Policy last updated: 21/03/2019

1. Purpose and nature

The International Fiscal Association Australia Limited (ACN 627 904 429) (Company) recognises the importance of your privacy. This Privacy Policy explains how the Company intends to collect, store, use, disclose, protect and otherwise handle your personal information having regard to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988(Cth) (Privacy Act).

This Privacy Policy does not constitute a contractual representation, promise, guarantee or warranty by the Company to you as to the manner in which the Company will or may collect, store, use, disclose, protect or otherwise handle your personal information.  Some matters are beyond the control of the Company, such as third party malicious or criminal attacks.

2. What is personal information?

Personal information is information or an opinion about you from which you can be reasonably identified.

3. Why does the Company collect personal information?

The Company collects personal information in connection with providing, administering, improving and personalising its services and membership benefits and marketing, and to support its business functions. The Company may also use your personal information for secondary purposes closely related to these primary purposes. If the Company does not collect your personal information, it may not be able to provide you with these services and membership benefits.

4. What personal information does the Company collect?

The types of personal information collected by the Company include:

• 1. names;
  2. contact details (including address, email address, telephone number(s) and other contact details);
  3. dates of birth;
  4. gender;
  5. occupation;
  6. usernames and passwords; and
  7. other information you provide to us.

4.2. Sensitive Information

The personal information collected by the Company may include sensitive information, which is defined in the Privacy Act as information or an opinion about such things as 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. The Company will only use sensitive information:

• 1. for the primary purpose for which it was obtained;
  2. for a secondary purpose that is directly related to the primary purpose;
  3. with your consent; or
  4. where required or authorised by law.

5. How does the Company collect your personal information?

The Company will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner. When you provide the Company with personal information you consent to the use, disclosure and handling of your personal information in accordance with this Privacy Policy and any subsequent amendments (see clause 12).

5.1. Collecting information from you

If it is reasonable and practical do to so, the Company will collect personal information directly from you.

Depending on how you choose to interact with the Company, the Company may collect your personal information when you contact, or are contacted by, the Company or its service providers by telephone, by email, through the Company’s website, apps, social media and other digital services or when you complete a form or document and provide it to the Company.

5.2. Collecting information from third parties

The Company may also collect information about you from other people (eg, a third party administrator) or independent sources. For example, the Company may collect personal information about you from its service providers. However, the Company will only do so where it is not reasonable and practicable to collect the information from you directly. Where the Company has collected your information from a third party, such personal information will be held, used and disclosed by the Company in accordance with this Privacy Policy.

5.3. Collecting information from visits to the Company’s website

The Company may also collect information based on how you use its websites, including through ‘cookies’, web beacons and other similar technologies.

Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable the Company’s systems to recognise your browser and record non-personal information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie Information).

We use cookies to provide you with a more consistent experience across our services. No attempt is made by the Company to use Cookie Information to personally identify you. However, if Cookie Information is linked with personal information as set out above, this Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.

You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of the Company’s websites may not function fully for users that disable cookies.

5.4. Unsolicited information

If the Company receives personal information that it has not requested and determines that the personal information received is not reasonably necessary to provide its services, the Company will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.

6. How does the Company hold your personal information?

The security of your personal information is important to the Company. Accordingly, the Company takes reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification or disclosure. These steps include the implementation of the following: password protected databases and limited permission access to personal information.

The Company will take reasonable steps to permanently de-identify or responsibly destroy personal information if it is no longer needed for the purpose for which the information was used or disclosed.

6.1. Security breach procedures

The Company’s data security practices have been adopted with a view to protecting the data held by the Company.  Notwithstanding this, individuals should be aware that there are inherent risks associated with the transmission of data over the internet and other mediums. Accordingly, the Company cannot guarantee any transmission will be completely secure.

7. How does the Company use your personal information?

The Company may hold, use or disclose your personal information so that it can provide benefits to its members and provide any other products or services that you request.

The Company may also hold, use or disclose your personal information to:

• 1. consider any concern or complaint that you raise against the Company or to manage any legal action between you and the Company;
  2. prevent or investigate any actual or suspected fraud, unlawful activity or misconduct; or
  3. comply with any relevant laws, regulations, codes of practice and court orders.

7.1. Direct Marketing

The Company may also use your personal information to identify and promote products, services or events that may be of interest to you.

At any time, you may opt out of receiving direct marketing communications from the Company. To do so, you may use the opt out link within an email or contact us by email on admin@ifa-australia.com.au. Unless and until you opt out, your consent to receive direct marketing communications from the Company and to the handling of your personal information for this purpose will continue.

8. How is personal information disclosed to others?

The Company does not sell, rent or trade personal information to, or with third parties.

The Company may disclose your personal information to third parties in limited circumstances, including to the global International Fiscal Association and the Company’s service providers.

The Company’s website may contain certain links to other websites. The Company does not share your personal information with those websites and it is not responsible for the privacy practices applying in respect of those websites.

8.1. Cross-border disclosure

The Company may disclose your personal information to the global International Fiscal Association, the Netherlands, to assist the Company in providing its services and member benefits. For information on the privacy policy of IFA in the Netherlands, see www.ifa.nl/privacy-policy.

9. How you may access or correct your personal information

You may contact the Company to request access to the personal information it holds about you at any time. You may also ask the Company to correct information about you that you may believe is inaccurate, incomplete or out of date.

Please contact the Company using the contact details set out in clause 11. The Company will need to verify your identity before giving you access to, or correcting, your personal information. The Company will respond to the request within a reasonable period after the request is made. There is no charge to make a request, however the Company may charge a reasonable fee to cover the administrative costs of retrieving your personal information.

In certain circumstances, the Company may refuse, or be unable, to correct or provide you with access to your personal information. In these circumstances, the Company will write to you to explain the reasons why this is the case.

10. How you may complain if you have concerns about how the Company has managed your personal information

If you have a complaint related to how the Company has managed your personal information, please contact the Company using the contact details set out in clause 11. The Company may ask you to place your concerns in writing so that its compliance staff can fully understand and investigate your complaint.

The Company will provide you with an estimated response timeframe in relation to your complaint. In any event, the Company will endeavour to respond to your complaint with 30 days.

If a complaint remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.auto have the complaint heard and determined.

11. How to contact us

If you have any questions about this Privacy Policy or the Company’s management of your personal information, please contact the Company by email on admin@ifa-australia.com.au.

12. Changes to the Company’s privacy policy and information handling practices

This Privacy Policy is subject to change, so we encourage you to review this Privacy Policy at regular intervals. If the Company changes this Privacy Policy, an updated version will be posted on the Company’s website to notify you of this change. By continuing to use the Company’s services after that time you will be deemed to have accepted any changes to its Privacy Policy.