1. Introduction
This Privacy Policy explains the way in which Addisons (ABN 55 365 334 124) and Addisons Fidelity Pty Limited (ABN 52 440 084 279) (collectively Addisons, we, us and our) collects, holds, uses and discloses personal information. We respect the confidential and private nature of any information you provide to us. We are bound by and deal with the personal information you provide to us in accordance with the Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles (the APPs).
2. What is personal information?
When we refer to “personal information”, we mean information or an opinion about you, from which you are, or may reasonably be, identified. This information may include (but is not limited to) your name, date of birth, phone number, email address and address.
Personal information may also include information which is “sensitive information” under the Privacy Act. Sensitive information includes, for example, information or an opinion about an individual’s health, racial or ethnic origin, criminal record or membership of a professional association, trade association or trade union.
3. What kinds of personal information do we collect from you?
The types of personal information we collect from you will depend on the nature of your relationship with us. For example:
- If you are a client, potential client or their personnel, we will collect your name, job title, contact detail, communications between you and us, financial information, and other information you may provide to us.
- If you are a representative of a supplier, we may collect your name, business name and work contact details including address, phone number and email address. We will also collect your business’ Australian Business Number (ABN) and bank account details.
- If you apply for employment with Addisons or are an employee, we may collect, for example, your full name, contact details (including address, phone number and email address), job title, passport details, employment history and education details, names and contact details of referees, next of kin details (in the event of an emergency) and superannuation fund and Tax File Number details, if required by law, for example, under the Superannuation Guarantee (Administration) Act, the Superannuation Industry (Supervision) Act or the Income Tax Assessment Act and Taxation Administration Act.
From time to time, we may also collect sensitive information from you, where we consider it necessary to do so. This may include, for example, health information, dietary requirements if you are attending an event we are hosting or membership details of professional or trade associations or political parties. If we do collect sensitive information from you, we will not do so without first obtaining your consent.
You do not have to provide us with your personal information. However, if you do not provide us with certain information, we may not be able to provide you with the legal or other services that you require.
4. How do we collect your personal information?
We collect personal information about you in the following ways:
- directly from you when you provide it to us in person, by email, by telephone, through our website (for example if you complete an online form), or by any other means (such as via virtual meetings). This may occur when you engage our services, contact us with a query, attend a seminar we are hosting, subscribe to our newsletters or submit a job application, among other things.
- from third parties, for example, your authorised representatives, other professional advisors, our clients, counter-parties to transactions or disputes, recruitment platform providers, recruiters, referees, event or conference organisers, public registers and government and regulatory bodies.
If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy.
5. How do we use and disclose your personal information?
We will use and disclose your personal information for the purposes for which it was collected and related purposes such as:
- providing you with legal advice or other agreed services, which may include engaging with third parties, such as barristers, expert witnesses, dispute resolution service providers, copying services and search service providers;
- maintaining our relationship with you;
- assessing applications from prospective employees, contractors and service providers;
- conducting our business (for example, our internal accounting or business management processes such as service development and improvement and risk assessment);
- organising events and seminars;
- marketing our services, including providing you with information from time to time which we think may be of interest to you, for example, by keeping you informed of legal developments or events, such as seminars or forums that we hold; and
- complying with our legal and regulatory obligations, including our Anti-Money Laundering / Counter-Terrorism Financing (AML/CTF) obligations.
If you are a job applicant, employee or contractor with Addisons, we will use your personal information for purposes relating to your engagement, training, performance management, payroll, superannuation, health and safety, for administration and staff management purposes. Where we consider it appropriate, we may also conduct reference checks (or engage a third party to do so on our behalf).
We will only use or disclose your personal information for another purpose if:
- you have consented to the use or disclosure;
- the use or disclosure is permitted or required under an Australian law or a court or tribunal order; or
- you would reasonably expect us to use or disclose the information to provide you with the services you have requested.
If we disclose your personal information to third parties, we will only do so on a confidential basis and in accordance with our legal and professional obligations. These third parties, who may assist us in providing our services to you and in managing our business, may include, for example:
- our accounting or auditing service providers;
- photocopying and archive service providers;
- experts or external legal counsel we may engage on your behalf;
- government or regulatory bodies or public registers (such as the Australian Securities and Investment Commission, the Australian Taxation Office, Australian Stock Exchange or IP Australia);
- software providers who assist us in the operation of our business such as our customer relationship management software (CRM) platform provider;
- other service providers, such as legal process servers, mail houses, event organisers and investigators; and
- law enforcement bodies, courts and tribunals.
We do not sell, rent or otherwise trade your personal information.
Occasionally, the personal information you provide us may be disclosed to third parties outside Australia where necessary to conduct our business and provide you with the services you require. These are likely to include, for example, overseas clients, overseas law firms and third parties who assist us with providing services
The privacy laws in other countries might not be the same as in Australia. However, where we do provide your personal information to third parties overseas, Addisons is committed to ensuring that the recipients are bound by confidentiality obligations and that your personal information is handled in accordance with this Privacy Policy.
6. Is your personal information used for marketing?
From time to time, we may send you marketing materials, such as firm information, newsletters, Insights on topics you may be interested in, invitations to seminars or events we are hosting, offers to participate in surveys and other publications or resources. (This may include by post, email, telephone, LinkedIn or other means.)
If you do not wish to receive any information or communications of this kind, you can unsubscribe from our contact list:
- in relation to email – by clicking the “unsubscribe” link at the bottom of each email you receive;
- in relation to any other marketing materials – by contacting us through the avenues listed below in the ‘Contact Us’ section and informing us that you wish to be removed from our contact list.
7. Security of your personal information
We take reasonable steps to protect the personal information we hold from:
- misuse, interference and loss; and
- unauthorised access, modification or disclosure.
We store personal information in electronic format and sometimes also in hard copy.
Records containing personal information are accessible to employees of Addisons to enable them to perform their duties. Addisons’ employees are subject to confidentiality and privacy requirements. Access to our premises is controlled.
Access to files in our records managements system is limited. Personal information in our network is password protected. Electronic records are stored in our own secure network and through third party data storage providers. Our third party data storage providers must hold personal information in accordance with applicable laws and are required to use appropriate technical and organisation measures to protect against unauthorised or unlawful use of personal information or its accidental loss, destruction or damage.
All personal information held by Addisons is stored in Australia.
8. Does our website use cookies?
Cookies are small files that store information on your computer, mobile phone or other device. Our website uses cookies or similar tracking technologies for different purposes. Some cookies help us track website use and improve the website’s performance and this information is anonymous and is only used for statistical purposes. However, our website uses tracking cookies so, if you are a client of Addisons and your details are in our CRM database and you visit our website, the tracking cookie may identify you as an existing contact. Similarly, if you have completed an online form on our website, a cookie will be used to remember your details from the previous session when you next complete a form on our website.
You can disable cookies through your internet browser and, if you do so, this will not affect your use of our website.
9. Links to other websites
This website may contain links to other websites that may be of interest to you. The websites to which we provide links are not subject to this Privacy Policy and we are not responsible or liable for the content and activities of these linked sites. You should check the other websites for details about their privacy policies.
10. How can you access and/or correct your personal information?
We take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
If you wish to access and/or correct the personal information we hold about you, please send us a written request (signed by you or your guardian or power of attorney):
- by post to: GPO Box 1433 Sydney NSW 2001;
- by email to: [email protected], and including in the subject line the title:
- “Privacy – Access to personal information request”; or
- “Privacy – Correction of personal information request.
We may seek further information from you to verify your identity and/or clarify details of any request made.
We will endeavour to deal with your request as soon as is reasonably practicable.
We may refuse your access and/or correction request in certain circumstances in accordance with the APPs or where otherwise required by law. If we do refuse your request, we will provide you with reasons for our refusal (unless it would be unreasonable for us to do so) and measures which you can take to complain about any refusal. If we refuse your correction request, we will include a statement with your personal information about the requested correction (if you ask us to do so).
There is no charge for requesting access to or the correction of the personal information we hold about you.
11. How can you make a complaint?
We are committed to treating seriously all complaints made by any person concerning the privacy of any personal information we hold about them.
Any complaint you may have relating to the privacy of any personal information held by Addisons must be made in writing and signed by you, your guardian or your power of attorney. Complaints should be sent:
- by email to: [email protected], and using the title “Privacy Complaint” in the subject line; or
- by post to: GPO Box 1433 Sydney NSW 2001.
Our Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint.
Your complaint will then be investigated. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within a reasonable time, usually within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If, after receiving our response, you are not satisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
12. Variation of the Privacy Policy
We may vary this Privacy Policy from time to time. This will be done by way of an update to our website to include any changes to this Privacy Policy. Where changes to the Privacy Policy are material, reasonable notice of the changes will be provided (for example by posting a notice on our website) before the changes take effect. By continuing to use the website, use our services or provide us with your personal information, you acknowledge that you have read and accept these changes.
13. Contact Us
If you have any further questions or concerns about this Privacy Policy or the privacy of your personal information collected by Addisons, please contact us:
- by email to: [email protected]and including the title “Privacy Query” in the subject line; or
- by post to: GPO Box 1433 Sydney NSW 2001.
Date: October 2024