Johnstone Haines & Fergusson (“JHF”) understands the importance of protecting the privacy of an individual’s personal information. This policy set out how JHF aims to protect the privacy of your personal information, your rights in relation to your personal information managed by JHF and the way JHF collects, holds, uses and discloses your personal information.
Generally, the kinds of personal information JHF collects are:
- Contact and identification information such as your name, address, telephone number and email address;
- Information relating to your interests;
- Where you are acting on behalf of another entity (whether as an employee, director or other representative), details of that entity and your relationship with it;
- Financial information about your assets, occupation and income, account balances, account activities, payment history and transactions with us or third parties;
- Details of directorships, shareholdings or other investments you hold;
- Credit information, being credit related personal information lawfully created and accessible within the Australian credit reporting system.
Generally, JHF collects your personal information directly from you, through the completion of a manual or online form an interaction or exchange in person or by way of telephone, facsimile, email, post or through JHF’s website. There may be occasions when JHF collects your personal information from other sources such as:
- An entity you represent (including but not limited to your employer or a company of which you are a director), where necessary for JHF to provide its services to that entity through you;
- The completion of an application form by another person or entity that lists you as a director, guarantor, potential guarantor or trade reference;
- An information or credit service provider;
- A publicly maintained record or other publicly available sources of information;
- A government agency.
Generally, JHF will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.
JHF collects, hold, uses and discloses your personal information where it is reasonably necessary for the purposes of:
- Providing to you our products and/or services;
- Responding to your requests;
- Providing you with further information about JHF;
- Identifying and informing you of products, services and events of JHF or selected third parties that may be of interest to you;
- Accounting, billing and other internal administrative purposes;
- Any other legal requirements.
JHF may also use your personal information for purposes related to the above purposes and for which you wold reasonably expect JHF to do so in the circumstances, or where you have consented or the use is otherwise in accordance with the law.
Where personal information is used or disclosed, JHF takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to JHF. However, without certain information from you JHF may not be able to provide its services to you.
JHF discloses your personal information for the purposes of providing its services to you. JHF disclosures of your personal information to third parties are on a confidential basis and/or otherwise in accordance with law. JHF may also disclose your personal information with your consent or if disclosure is required or authorised by law.
JHF may also store, process or back-up your personal information on computer servers or networks which are located overseas or in the cloud.
JHF takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. JHF holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.
JHF will destroy or de-identify personal information in circumstances where it is no longer required, unless JHF is otherwise required or authorised by law to retain the information.