Progression Accountants & Business Advisors Pty Ltd respects your privacy and is committed to protecting your personal and financial information. This Privacy Policy explains how we collect, use, disclose and protect your Personal Information when you visit our website or use our accounting and advisory services.

What is Personal Information?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we may collect or be provided with include, but are not limited to your name, contact details, date of birth, employment and business details, tax and financial information, bank account details, identification information, details of company officers and beneficial owners, and records of our communications with you.

Why do we collect it?

We collect Personal Information that is reasonably necessary for us to provide accounting, taxation, business advisory and related services, establish and manage our relationship with you, verify identity and ownership information, meet our legal, regulatory and professional obligations, process payments, communicate with you, manage risk, and operate and improve our business.

When you visit our website or submit an enquiry, we may collect the contact information and other details you choose to provide, together with limited technical information required to operate, secure and maintain the website. Our website may use essential cookies for these purposes. We may also use your contact details to send newsletters and service updates, and you may unsubscribe at any time.

Sensitive Information

Sensitive information is a category of personal information that includes information or an opinion about an individual’s racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union or professional association membership, sexual orientation or practices, criminal record, health information, genetic information and certain biometric information. We will only collect sensitive information where it is reasonably necessary for our functions or activities and you have consented, or where the collection is otherwise required or authorised by law. We will use or disclose sensitive information only for the purpose for which it was collected, for a directly related secondary purpose that you would reasonably expect, with your consent, or as otherwise permitted by law.

Government Related Identifiers and Tax File Numbers

Government related identifiers include driver licence, passport and Medicare numbers. Tax file numbers are subject to separate legal requirements. We may collect, use or disclose these identifiers where reasonably necessary to verify your identity, provide taxation or related professional services, and comply with our legal and regulatory obligations. We handle government related identifiers in accordance with the Australian Privacy Principles and tax file number information in accordance with the Privacy (Tax File Number) Rule 2015 and other applicable laws.

Third Parties

We generally collect Personal Information directly from you. We may also collect it from your authorised representatives, employers, business associates, government agencies and registers, identity-verification providers, publicly available sources, and our website or other digital services. Where required, we will take reasonable steps to notify you of the circumstances of the collection.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

·       To your authorised representatives, professional advisers and service providers that assist us to deliver our services;

·       To government agencies and regulators, including the ATO, ASIC and AUSTRAC, where required or authorised by law; and

·       To other third parties with your consent or where required or authorised by law.

Security and Retention of Personal Information

We take reasonable technical and organisational measures to protect your Personal Information from misuse, interference, loss, and unauthorised access, modification or disclosure. These measures may include access controls, secure systems, multifactor authentication, staff confidentiality obligations, data backups and service-provider reviews.

We retain Personal Information only for as long as required for the purposes for which it was collected, to meet our legal and professional obligations, or to protect our legitimate interests. When it is no longer required, we take reasonable steps to securely destroy or de-identify it.

Access to and Correction of your Personal Information

You may request access to, or correction of, the Personal Information we hold about you by contacting us in writing. We will respond within a reasonable period and may ask you to verify your identity before providing access or making a correction.

We do not charge a fee for making an access or correction request. We may charge a reasonable administrative fee for providing access to your Personal Information and will advise you of any fee before proceeding. If we are unable to provide access to, or correct, your Personal Information, we will explain our decision in writing where legally required and advise you how to lodge a complaint.

Maintaining the Quality of your Personal Information

We take reasonable steps to ensure that the Personal Information we collect is accurate, up to date and complete, and that the information we use or disclose is accurate, up to date, complete and relevant for its intended purpose. If you believe the Personal Information we hold about you is inaccurate, incomplete, out of date, irrelevant or misleading, please contact us so that we can review and, where appropriate, correct our records.

Anti‑Money Laundering (AML) and Counter‑Terrorism Financing (CTF)

Where we provide services that are regulated under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), we may collect, use and disclose Personal Information to verify your identity and beneficial ownership, conduct customer due diligence, assess and manage money laundering, terrorism financing and proliferation financing risks, and meet our reporting and record-keeping obligations. This information may include identity details, ownership and control information, corporate structures and, where reasonably necessary, information about the source of funds or wealth.

We will only collect and retain Personal Information that is reasonably necessary for these purposes and will take reasonable steps to protect it from misuse, interference, loss and unauthorised access, modification or disclosure. We may be required to disclose information to AUSTRAC or other authorised government or law enforcement bodies. In some circumstances, the law may restrict the information we can provide to you about a report or disclosure. Further details are included in the privacy collection notice.

Electronic identity verification using APLYiD
We use APLYiD to verify your identity and assist us in meeting our anti-money laundering and counter-terrorism financing obligations. We handle the Personal Information we receive through the verification process in accordance with this Privacy Policy. APLYiD separately handles Personal Information collected or processed through its service in accordance with APLYiD’s Privacy Policy.

Privacy Collection Notice

Progression Accountants & Business Advisors Pty Ltd collects Personal Information from you, your authorised representatives and, where appropriate, identity-verification providers, government registers and publicly available sources. We collect this information to provide our services, verify your identity and beneficial ownership, conduct customer due diligence, assess and manage financial crime risks, and comply with our legal, regulatory and professional obligations, including obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) where applicable.

If you do not provide the information we reasonably require, we may be unable to verify your identity, complete our onboarding process or provide a regulated service to you. We may disclose your information to our technology and identity-verification providers, professional advisers, related service providers, and government agencies or regulators such as AUSTRAC where required or authorised by law. We may use APLYiD to electronically verify your identity. We handle the Personal Information we receive through the verification process in accordance with our Privacy Policy. APLYiD separately handles Personal Information collected or processed through its service in accordance with APLYiD’s Privacy Policy.

We handle your Personal Information in accordance with our Privacy Policy, which explains how you may request access to or correction of your information and make a privacy complaint. Some of our employees, contractors or service providers located overseas, including in the Philippines may access, process, store or receive your Personal Information to assist us in providing our services. Other overseas locations may vary depending on the service providers and technology platforms we use from time to time. Further information about relevant countries may be requested using the contact details below. We take reasonable steps to ensure that Personal Information accessed or disclosed overseas is handled in accordance with applicable Australian privacy laws. For privacy enquiries, please contact us at admin@progression.com.au or 03 9457 9000.

Policy Updates

We may update this Privacy Policy from time to time. The latest version is available on our website.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about how we handle your Personal Information, please contact us using the details below:

Level 1, 460 Lower Heidelberg Road

Heidelberg VIC 3084

admin@progression.com.au

03 9457 9000

We will acknowledge your complaint, investigate the matter and respond within a reasonable timeframe.