024.

Cleave Accounting Pty Ltd (ACN 144 616 339) (we / us / Cleave Accounting), acknowledge the importance of your privacy and are committed to protecting any personal information we collect about you by adhering to the Australian Privacy Principles (APP’s) and the requirements of the Privacy Act 1998 (Cth) (the Act). This Policy sets out Cleave Accounting’s approach to gathering personal information, and our approach to the use and dissemination of such information. We undertake to treat all client and other personal information in our possession in accordance with the requirements of the Act. This Policy does not apply to employee records, which are dealt with separately.

Collection of personal information

By “personal information” we mean information or an opinion about an identified individual, or about an individual reasonably identifiable from the information.

There is a subset of “personal information” called “sensitive information”, which is afforded a higher degree of protection under the Act. This includes, for example, an individual’s health information, racial or ethnic origins, or religion.

Cleave Accounting collects and holds a range of personal information about its employees, job applicants and contractors we engage. We also collect and hold personal information of our clients, potential clients and contacts.

We collect this personal information so we can deliver the best possible services to our clients and offices, and to comply with our legal obligations.

The personal information we collect and hold:

Personal information we collect typically includes but is not limited to:

• Your name, address, contact details and date of birth
• Your Tax File Number (TFN), Director Identification Number (DIN) & Australian Business Number (ABN)
• Copies of primary photographic identification (Drivers Licence, Passport, Proof of Age Card), primary non-photographic identification (Birth Certificate, Marriage Certificate, Change of Name Certificate etc) and secondary identification (ATO or Centrelink notices, Utility bills etc)
• Residency status
• Employment details
• Details of bank accounts, credit cards and loan accounts
• Details of your investments and interests in other entities
• Accounting data and financial records
• Details of your spouse, dependants and entities associated with you
• Other information that may be necessary for provision of our services in accordance with the terms of engagement.

Job applicants and contractors

We may collect and hold certain personal information about applicants for employment with us and contractors wishing to supply products and/or services to us as well as their employees. The information we collect may include your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.

We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number, superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions.

Clients, potential clients and community contacts

We collect a range of personal information about clients and potential clients.

The kinds of personal information we may collect include your name, place & date of birth; your contact information, including postal and residential addresses, telephone numbers, and email addresses; details of prior enquiries you have made and our communications with you or work we have performed for you, which may include your financial information, and where relevant your TFN, ABN, HIN, CAN, DIN and registered business names.

We collect personal information directly from you, such as when you meet with us, provide your information by document, telephone or facsimile, by forwarding us an email, or by submitting personal information by using our secure portal.

In some cases, personal information may be provided by an entity/person authorised by you to do so, such as your employer or a corporate or business entity with which you are involved either as a principal, member or beneficiary, for the purpose of providing services to or on your behalf.

Our purpose for collecting personal information

We collect your personal information in order to conduct our business and provide services to you, including any purposes that you may reasonably expect, such as where we are required by law to do so in our capacity as Tax Agent, or for any other purposes disclosed to or authorised by you. This may include disclosure to organisations that provide us with support services, and professional advice. The collection will be fair, lawful and not intrusive. The nature of this information will vary according to your relationship with Cleave Accounting.

Sensitive information

During the course of business, Cleave Accounting may at times be required to collect sensitive information about individuals. Collection of any sensitive information will be done in accordance with the Act. We will not collect sensitive information unless you have consented, it is required by law, or in other special specified circumstances, for example, relating to health services provision and individual or public health or safety.

Use and disclosure of personal information

We will hold your personal information for as long as is required to fulfill the purposes for which it was collected or as required by law. We will take reasonable steps to destroy or de-identify any personal information about you once the information is no longer required for the purposes for which it was collected or as authorised or required by law.

We will only disclose personal information for the purpose it was collected unless you have consented, or you would reasonably expect such use or disclosure, or the use is for direct marketing as outlined below.

Job applicants and contractors

We may disclose personal information about job applicants and contractors to professional advisors such as lawyers, auditors and recruiters, and government agencies , where this is necessary to assess their suitability to perform the duties required and deliver services to our clients or to meet our obligations under relevant laws.

Clients, potential clients and community contacts

Personal information collected about our clients, potential clients and/or community contacts may be disclosed to:

• our employees and contractors (e.g., to enable them to perform services under contract with us which may directly or indirectly benefit the client from whom the information was collected);
• marketing providers to facilitate marketing of our services to current and prospective clients;
• government agencies where this is necessary for us to transact matters on behalf of our clients and/or comply with our legal obligations to notify the government and police of certain matters;
• our professional advisers, such as lawyers or auditors; and
• related organisations.

Direct marketing

Cleave Accounting may use or disclose your personal information for the purpose of informing you about Cleave Accounting services or other opportunities that may interest you. Any such marketing would be received directly from Cleave Accounting.

Sale or merger of Cleave Accounting

Personal information about individuals we have collected and hold may be disclosed to third parties on a strictly confidential basis in the event we offer to sell and/or sell our business and/or assets, at or before the time of a merger, acquisition or sale.

Website collection of personal information

We may record your IP address and details of your access to our sites, we may place cookies on your computer to enable your web browser to search and find us efficiently. We use cookies to monitor the traffic to the various pages on our website, for statistical and website improvement purposes only. This information is anonymous and will not enable you to be identified. You are able to disable cookies and applets via your computers web browser however this may restrict access to some webpages and services within our website.

However, if you submit your personal information to us via our website, for example, if you submit a query, request to be added to a newsletter mailing list, or subscribe for an event or program, then we may record your details in our customer relationship management system so that we can respond to your query or send information in relation to opportunities that may interest you.

There will always be a simple means by with you can opt out of receiving marketing communications, whether that is by clicking the “opt out” option on the website or in the marketing material itself, or by contacting us using the contact details below.

Data security of personal information

We have taken reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure. Staff are required to sign a confidentiality clause as a part of their contracts of employment. They are also required to adhere to and comply with our Privacy Policy.

There are a range of physical and electronic procedures to ensure that privacy is safeguarded. However, the internet is not secure and we cannot guarantee the security of any information sent to us via the internet.

Sometimes breaches of personal information occur, which can range from non-threatening to serious. When a data breach is considered serious it is likely to cause harm to the individual that the personal information is about. This is called an eligible data breach. If a circumstance arises that is considered an eligible data breach, we will notify the individual and the Office of the Australia Information Commissioner. In this notification we will make recommendations to the individual on the steps they should take in order to protect themselves in relation to the breach of information.

We have also appointed a Privacy Officer who is responsible for the application of Cleave Accounting’s Privacy Policy to ensure that the practices, procedures and systems adopted by Cleave Accounting are applied in an open and transparent manner.

Accessing and correcting your personal information

It is important that the information we hold about you is accurate. Except in certain situations, you have the right to access your personal information and ask us to correct it. We will take reasonable steps to update or correct, as soon as possible, any information in our possession that is inaccurate, incomplete, out-of-date, irrelevant or misleading.

We may refuse to grant you access where this is allowed or required by law, for example, where this would have a negative impact on someone else’s privacy. If we do refuse to grant access, we will give you written reasons.

If you would like to access your personal information, please contact us via the contact form below or by contacting admin@cleave.com.au

We may charge you a small fee for accessing your personal information, as permitted by law.

Complaints

You have the right to complain if you believe we have breached this Policy or your rights under the Act. Should you have any complaints about our treatment of your personal information please contact our office:

07 3359 3311

Privacy Officer
Cleave Accounting
PO Box 165
VIRGINIA, QLD 4014

admin@cleave.com.au

We will treat any complaint about a breach of privacy legislation or any relevant registered code seriously, and will investigate any breach of which we become aware – including how it occurred and how best to prevent such a breach occurring again.

We will promptly acknowledge receipt of your complaint and we will endeavour to deal with your complaint and to provide you with a response within a reasonable time period following receipt of your complaint (generally within 30 days of receipt). Where a complaint requires a more detailed investigation, it may take longer to resolve. If this is the case, then we will provide you with progress reports.

We reserve the right to verify the identity of the person making the complaint and to seek (where appropriate) further information from the complainant in connection with the complaint.

Where required by law, we will provide our determination on your complaint to you in writing.

Please note that we may refuse to investigate or to otherwise deal with a complaint if we consider the complaint to be vexatious or frivolous.

If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner:

Further information can be found at http://www.oaic.gov.au/privacy

Commonwealth Government identifiers

We will not use Commonwealth government identifiers (Identifiers) as an identifier of individuals. Identifiers will only be used or disclosed in the circumstances permitted by the Act.

Anonymity

In many cases, you will need to provide your real name when interacting with us. You may however – wherever lawful and practicable – use a pseudonym (or simply not identify yourself) when dealing with us. For example, if you have a complaint or concern about our site, or a general question about any of our products, you are welcome to contact us without identifying yourself. In some cases, however, if you do not provide us with this information we may not be able to fully provide you with our services or respond adequately to you. For clarification on when you must identify yourself, please contact our Privacy Officer.

Transborder data flows

There may be occasions when personal information is transferred outside of Australia. Generally, this will occur in the provision of services to you and the transfer of this information outside of Australia will have been disclosed to, and authorised by, you as part of the terms of our engagement. i.e. where you are a foreign tax resident or receive a foreign pension. When transferring personal information outside Australia we will comply with the requirements of the Act that relate to transborder data flows. Unless we have your consent, or an exception under the Act applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.

From time to time, we will engage IT service providers to assist us to collect, store and manage your personal information. For example, we may upload personal information to cloud-based data management systems. Some of those IT service providers may be located outside Australia but we will take reasonable steps to ensure they comply with the Australian Privacy Principles or are otherwise subject to a law that has the effect of protecting your personal information in a way that is substantially similar to the way the APPs protect the information, and that you can access mechanisms to enforce the protection of that law .

Updating privacy policy

We will review our Privacy Policy from time to time to ensure that it is in line with best practice and remains current with any legislative requirements. Any changes to our Privacy Policy will be incorporated into a new version of this Policy, stating the date from which it will operate. Our commitment to your personal information will be governed by the most recent and up-to-date policy in place.

Contacting us

Cleave Accounting welcomes your comments regarding this Privacy Policy. If you have any questions about this Privacy Policy and would like further information, please contact our office.