Brodie Long & Grew Pty Ltd, trading as BLG Business Advisers, and BLG Audit Services Pty Ltd are committed to protecting your privacy and your personal information, which applies to our website, subscription service and our client management system.
The personal information we collect is handled in accordance with the Australian Privacy Principles and the Privacy Act 1988 (Privacy Act). We also comply with the Spam Act 2003 which imposes restrictions on sending commercial electronic messages.
This refers to any information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can be reasonably ascertained from the information or opinion. Examples of this include your name, address, birth date, or email address.
This refers to personal information about things such as your membership of professional associations, race, ethnic origin, political affiliation, religion, sexual orientation, biometric information and health information.
Cookies are used to collect information about how you interact with our website and allow us to remember you. You can choose to accept or decline storing cookies on your computer when visiting our website.
2 Kinds of personal information we collect and hold
You are free to explore our website without providing any personal information about yourself. When you register to our subscription services we request that you provide some personal information about yourself, and we collect navigational information. Personal information as a subscriber refers to information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business.
Personal Information also includes Navigational Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed.
Due to the nature of the products and services we provide, and the requirements of legislation and regulations, we ask for a range of personal information from our clients.
The personal information that we may collect and hold about you includes your name, employment titles, business name and industry, business and personal postal and street addresses, e-mail addresses, telephone numbers and any other contact information, place and date of birth, gender, information in identification documents (eg. Passport, drivers licence), tax file numbers, ABN/ACN and government related identifiers, educational qualifications and employment history, recommendation and reference letters (including letters of good standing), social media information, information you make available via social media websites or post on BLG Business Advisers social media pages, information relating to the complaints, enquiries and/or referrals you have made to us and any complaints, enquiries and/or referrals made about you, records of some of your communications and other interactions with us (including where we record your communications with us), the information collected during any disciplinary investigations or other action, information about audits performed on your business/practice, bank account details, assets and liabilities, personal income, Visa and work permit status, shareholdings and details of investments, superannuation details, tax and financial statements, insurance information, personal information about spouse and dependants.
It may be necessary in some circumstances for BLG Business Advisers to collect sensitive information (which is a form of personal information) about you in order to provide specific services. The types of sensitive information we may collect includes health status, ethnic origin, details of any membership/s to professional associations, criminal record and other sensitive information (to the extent it is reasonably necessary for one or more of our functions or activities).
You have a right to refuse to provide us with your personal information or to anonymity or the use of a pseudonym. However, if you do refuse to provide such information, or request the use of anonymity or a pseudonym we may be unable to complete or fulfil the purpose for which such information was collected, including providing you or our clients with the services we were engaged to perform.
Information About Children
Our website and subscription services are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at email@example.com, so that we may delete the information.
3 How we use the information we collect
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
When you visit our website you can accept or decline to store cookies on your computer. Cookies that are stored on your computer are used to give you an improved and more personalised customer experience while on our website, and via other media if you have subscribed with us. The information stored by the cookies also provide us with analytics and metrics about our visitors both on this website and via other media.
When you register for our subscription service, we collect, hold and use personal information to ensure that we:
- improve your browsing experience by personalizing the website and to improve the subscription service;
- send information or content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
- promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
- meet legal requirements.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your personal information to the third party.
Client management system
We use APS as our internal client management system which collects personal, and sometimes sensitive information, as necessary to ensure we provide you with the information and services that you request as our client and that are appropriate to your needs. This includes:
- Updating personal and business details and profiles, fulfilling an order or request for information, product or service (including confirming and/or processing payments for the same);
- For promotional and marketing purposes, including sending you information about BLG Business Advisers services, information, and events;
- Communicating on any matters relevant as a client of BLG Business Advisers and any other opportunities or transactions with us;
- Monitoring, moderating and improving BLG Business Advisers social media pages;
- Assessing suitability for the provision of services by independent contractors;
- Dealing with other bodies and fulfilling our contractual and other obligations, including with external payment providers;
- Conducting, managing and reporting on quality assurance reviews and audits;
- Conducting competitions;
- Organising and hosting training and events (including with third parties);
- Providing products and services, including training and events, or information relating to such products and services;
- Assessing and improving our services to customers, as well as for training and quality purposes, including where we monitor, record and analyse communications between you and us;
- A purpose directly related to any of the purposes identified above; and
- Providing information to third parties as authorised or required by law (including a Privacy Act) or a court/tribunal order.
Client Testimonials and Comments
We post client testimonials and comments (client stories) on our website, which may contain personal information. We obtain each client’s consent via email prior to posting their name, business and testimonial.
4 Collection of personal information
We use HubSpot, Inc. to collect your personal information when you subscribe via our website, and to track cookies when you visit our website.
You can voluntarily register for our subscription service via our website on our home page, via the subscription form on the footer, via a pop-up subscription form or when you contact us for more information via our Get In Touch form.
When you visit our website you can accept or decline to store tracking cookies on your computer which provide us with analytics and metrics about our visitors both on this website and via other media. We also collect navigational Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Google analytics collects this navigational information. Google Analytics uses first party cookies, which are text files placed on your computer for the purpose of anonymously identifying your session.
When we collect, hold and use personal or sensitive information it must be done through lawful and fair means. Consent must be obtained to collect, hold, use and disclose personal information. We are not required to obtain your consent to collect, hold, use of disclose your personal or sensitive information if the collection is required or authorised by or under an Australian law or a court/tribunal order. There are other exceptions to the requirement of obtaining your consent in accordance with the Australian Privacy Principles.
BLG Business Advisers use a variety of formats for the collection of personal and sensitive information for client services. These include:
- Requiring clients to complete a Client Profile or other forms;
- Receipt of emails, letters and other correspondence;
- Telephone calls;
- Appointments in person;
- Publicly available records;
- Through a client’s personal representative;
- Through use of our website, such as via our online Get In Touch form.
In every circumstance we will attempt to obtain such personal and sensitive information directly from you. If that is unreasonable or impracticable, we will attempt to obtain such information from other sources as listed above.
Collection of someone else’s personal information
You should only provide us with someone else’s personal information where you have their express consent to do so and it is for the purpose of us providing services to you. Matters in this policy should be communicated to any person whose information you collect and provide to us.
Unsolicited personal information
There may be circumstances where we are provided with personal information which we did not actively seek. An example may be misdirected mail, or an excess of documents provided to us by clients.
In such situations, we will make a determination on whether we could have obtained the information lawfully in accordance with the APPs. If the information was not lawfully obtained it will be destroyed or anonymised. We will try to notify the relevant person, whose information has been mistakenly received, if this situation arises.
5 Retention of personal information
How long we keep information we collect about you depends on the type of information. as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain personal information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about client services, the subscription service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to retain your personal information, we take all reasonable steps to destroy the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
If you have elected to register with our subscription service, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
6 Access and correction of personal information
Individuals have the right to access their personal information that BLG Business Advisers holds and request its correction.
We will in most cases provide an individual access to their personal information. This is subject to some limited exceptions, such as where:
- Providing access may have an unreasonable impact on the privacy of other individuals;
- Providing access would be unlawful or would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, BLG Business Advisers or an enforcement body;
- Providing access would reveal the intentions of BLG Business Advisers in relation to negotiations with the individual in such a way as to prejudice those negotiations;
- We have reason to suspect that unlawful activity, or misconduct of a serious nature, relating to our functions or activities has been, is being or may be engaged in; and giving access would be likely to prejudice the taking of appropriate action in relation to the matter;
- Giving access would reveal evaluative information generated within BLG Business Advisers in connection with a commercially sensitive decision-making process;
- We reasonably believe that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
- The request for access is frivolous or vexatious; or
- Where we are otherwise permitted by a Privacy Act to do so.
To request access or seek the correction of personal information held by BLG Business Advisers, please make it in writing to:
BLG Business Advisers
PO Box 460
Wollongong NSW 2520
P: (02) 4229 2211
7 Security of your personal information
We are committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable safeguards to secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
Our employees undertake privacy and data protection training to understand their obligations in regards to protection of confidential and personal information.
When we engage third party providers we do so on the basis that the third party providers comply with the requirements under the Australian Privacy Act and they have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
8 Hosting and access to data
Depending on the nature of the engagement we may disclose your personal information to third parties to fulfil the purpose of the engagement. This includes third party providers in Australia and the Philippines. You can review our Engagement Terms & Conditions on the website.
We only store, process or back up your personal information on servers that are located in Australia. Third party providers in Australia and the Philippines may have access to these servers, and the personal information contained on them. Access to the servers is protected by appropriate safeguards, including limitations on transmission of data by third party providers. Our website is supported by HubSpot which is hosted on Amazon Web Services (AWS) in the United States East region and also leverages the Google Cloud Platform (GCP) in the EU (Frankfurt, Germany region).
There will be circumstances in which the disclosure of personal information is required or authorised by Australian law or a court/tribunal order, the Code of Ethics for Professional Accountants, or where you have given your direct consent to disclose it.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
9 Privacy concerns
If you would like any further information about our handling of personal information or to make a complaint about something you believe breaches a Privacy Act, please lodge a written complaint using the contact details above. Once we receive your complaint, we will respond to your complaint within a reasonable period of time, usually within 14 working days.
If you are unsatisfied with the handling of your complaint, you may contact us further to advise of your concerns and, if we are unable to reach a satisfactory resolution, you may wish to take your complaint to the Office of the Australian Information Commissioner (OAIC) (AUS) for a review of your complaint.