PRIVACY POLICY

OVERVIEW

The objective of this policy is:

1. ensuring lawful/ethical handling of personal information;
2. maintaining confidentiality and trust;
3. complying with Privacy Act/APP obligations

Lambourne Partners is committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act).

This Privacy Policy sets out how Lambourne Partners handles personal information, excluding personal information collected that is exempt under the Privacy Act (i.e. employee records).

In this Privacy Policy, ‘Lambourne Partners’, ‘we’, ‘us’ and ‘our’ is a reference to the Lambourne Partners partnership and includes any entity carrying on business in Australia that is part of the Lambourne Partners group.

This policy applies to all Lambourne employees as well as contractors, partners and service providers handling information. This policy also supports professional obligations under APES 110, including acting with integrity, objectivity and the public interest.

1. PERSONAL INFORMATION WE COLLECT

The types of personal information we collect depends on the nature of our engagement. Examples of personal information we may collect include:

• names, job titles, contact and address details;
• information in identification documents (for example: passport or driver’s licence);
• tax file numbers and other government-issued identification numbers;
• date of birth and gender;
• bank account details, shareholdings and details of investments;
• details of superannuation and insurance arrangements;
• educational qualifications, employment history, salary and referee reports;
• visa or work permit status;
• payment details; and
• personal information about your spouse and dependants.

It is generally not practical to remain anonymous or to use a pseudonym when dealing with Lambourne Partners as usually we need to use your personal information to provide specific services to you, or which relate to or involve you.

2. HOW WE COLLECT AND MANAGE PERSONAL INFORMATION

2.1 How we collect personal information

Generally we collect your personal information from you directly (for example, when we deal with you in person or over the phone, when you send us correspondence (including via email), when you complete a questionnaire, form or survey, when you subscribe to our publications or when you use our website or our social media).

Sometimes it may be necessary for us to collect your personal information from a third party. For example, we may collect your personal information from your employer where they are our client, from your personal representative or a publicly available record.

We may also collect personal information about you from your use of our websites and information you provide to us through contact mailboxes or through the registration process on our websites.

2.2 Where you provide us with personal information about someone else

If you provide us with someone else’s personal information, you should only do so if you have their authority or consent to provide us with that information. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy or any Privacy Collection Statement we give you.

2.3 Retention and disposal of personal information

Lambourne Partners holds personal information in hard copy and electronic formats. We take security measures to protect the personal information we hold including physical (for example security monitored and locked/secured office, storage of files in lockable cabinets) and technological (for example, restriction of access, firewalls, the use of encryption, passwords and digital certificates).

In some cases, Lambourne Partners engages third parties to host electronic data (including data in relation to the services we provide) on our behalf. Lambourne Partners will retain personal information only for as long as it is reasonably required to meet business, legal, regulatory, professional and contractual obligations.

Personal information must be retained in accordance with applicable legislative requirements, professional standards, record keeping obligations and any relevant internal retention schedules. Where no specific retention period applies, the information must not be kept longer than is reasonably necessary for the purpose for which it was collected.

At the end of the applicable retention period, or where personal information is no longer required, Lambourne Partners will take reasonable steps to securely destroy, de-identify or permanently delete the information, having regard to the nature of the information and the method of storage.

Secure disposal methods may include confidential shredding of physical records, secure deletion of electronic files, deletion from systems and devices, and appropriate management of archived or backed-up information where reasonably practicable.

All personnel are required to ensure that personal information is not informally discarded, retained unnecessarily, or stored in locations or systems outside approved business processes.

2.4 Purpose for collecting, holding, using and disclosing personal information

Lambourne Partners collects, holds and uses personal information for a number of purposes including:

• to provide and enhance our services
• to respond to requests or queries
• to maintain contact with our clients and other contacts, and keep them informed of our services, industry developments, seminars and other events
• to verify your identity
• for administrative purposes, including processing payment transactions
• for recruitment purposes
• when engaging service providers, contractors or suppliers relating to the operation of our business
• to manage any conflict of interest or independence (including auditor independence) obligations or situations
• to conduct surveys
• for seeking your feedback
• to meet any regulatory obligations
• to develop our expertise and know how, for benchmarking purposes, analytics, quality assurance and thought leadership, and other purposes related to our business.

As part of an engagement, if you are a customer, an employee, a contractor or supplier of services to one of our clients, then we may disclose your personal information as part of providing services to that client.

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

• experts or other third parties contracted as part of an engagement
• our agents, third party contractors and suppliers
• our professional advisers
• government or regulatory bodies or agencies, as part of an engagement or otherwise, (for example, the Australian Taxation Office).

We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you. However, we may share non-personal, de-identified or aggregated information with select third parties for research or promotional purposes other than direct marketing.

3. DIRECT MARKETING

Lambourne Partners may use your personal information for the purpose of marketing its services to you.

If you do not want to receive marketing material from us, you can contact us as detailed below:

• for electronic communications, you can click on the unsubscribe function in communications; or
• for hard copy communications, you can email info@lambourne.com.au or
• through our contact details on our website.

4. PRIVACY ON OUR WEBSITE

4.1 Automatic collection of personal information

Cookies and other technologies are used by Lambourne Partners and its service providers on some Lambourne Partners websites and through email to automatically collect certain types of information. The collection of this information allows us to improve the effectiveness of Lambourne Partners online environment and to measure the effectiveness of our marketing activities.

If you register on the Lambourne Partners web site and provide information about yourself, we will use your information to personalise your experiences with Lambourne Partners (through marketing and communications). If you access the Lambourne Partners web site (or other social media account) using a third-party account (such as LinkedIn, Google or Twitter), we may collect any information you have permitted the third-party service to share (i.e. your name and email address, depending on the privacy settings you have selected with the third-party provider and their privacy policy).

4.1.1 IP address

Public IP addresses from which visitors to the Lambourne Partners website and social media accounts may be used to conduct web site trend and performance analysis.

4.1.2 Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit the Lambourne Partners website and social media accounts. This allows the site to remember your computer or device and serves a number of purposes.

Cookies by themselves do not tell us you’re your identity (i.e. email address or personal information). However, we may use the details collected from cookies (i.e. IP addresses), for the purpose of trend analysis (i.e. number of visitors to our web sites and their geographic location).

4.1.3 Analytics Tools

Lambourne Partners uses analytics tools (such as Google Analytics) to provide details about visitors to our website. Users are able to make choices on how their data is collected by Google Analytics through their Google Analytics Opt-out Browser Add-on (the add-on indicates to Google Analytics that information about the visit should not be provided by Google Analytics). It is noted that the Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

More information about how Google Analytics is used can be found at https://www.google.com/analytics/terms/us.html

4.1.4 Social media

Some Lambourne Partners websites and services may enable information gathering and sharing through third party social media applications (i.e. Facebook Like button).

These social media applications may collect and use information regarding your use of the Lambourne Partners websites and social media pages. Any personal information that you provide via such social media applications may be collected and used by those social media applications whom are separate to Lambourne Partners.

Such interactions that are monitored by social media applications are governed by the privacy policies of the relevant companies that provide the applications. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, Lambourne Partners may host blogs and forums. The purpose of these media sources are to facilitate the sharing of knowledge and content across Lambourne Partners network. Any personal information that you provide on these blogs and forums may be shared with other users of that social media platform, outside of Lambourne Partners control, unless otherwise stated at the point of providing the information.

4.1.5 Location-based tools

Lambourne Partners may collect and use the geographical location of your computer or mobile device. This data is collected for the purpose of analysing the visitors to our website and social media accounts.

4.2 Third party websites

Lambourne Partners websites contains links to third party websites. Those other websites are not subject to our privacy policy and procedures and the users will need to review the privacy policy of those third party websites. Lambourne Partners does not take any responsibility for the collection and control of the private information supplied to third party websites.

Unless expressly advised, Lambourne Partners does not endorse or approve the services or products provided on any third party website.

4.3 Subscriptions

You are not required to provide any personal information when visiting the Lambourne Partners websites. However, if you subscribe to receive information about our updates or request us to contact you, provision of certain personal information will be required to facilitate these requests.

5. INFORMATION ACCESS REQUESTS

You can request access to your personal information, subject to some limited exceptions as permitted or required by law. Such request must be made in writing to Lambourne Partners using the following details:

• via email at info@lambourne.com.au or
• via post to:
  PO Box 1050
  HAMILTON NSW 2303

6. KEEPING PERSONAL INFORMATION CURRENT

If you believe that any personal information collected about you by Lambourne Partners is inaccurate, not up-to-date, incomplete, irrelevant or misleading, you may request correction. To do so, please contact your Lambourne Partners key account contact and we will take reasonable steps to correct it in accordance with the requirements of the Privacy Act.

7. DATA BREACHES / PRIVACY INCIDENTS

Any actual, suspected or potential privacy breach, unauthorised access, unauthorised disclosure, loss of personal information, or cyber incident affecting personal information must be reported immediately to the appropriate internal contact or responsible manager.

On becoming aware of a potential privacy incident, Lambourne Partners will take reasonable steps to contain the incident, secure affected information and systems, and assess the nature and scope of the issue.

All privacy incidents must be assessed promptly to determine the type of information involved, the cause and extent of the incident, the individuals potentially affected, and the likelihood of serious harm occurring.

Where required, the matter will be escalated internally for investigation and response, including consideration of legal, regulatory, client, insurer and operational implications.

Lambourne Partners will assess whether the incident gives rise to obligations under the Notifiable Data Breaches scheme, including whether there are reasonable grounds to believe that an eligible data breach has occurred.

Where an eligible data breach is identified, Lambourne Partners will take reasonable steps to comply with applicable notification obligations, including notifying affected individuals and the Office of the Australian Information Commissioner, as required.

Privacy incidents will be documented, investigated where appropriate, and reviewed to identify any control improvements, training needs, or system changes required to reduce the risk of recurrence.

8. COMPLAINTS

If you wish to make a complaint to Lambourne Partners about our handling of your personal information, you can contact Lambourne Partners Privacy Officer on the below details:

Privacy Officer
Lambourne Partners
PO Box 1050
HAMILTON NSW 2303

Or via email at info@lambourne.com.au attention to the Privacy Officer.

Lambourne Partners will endeavour to reply to you within 30 days of receipt of the complaint and, where appropriate, will advise you of the general reasons for the outcome of the complaint.

In some circumstances, Lambourne Partners may decline to investigate the complaint (for example if the complaint relates to an act or practice that is not an interference with the privacy of the person making the complaint).

If you are not satisfied with the outcome of your complaint, you can refer your complaint to the Office of the Australian Information Commissioner.