PRIVACY POLICY

In the course of carrying out instructions, it is necessary for Vincent Partners to collect and store certain personal information. This Privacy Policy outlines how Vincent Partners manages that personal information. It also summarises:

the sort of personal information that we record;
why we record it; and
how that information is collected, held, used and disclosed.

This Privacy Policy applies to all our dealings with clients.

Personal Information

The information we collect includes all information that may be necessary for us to carry out instructions. This may happen when we are provided with personal information during an appointment, by correspondence, over the telephone or by any other means. In certain cases we collect personal information from third parties, for example, from credit reporting agencies, government authorities, financial advisers, accountants or bankers.
Unless it is necessary for the work that we are carrying out, we will not generally collect information about our clients that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of professional or trade associations, membership of trade unions, details of health, disability, sexual orientation or criminal record. In certain circumstances we may also be required to collect government identifiers (for example, tax file numbers, Medicare/Health Insurance Commission numbers, pension card numbers).

Using and Disclosing Personal Information

All personal information is held, used or disclosed consistently with the applicable privacy laws. Other than information that may be available as a matter of public record or which is disclosed to us during the course of our instructions, we will not use or disclose any of this information other than:

when required or authorised by law;
by the client that the information relates to; or
if it is necessary to do so in order to carry out instructions.

In certain circumstances personal information may be provided to:

other agents or representatives, for example process servers, accountants or bankers;
relevant organisations as required or authorised by law, for example, government or regulatory bodies for purposes related to public health or safety, the prevention or detection of unlawful activities or similar purposes;
anybody that a client consents or instructs us to.

Audits
Certain information may be made available for our internal audit purposes, although it remains strictly confidential and our auditors are bound by similar privacy obligations. Clients must let us know in advance if they do not want any information made available to our auditors so that appropriate arrangements can be made.
Vincent Partners is required to report details of transactions involving cash of $10,000.00 or more to the Australian Transaction Reports and Analysis Centre. It is an offence to conduct or structure transactions in such a way to avoid those reporting requirements.

Protecting Personal Information

Personal information is stored in various ways including on paper, electronic and digital format. The security of personal information is a priority and we take reasonable care to protect it from misuse, loss, unauthorised access, modification or disclosure. Our security procedures include:

confidentiality requirements for our employees;
secure document storage security policies;
security measures for computer and systems access;
providing a discreet environment for the confidential transaction of business;
restricting access to personal information to individuals who satisfy our identification and security requirements;
access control to our buildings, records and archives.

Access to Personal Information

Any client can gain access to their personal information. This may be subject to some exceptions including if:

access would pose a serious threat to the life or health of any individual;
access would have an unreasonable impact on the privacy of others;
a request is frivolous or vexatious;
the information relates to a commercially sensitive decision making process;
access would be unlawful;
access would prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security function or negotiations;
there is a legal dispute or action in progress or pending;
denying access is required or authorised by or under law;
there is a cost to retrieve or obtain the information and that cost is not paid.

We will provide reasons if access to any information is refused.

Vincent Partners do not sell, share, disclose or release personal information concerning our clients except as outlined in this Policy.

Queries