GENERAL

We understand that the privacy of your personal details is of the utmost importance to you and this policy sets out the rules we will abide by when dealing with personal information we collect from individuals in the course of our business. This policy is consistent with the Australian Privacy Principles (APP) of the Privacy Act 1988.  Our privacy policy can be found on our website, or you can request a copy from our office.

PERSONAL INFORMATION

In this policy, personal information means information from which an individual is either identified or reasonably identifiable.

HOW INFORMATION IS COLLECTED

At the time of collection or as soon as practicable afterwards, we will take reasonable steps to provide you with access to this privacy policy.  We will advise you of the purposes of collection, overseas disclosures, the main consequences if we do not collect the information and how you can access and correct your information.

Wherever possible, if it is reasonable and practical to do so, we will collect personal information directly from you, as the individual concerned, with your consent. This may be through emails, over the telephone, over the internet, in person, or through a third-party application which we will send you link for via email or SMS. Additionally, we may collect this information from a response you provide to our request, personal information from a business meeting with you, a complaint you may advise us of, a credit card payment or CCTV footage.

With your prior permission, we may also collect information from another person or entity such as the Australian Taxation Office, ASIC, your bank, your previous accountant, your financial adviser, your employer, your lawyer or other sources as required where it is necessary for the service we provide you and where it is unreasonable or impractical for you to give us this information yourself. We will only collect information by fair and lawful means as described in the Australian Privacy Principles. We do not collect personal information without your consent.

When you provide personal information to us about other individuals, we rely on you to have made them aware that you will or may provide the information to us and the relevant purposes for which we will use this information. You also need to inform them how they can access this information.

WHAT INFORMATION IS COLLECTED AND HELD

Clients or Potential Clients

When you agree to become a client of Bonsella or request information about becoming a client of Bonsella, we will collect personal information from you which is reasonably necessary to provide you with the services or information you request from us. The personal information we collect includes your name, address, date and place of birth, telephone numbers, email address and other information specific to the services provided. This can include, but is not limited to, tax file number, Australian business number, bank account and credit card details, entity beneficial controlling parties and owners, business and financial information, biometric information. We may also complete credit, adverse media, sanctions, terrorism proliferation politically exposed persons or other publicly available checks. This information is used in the provision of accounting, taxation and other professional financial services that you request us to complete on your behalf.

Website and Client Portal Users

When using our website or client portal you may provide us with personal information. We will use all reasonable measures to protect any such information from being used for any other purpose, other than the purpose for which it was intended.

As well as the information you specifically provided above, we may gather statistics on web site use, collecting information such as the number of visitors coming to the site and their location. No identifying information is collected during this process. We use this information for statistical purposes only.

Employees and Potential Employees

When recruiting and employing staff, we collect personal information such as name, address details, telephone numbers, email address and other information specific to the recruiting/ employment activities. This can include, but is not limited to previous work experience, education, references, bank account details, tax file number, right to work in Australia and superannuation details. Under some circumstances we may complete a police, credit or media check.  We may collect this via email, SMS, our website and employment applications either sent directly to us or via an agency or online employment platform.

CCTV Footage

Where you visit our premises, we will collect CCTV and/or security alarm footage which we may access for business security, legal, staff compliance, safety or access to the building reasons. We may also provide this footage to other agencies where we are required to do so by law.  We retain this data for no more than six months, depending on the length of time it takes to fill and overwrite our storage system. We will notify you via signage in the building where CCTV is operating.

Sensitive information

We will only collect sensitive information with your consent unless an exception under the Privacy Act applies. For example:

– Where we are required to do so by law.

– If we suspect unlawful activity or misconduct of a serious nature relating to the entities’ functions or activities has been, is being or may be engaged in and reasonably believes collection is necessary for appropriate action to be taken.

– To assist in the location of a missing person collected within the rules of the Information Commissioner

– Where it is reasonably necessary to establish, exercise or defend a legal or equitable claim

– Where it is reasonably necessary for a confidential alternative dispute resolution process

PURPOSE OF COLLECTION

We will collect your information for the purpose of providing services to you that you have requested from us. Services we provide you could include but are not necessarily limited to – preparation of financial statements and tax returns, business advice, bookkeeping and taxation advice. We will also collect information to identify you as we are required to do by the Tax Practitioners Board and the Australian Government.   If you are an employee of Bonsella we will collect your personal information for the purpose of fulfilling our employment compliance requirements and to properly discharge the employment contract responsibilities which is held between us.

CONSEQUENCES OF NON-COLLECTION

If we do not collect all the information we have requested from you, we may not be able to provide you with a service if we are not able to properly identify you. If information is incomplete, we may not be able to complete all the services you have requested in an accurate and professional manner.

UNSOLICITED INFORMATION

Unsolicited information is information we have not requested from you; which is not required to complete a service for you or is sensitive information which you have not agreed to we should collect unless it is required for us to complete a service you have requested.   If we receive this type of information and are not required to retain it by law, we will destroy or de-identify it unless you request its return.

HOW WE WILL KEEP PERSONAL INFORMATION UP TO DATE

We seek to maintain the quality of the information we hold by taking reasonable administrative and technical steps to make sure that the information collected, used and disclosed is accurate, complete and up to date particularly before in is disclosed in relation to financial, taxation or advisory services.  If the information we hold about you is incorrect, you may inform us and we will correct it for you.

HOW WE STORE INFORMATION AND KEEP DATA SECURE

Bonsella Business Solutions utilises up-to-date techniques and processes, which meet current government requirements to protect personal information from misuse, loss and unauthorised access, modification or disclosure. Paper documents are protected from unauthorised access, misuse, unauthorised modification or disclosure by only allowing authorised employees and contractors access to our physical offices, which are locked and alarmed after hours.

We also maintain up-to-date computer and network security systems with appropriate audit logs, cloud-based secure backups, firewalls, multi factor authentication (MFA) access controls and passwords to protect and prevent loss of electronic copies of personal information.

The only people who are permitted to access personal information are those employees or contractors who need personal information to do their jobs. All employees and contractors are contractually bound by the confidentiality agreements in place on how personal information must be treated.

We take all reasonable steps to ensure that all personal information we hold is secure from any

unauthorised access, misuse or disclosure, however we cannot guarantee that unauthorised access will not occur. In the unlikely event that we should have a data breach which affects you, we will inform you via the contact details we hold on file for you. We will also, where required by law, notify the Office of the Australian Information Commissioner and follow their requirements in the assessment of the data breach.

ANONYMITY AND PSEUDONYMITY

If you request us to, we will assign your matters to a pseudonym or allow you to act anonymously in your dealings with us where lawful and practicable.  With regard to anonymity, we will not collect your personal information or identifiers, however this will limit the services we are able to provide you with. If you wish to use a pseudonym, we will only link your personal information to your pseudonym where you consent to this. We will also limit access to your information to authorized personnel. In some circumstances we are required by law to identify the person we are providing the service to.  In these cases, we will advise you of this and only collect the minimum information required complete the service.

DESTROYING PERSONAL INFORMATION

Any personal information we hold will be maintained to comply with legislative and professional requirements – generally five to seven years, after which time the information will be securely destroyed, where the information is based on paper.

ACCESS TO PERSONAL INFORMATION WE HOLD AND CORRECTION OF THAT INFORMATION

Our policy is to provide you with access to your own personal information, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (i.e. by providing copies or permitting a file to be viewed), provided it is reasonable and practical for us to do so.  You can request your personal information by emailing us at info@bonsella.com.au and we will respond to your request within 30 days. If we are not able to provide the information we will advise the reason for the refusal. There may be a reasonable charge to you, for us to search for, reproduce and provide this information to you, however this may be waived in consideration of each individual circumstance. We reserve the right to verify your identity prior to release of data to you.

COMPLAINTS

Should you have a complaint about any of our privacy procedures, please contact us by email at info@bonsella.com.au or by telephone on 02 62574144. We will deal promptly with your complaint, responding to you within 30 days. If we cannot resolve the complaint to your satisfaction within 45 days or a reasonable time, you or we may refer the complaint to the Office of the Australian Information Commissioner on 1300 363 992.

DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

There are occasions when we may be requested to provide your financial, legal, personal or other information which you provided to us to allow us to provide a service you requested or to complete an employment contract, to third parties such as the Australian Taxation Office, Australian Securities Commission, AUSTRAC, your bank or other parties such as software applications or employment contractors in order to provide our services to you. This is done with your consent to using your personal information in this way, unless we are required by or authorized by legislation to disclose information with or without your consent.

USE FOR SECONDARY PURPOSES

We will only use or disclose your information for secondary purposes, in line with Australian Privacy Principle 6 which you can find at the Office of the Australian Information Commissioner website. Use or disclosure reasons include where you have consented to the use or disclosure, it is reasonable to do so related to the primary purpose we received the documents, we are authorized or required under Australia law, to lessen or prevent a serious threat to health, life or safety, in relation to unlawful activity, to locate a missing person, where it is reasonably necessarily to establish, exercise or defend a legal or equitable claim; for confidential alternative dispute resolution processes.

DIRECT MARKETING

Bonsella does not use your personal information for Direct Marketing purposes.

DISCLOSURE OF YOUR INFORMATION TO OVERSEAS RECIPIENTS

We have accounting professionals located in overseas locations who work on client assignments. They assist us with tasks like bookkeeping, administration, and end-to-end accounting, including the preparation of BAS, IAS, financial statements and tax returns. We take care to ensure reasonable steps so that an overseas recipient follows our policies and procedures, does not breach the Australian Privacy Principles in relation to personal information and have confidentiality agreements in place with all personnel who access personal information. Additionally, we use a number of reputable software providers who maintain their own privacy policies and who, from time to time, may use or disclose information outside the jurisdiction of Australian Privacy laws. We take reasonable steps that they comply with the Australian Privacy Principles however note that once outside of Australia the recipient may by subject to foreign laws which could compel disclosure to third parties.

USE OR DISCLOSURE OF GOVERNMENT RELATED IDENTIFIERS

We will not use a government identifier as your unique identifier within our systems. We will not disclose any of your government related identifiers without your express consent, unless it is necessary to provide the service you have requested us to complete, or if we are required under the Law. We handle Tax File Numbers in accordance with the Privacy (Tax File Number) Rule 2015.

USE OF ARTIFICIAL INTELLIGENCE

We use third party AI software to assist us in providing you with our services. For example, we may use third party software to record meetings with you and to analyse meeting and client contact using AI. We do not put your personal information on any publicly available AI websites or applications.  Your data is not used to train models. Where we generate personal information relating to the provision of a service to you using AI, or if we use AI to generate decisions based on the analysis of your personal financial circumstances, we keep the information securely and in accordance with this privacy notice. We also carefully consider and if necessary amend the accuracy of these decisions before providing them to you.

Bonsella Business Solutions Pty Ltd
ABN 44 163 754 498
Contact: The Practice Manager