This privacy policy applies to the management of your personal information by or on behalf of NRD Pty Ltd ATF NRD Discretionary Trust T/A JMP Accountants ABN 62 539 058 711 its subsidiaries and affiliates in Australia (including J M Partners Pty Ltd (ACN 081069132)) (collectively referred to as (“JMP Accountants”/ “we” / “us”/ “our”).
JMP Accountants provides professional accounting and taxation services in Australia (“services”). Information about us and the services we provide are viewable at https://www.jmpartners.com.au (“website”).
We have created this Privacy Policy to demonstrate our commitment to the Privacy Act 1988 Cth (“Privacy Act”), the Australian Privacy Principles (“APPs”) and other applicable privacy laws (together, the “Australian Privacy Laws”). It sets out how we may collect, hold, use or disclose your personal information.
This Privacy Policy applies to all personal information collected by us, including personal information collected or submitted through our website. When we use the term “personal information” we use it in the same way as defined in the Privacy Act.
We take privacy very seriously and are committed to the protection of your privacy. By providing your personal information to us, you understand we will handle and treat our personal information in accordance with the practices described in this Privacy Policy. If you do not agree with any of the terms of this Privacy Policy, please do not submit any personal information to us.
Other terms may also apply to you and the personal information we hold about you (for example where we provide you with a specific privacy collection notice or if the EU General Data Protection Regulation applies).
What information do we collect?
The type of personal information we collect will vary depending on the nature of your dealings with us. We have outlined this in more detail below.
Clients and prospective clients
When you (or a business you represent) enquires about our services (including a business-to-business client), a record is made which includes your personal information. If you elect to become a client of JMP Accountants, we will also collect personal information from you. The type of personal information that we collect will vary depending on the circumstances of collection and if you are a natural person. For natural persons, the type of personal information we collect typically includes:
• your name;
• contact details including your phone number, email address and mailing/delivery address (including where those details are related to a business you represent);
• your professional details (such as your job title);
• information about your employer or an organisation you represent (if you contact us in a business capacity);
• information your tax and accounting affairs, including your tax file number, banking details, credit card information and credit history;
• any other information you provide to us when we provide services to you; and
• any additional information relating to you that you provide to us directly or indirectly through the use of our website or online presence.
To provide some of our services, you may provide us with personal information which relates to another person (for example, name and business contact details of a person who is the contact in a company or government agency with whom we provide concurrent services to under our letter of engagement). If you provide us with personal information about any other person, you must obtain that person’s permission to give us their personal information and inform them of our privacy policy.
Prospective employees/applicants
We collect personal information when recruiting personnel, such as your name, contact details, qualifications, and work history (including references and other information included in a CV or cover letter as part of the application process). Generally, we will collect this information directly from you.
Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks (including criminal checks) to determine your suitability for certain positions. If you are offered a position with us, then we may also collect other personal information directly from you including your date and place of birth, your emergency contact’s name and contact details. From time to time we may also collect sensitive information you provide us as an employee, for example in relation to your health, criminal record and security clearance.
What happens if you don’t provide us your information?
You can always decline to give us any of the personal information we request, but that may mean we cannot provide you with some or all the services you have requested, we may not be able to do business with you effectively or we may not be able to offer you employment. If you have concerns about the personal information we have requested, please let us know.
How we collect your information
Generally, we collect your personal information directly from you, for instance, we collect your personal information as part of us providing and offering our services, or as a part of your prospective or current employment. This includes when you provide your personal information to us in person, when you access our website, during phone and video calls, by email, via social media, or otherwise via client enquiries or communications. For current employees, we may also collect your personal information via internal messaging systems.
We may also collect your personal information from other people or organisations if you have given your consent, for example from:
• our affiliated and related companies;
• government agencies, third party suppliers, and contractors who assist us to operate our business (this is discussed further below);
• from any person you direct us to obtain information from (for instance your bank and xero); and
• in respect of prospective employees / job applicants, from recruitment agencies or referees you have nominated.
Where personal information is collected from a third party, JMP Accountants will treat your personal information in accordance with the practices described in this privacy policy. JMP Accountants cannot guarantee the accuracy of personal information provided by a third party.
Why do we need your personal information?
Generally, we collect and hold your personal information so we may provide services to you, or as is reasonably necessary for our business functions or activities, including to assess and manage our clients’ needs. We may also collect information for employment related matters, or to fulfil functions associated with our services, for example, billing and managing clients, and other business relationship and development activities.
The purposes for which we collect and use your personal information depends on the nature of your interaction with us, but may include:
• to provide you our services;
• researching, developing, expanding and improving our services;
• administering your account with us;
• analysing your interactions and use of our website to understand and improve the effectiveness of our marketing initiatives;
• keeping and updating records and databases to ensure the smooth operation of our business;
• communicating with you about changes or developments to our services and business or in the normal course of business dealings;
• responding to your enquiries or requests for help or information, including about any service we provide you;
• managing our relationship with you, including if you are a supplier, or business partner; and
• if you are our current or prospective employee, then we will use your personal information in relation to your actual or potential employment.
(Permitted Purposes)
If you do not provide us with your personal information, we may not be able to carry out some or all of the Permitted Purposes.
How do we use or disclose your information?
By submitting your personal information to us via any means, you consent to us using or disclosing your personal information for:
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the Permitted Purposes;
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any purpose related to the Permitted Purposes that could be reasonably anticipated at the time your personal information was collected (Secondary Purpose);
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any purpose to which you direct us to or otherwise agree to (including as disclosed to you in an information collection statement at the point where we collect your personal information);
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any other purpose required or authorised by law (including under the Privacy Law); and
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to CPA Australia or Chartered Accountants Australia + NZ (CAANZ) for the purpose of conducting practice reviews (including the CPA Australia Best Practice Program assessment and the CAANZ quality and practice program review) on the services we provide. If your personal information is disclosed to CAANZ or CPA Australia, your personal information will be handled as outlined in the CAANZ Privacy Policy, the CPA Australia Privacy Policy and the member collection notice (as applicable).
Secondary Purposes may include: sending you direct marketing about our products or services, deals and promotions; conducting client surveys; monitoring how you interact with us on our website or other contact points. Secondary Purposes may also include marketing, administrative, management and operational purposes including statistical analysis and reporting, training staff, contractors and other workers, risk management and management of legal liabilities and claims (for example, responding to legal orders and obligations, liaising with insurers, and obtaining advice from our legal representatives).
Where we disclose your personal information to third parties (see below for further information on this point), your personal information will be dealt with in accordance with the privacy policies of those third parties.
Notwithstanding the above, we will only use or disclose your tax file number and associated information (including for matching personal information about individuals) to the extent authorised by taxation law, personal assistance law or superannuation law.
Disclosure to our affiliates or related entities
In providing services to you we may disclosure your personal information to our affiliates or related body corporates.
Disclosure to our service providers
To provide services to you, or otherwise as permitted under this policy, will disclose your personal information to government agencies including the ATO and ASIC. We may also disclose your personal information to our outsourced service providers (such as professional advisors we use to assist us to deliver services to you), cloud computing providers, payment gateway providers or any other party with responsibilities relevant to the services we provide you (Service Providers). We will only disclose your personal information a Service Provider to extent necessary for us to provide you with our professional services or otherwise to administer our relationship with you.
For prospective employees / job applicants
To assist us with our recruitment process, we may disclose your personal information to those employees who it is necessary for your personal information to be disclosed to as part of the recruitment process as well as recruitment agents and other advisers who assist with recruitment.
Non-Personally Identifiable Information
We may use certain non-personally identifiable information (such as anonymous usage data, IP addresses, browser or platform type etc.) to improve the quality and design of our website, and to create new features, promotions, functionality and services by storing, tracking, analysing and processing user preferences and trends as well as user activity and communications.
Can you remain anonymous or use a pseudonym?
We will, if practicable, allow you to use a pseudonym or to not identify yourself (unless this is impractical or against the law (including the Australian Privacy Laws)). Where required by law, we also redact certain personal information (such as your tax file number) before sharing it with our Service Providers.
However, given the nature of the services we provide, if you do not provide us with some of your personal information, we may not be able to provide you with the relevant service or information. This may have an effect on whether we can begin or continue a relationship with you.
Overseas use and disclosures
Generally speaking, we use and disclose your personal information for the purposes set out above in “How do we use or disclose your information”). Some of our Service Providers, or the services they provide (like our outsourced provides), may be based outside Australia (which may include without limitation in the Philippines and Vietnam). In order to protect your personal information, we take care where possible to only work with subcontractors and other service providers who we consider maintain acceptable standards of data security compliance, and we do our part to meet those standards as they apply to us.
By providing us with your personal information, you consent to your personal information being used, stored and disclosed overseas (and acknowledge that no additional obligations that may apply to the overseas disclosure of personal information under Privacy Laws will apply).
Is your information confidential and secure?
We take all reasonable steps to keep your personal information secure and to ensure it is protected against misuse, loss, unauthorised access, modification, or inappropriate disclosure. We may hold your personal information in both hard copy and electronic forms but will store it in secure systems accessible only to authorised personnel.
We host your personal information that we collect in secure server environments that are protected by industry best practices in an effort to prevent interference or access from unauthorised persons.
Do we use “cookies”?
When you visit our website, the server may attach a "cookie" to your computer's memory. A “cookie” assists us to store information about how you use our website and to make assumptions about what information may be of most interest to you. This information is generally not linked to your identity and can include information such as the type of device or browser you’re using, IP address, your device ID (a numeric identifier for your mobile device, if you access our website using a mobile device), the time of your visit, the duration and the pages you accessed on our website. We may use knowledge of your user experience to better understand what products or services may be of interest to you and to collect statistical information.
Most browsers can be set to detect cookies and you can control how your browser deals with cookies by changing your browser settings (for example by rejecting cookies). However, in doing so, you may not be able to use certain content on our website and may not have the same user experience.
Using third party websites and services
Our website may contain links to other websites, platforms or applications. Unless the other website, platform or application is one of our products, we are not responsible for the privacy practices of the owners of those websites, platforms, or applications. We recommend that you read the privacy policy of any website, platform, or application that asks you to provide your personal information.
Changes to our Privacy Policy
We may need to change this privacy policy from time to time. When we do amend it, the changes will be effective immediately upon being made public on our website. We will use reasonable measures to notify you of any relevant changes to this privacy policy, but please be aware that it is your responsibility to review our privacy policy regularly and make sure you keep up to date with any changes.
Managing your information
You are responsible for ensuring that your personal information is accurate, current and complete and we encourage you to contact us to update your personal information if it changes.
You may ask us to access your personal information in accordance with the Privacy Law including by asking us to provide you with a summary of your personal information that we hold, subject to certain limitations under the Privacy Law.
For your protection, we may require you to confirm your identity before access to your personal information is granted.
In most cases, we can provide you with a summary of your personal information free of charge. However, in some circumstances, reasonable costs may be charged to you in accessing your personal information in accordance with and subject to the Privacy Law, including in respect of any costs limitations.
If you believe that any of your personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your personal information.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
Deletion of your information
In some instances, you may request that we delete some or all of your personal information, and if requested, we will take reasonable steps to destroy the information.
However, we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations. If you ask to delete information which we are permitted by law or have compelling legitimate interests to keep, we may not be able to fully meet your request.
Queries and complaints
If you have a question or want to make a complaint about how we handle your personal information, please contact us using the details below. We will review any question, complaint or concern you may have and will respond to you after we have carefully considered it. We will, where reasonably possible, take steps to investigate and resolve complaints within 30 days. Please note, we may require further information from you to resolve any complaints. If we need more time, we will notify you about the reasons for the delay and seek to agree a longer period with you (if you do not agree, we may not be able to resolve your complaint). If we cannot resolve a complaint related to your privacy information, you may contact the Office of the Australian Information Commissioner (“OAIC”) directly.
We can be contacted via our Privacy Officer:
Email: info@jmpartners.com.au
Or for more information about privacy issues in Australia and protecting your privacy, please visit the OAIC website at www.oaic.gov.au.
Last date Updated: August 2022
