Foley and Associates Pty Ltd (Foley) is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your personal information.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your personal information.
A copy of the APPs may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au.
Information We Collect
We collect your personal information for the primary purpose of providing our services to you, providing information to our clients and for marketing purposes. The personal information that we collect will vary depending on how you interact with us and the services for which you engage Foley.
The information we collect may include:
- personal identifiers, such as your name, date of birth, address, email address, contact numbers;
- documents that verify your identity, such as your driver’s license;
- information about the services that Foley provides or has provided to you;
- information collected through your use of our website, including cookies, media and publications, third-parties, and other publicly available sources; and
- information about how you use Foley’s website or services.
We may also use your personal information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by clicking an unsubscribe link at the bottom of the email or contacting us in writing.
The above personal information may also include information about other individuals provided by you, such as any staff members linked to your account. We rely on you to get their consent before providing any information to Foley.
Foley may collect sensitive information in limited circumstances about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. Foley will get your express permission before collecting this information (except if required by law). We will only use sensitive information for the primary purpose that it was collected for or a secondary purpose that is directly related to the primary purpose.
Where reasonable and practicable to do so, we will collect your personal information only from you. However, in some circumstances we may be provided with information by third parties. In such a case, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
How We Collect Information
We collect information:
- directly from you when you interact with us through our website, email, phone or in person;
- when you interact with or use our website; and
- from other third party sources, such as people with permission from you to give us your information (such as your employer), third party websites and social media that collects and discloses information about you (such as Google or Facebook), business directories, open data sources, Government Agencies (such as the Australian Bureau of Statistics), and credit reporting bodies or services providers that assist Foley to provide services to you, or identity and fraud checking services, or analytics and advertising-related services.
How We Use Information
When we collect personal information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. Generally, we use personal information we collect for:
- Business Operations: providing you with our services or communicating with you.
- Administration: billing, security and verification processes.
- Analytics: developing insights about you to identify market segments, market products and services, carry out market research, analyse effectiveness of marketing campaigns and audience ratings, including comparing this information to third party information (such as Google or Facebook).
- Marketing and Advertising: communicating news that may be of interest to you or you have expressed interest in, developing services that may be of interest to you, conducting promotions, delivering targeted advertising or other content.
- Compliance: when we are required to use your information by law.
If We Share your Information
Your personal information may be disclosed in a number of circumstances including the following:
- third parties where you consent to the use or disclosure;
- organisations working with us to prevent or investigate unlawful activity primarily relating to fraud and identity theft;
- debt recovery agents and credit reporting bodies; and
- where required or authorised by law.
It is unlikely that your personal information will be disclosed to overseas recipients.
When we disclose your personal information, Foley put measures in place to ensure your information is kept confidential, used securely and only used for the purposes outlined above. We will not otherwise sell or share information that directly identifies you with any third-party for commercial purposes without your express consent.
For commercial purposes, we can de-identify your information and share it so that it can be used for analytical services and anonymous aggregated insights into our customer data.
Security of Personal Information
Your personal information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However, most of the personal information is or will be stored in client files which will be kept by us for a minimum of 7 years.
Access to your Personal Information
You may access the personal information we hold about you to update or correct it, subject to certain exceptions. If you wish to access your personal information, please contact us in writing.
In order to protect your personal information, we will require identification from you before releasing the requested information.
It is important to us that your personal information is up to date. We will take reasonable steps to make sure that your personal information is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Information Disclosures and Breaches
If we become aware that we have inappropriately used or disclosed your personal information, or that your personal information has been subject to a data breach, and we are unable to rectify the data breach without any potential adverse effect on your privacy, we may contact you to inform you, and to work with you to minimise or mitigate the consequences of the data breach.
We may be required to notify you of a data breach as soon as we practicably can if we consider you are reasonably likely to be at risk of serious harm (including financial harm or mental or physical harm) in accordance with Part IIIC of the Privacy Act. Where reasonably practicable, we will give you details of the data breach and, if practicable, steps you can take to lower the risk of harm to you. We may make a public notification for a data breach affecting a large number of clients before we contact you directly or in place of direct contact.
To the extent permitted by law, Foley has no liability to you at law or in equity, under statute, for breach of contract, or in tort for negligence or otherwise for any loss or damage suffered by you in connection with a data breach arising out of, or in connection with, any services for which you engage Foley.
Suite 25.01, Level 25
25 Bligh Street
Sydney NSW 2000
This Policy may change from time to time and is available on our website.