Privacy Policy

The privacy of your personal information is important to Dulwich Group Services Pty Ltd trading as Johnston Grocke (“Johnston Grocke”)

Johnston Grocke is committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act). This Privacy Policy sets out how we handle personal information.

This Privacy Policy does not apply to personal information by Johnston Grocke that is exempted under the Privacy Act, for example employee records.

Personal Information we collect

This policy outlines how we manage your personal information. It also describes generally the type of information held and how that information is collected, used and disclosed.

What personal information will be collected?

In the course of our activities, we collect and hold personal information about you. Such personal information is collected for the purpose of providing the service(s) you have requested.

The nature of personal information we collect will depend on what service we are providing to you but will generally comprise, but not limited tom the following:

• Name, address, contact details (phone, fax, email), date of birth
• Educational qualifications, employment details and employment history
• Information in identification documents (e.g. passport, driver’s licence)
• Tax File Numbers and other government issued identification numbers
• Bank account details, shareholdings and details of investments
• Details of your superannuation and insurance arrangements
• Your Internet Protocol (IP) address
• Payment details
• Your financial needs and objectives
• Financial details including your assets and liabilities (both actual and potential), income and expenditure
• Your personal goals and objectives
• Your investment preferences and aversion or tolerance to risk
• Health information including current health, smoker status and historical medical records
• Status of wills, beneficiaries and powers of attorney

How we collect and manage personal information

Generally, we collect personal information from you directly. This may be when we deal with you in person or over the phone, when you send us correspondence, when you complete a survey, form or questionnaire, when you subscribe to a publication or when you use our website or social media.

Due to the nature of our services, this is generally not practical for us to deal with individuals on an anonymous basis or using a pseudonym, although at times this may be possible (e.g. for client or staff feedback sought on an anonymous basis).

Personal information about someone else

Where you provide us with personal information in relation to someone else, you must have their consent or authority to do so. You must inform them of the details of this Privacy Policy.

Holding personal information

We store personal information in hard copy and electronic formats. We take security measures to protect your personal information including locks and alarms on our offices to protect physical information, as well as controls over our electronic information (e.g. restriction of access, firewalls, encryption, and passwords). We have document retention policies and procedures. In some cases, we engage third parties to host electronic data on our behalf.

Sensitive personal information

In certain circumstances we may request sensitive personal information such as health details. In doing so, we will request your consent to the proposed uses of that information. If you provide us with unsolicited sensitive personal information, you consent to us using that information subject to applicable laws as described in this policy. We do not collect information about political or religious beliefs, ethnic background or sexual preference.

Retaining your personal information

We will retain your personal information for the duration of your use of our services or our Website (as applicable). When you cease use, we will retain your personal information for no longer than 7 years or for any such period that is necessary for us to retain your Personal Information (the Retention Period).

Destruction of your personal information

Once the Retention Period has lapsed, we will ensure the timely and secure destruction and/or disposal of your Personal Information, including both physical information and cyber information.

If at any other time, you request we destroy and/or dispose of your Personal Information, we will comply with your request in a timely matter, to the extent that is does not interfere with the conduct of our business.

The purpose of collecting, holding, using and disclosing personal information

We collect, hold and use personal information for a number of purposes including:

• To provide our services
• To respond to requests or queries
• To keep our clients and other contacts informed of our services and of industry developments and market trends
• To notify clients and other contacts of seminars, or other functions
• To verify clients’ identity
• For general management, reporting and administrative purposes
• For processing payments
• For recruitment purposes
• For employment purposes
• To conduct surveys
• To meet any regulatory obligations
• As part of an actual (or proposed) acquisition, alliance, joint venture or referral arrangement
• To conduct internal analysis of our databases
• For any other business purpose

The types of third parties to whom we may disclose your personal information

• Our service providers
• Our professional advisers
• Organisations with whom we have a business relationship that are bound by strict confidence
• Government or regulatory agencies as part of an engagement or otherwise (e.g. the Australian Taxation Office or Centrelink)
• As part of an actual (or proposed) acquisition, alliance, joint venture or referral arrangement

We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you.

Disclosure of personal information overseas

In addition to disclosures permitted under this policy, we may disclose your information to our third parties that we engage to assist us in providing professional services to our clients or in the operation of our business (i.e our subcontractors, advisors and suppliers).

These entities and third parties may sometimes be located in other countries, in particular the Philippines.

Where we disclose your personal information to other third-party service providers, we will take steps to ensure that those recipients protect that information from unauthorised access, modification or disclosure and from misuse, interference and loss.

Employee Records

Employee records are not generally subject to the Privacy Act and therefore this policy may not apply to the handling of information about employees by Johnston Grocke. For information about our practices relating to employee information, please contact us directly.

Direct Marketing

Johnston Grocke may use your personal information for the purposes of marketing our services. If you do not want to receive marketing material from us, you can contact our office.

Privacy on our website

Similar to other commercial Websites, our Website utilises a standard technology called cookies and web server log files to collect information about how our Website is used. Information gathered through cookies and Web server logs may include the date and time of visits, the pages viewed, time spend on our Website and the Websites visited just before and just after our Website.

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a Website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Most browsers recognised when a cookie is offered and permit you to refuse or accept it.

In general, you are not required to provide personal information when you visit our website. However, if you apply to receive information about our services, or wish to apply for a job, provision of certain information will be required.

We are not responsible for the practices employed by Websites linked to or from our Website or the information or content contained therein. Often, links to other Websites are provided solely as pointers to information on topics that may be useful to the users of our Website. Please remember that when you use a link to go from our Website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which have a link on our Website, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.

Children’s Privacy Protection

We understand the importance of protecting children’s privacy in the online world. Our website is not designed for or intentionally targeted at children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13. It is our policy to never knowingly collect or maintain information about anyone under the age of 13, except as part of a specific engagement to provide professional services which necessitates such personal information be collected.

Gaining access to the personal information we hold

You may request in writing access to personal information held by us. This right of access is subject to exceptions allowed by law. The request must be made in writing to the Privacy Officer. Please see ‘Privacy Officer Contact Details’ for how to contact us.

Accuracy of personal information

We are committed to ensuring that personal information is accurate, complete and up to date. Accordingly, please provide us in writing of any changes to the personal information you have provided. Furthermore, if you believe the personal information held by us is not accurate, complete or up to date, please contact the Privacy Officer and we will take all reasonable steps to correct the information.

Complaints Resolution

We are committed to providing a fair and reasonable system for the handling of complaints from parties whose personal information we hold. We will address any concerns you have through our complaints handling process. If you have any concerns regarding the way we have handled personal information, please contact our Privacy Officer in writing.

If you believe that Johnston Grocke has not adequately handled your privacy complaint, you may complain to the Office of the Australian Information Commissioner.

Office of the Australian Information Commissioner

GPO box 5218

Sydney NSW 2001

1300 363 992

enquiries@oaic.gov.au

Privacy Officer Contact Details

Email office@jgg.com.au or write to us at 290 Glen Osmond Road, FULLARTON SA 5063 or telephone on (08) 8303 0300

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