GREEN LIGHT BOOKKEEPING

PRIVACY POLICY

1. OVERVIEW

Green Light Bookkeeping is committed to privacy protection and compliance with applicable privacy laws and standards, and will manage personal information in an open and transparent way. Green Light Bookkeeping will fulfil its obligations under the Privacy Act of 1988 (including the Amendment (Enhancing Privacy Protection) Act 2012 (Cth)), by complying with the Australian Privacy Principles (APPs). These 13 principles detail how organisations should collect, update, use, keep secure or where necessary disclose and give access to personal information, as well as how complaints should be handled and how, in some circumstances, anonymity can be maintained.

2. SCOPE

This policy applies to all employees, contractors, customers and suppliers. It applies to the collection, updating, use, storage, disclosure and access to personal and sensitive information that can be recorded in any format including, but not limited to, information held in writing, online, digitally or by electronic means, including mobile phones and USB sticks.

3. POLICY

3.1 COLLECTION

3.1.1 Your personal information

Information collected and held by Green Light Bookkeeping could include name, current and previous address, telephone number(s), driver licence number, bank account details, Tax File Number, date of birth, diversity status, and relevant sensitive (e.g. health) information, as well as details of your trading with us e.g. numbers, financial and business details (suppliers and customers) information.

Green Light Bookkeeping will:

3.1.1.1 where reasonable and practicable to do so, collect personal information about an individual from that individual

3.1.1.2 ensure that individuals are aware that, in some circumstances, information may be provided anonymously or by using a pseudonym unless

(a) Green Light Bookkeeping is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves or
(b) it is impracticable for Green Light Bookkeeping to deal with individuals who have not identified themselves or who have used a pseudonym

3.1.1.3 not collect, update, use, store or disclose personal, health or business information to another party without written consent from an individual, business or Green Light Bookkeeping

3.1.1.4 only collect personal information that is necessary for its functions or activities

3.1.1.5 only collect information by lawful and fair means, without unwarranted coercion and in a way that is not unreasonably intrusive 

3.1.1.6 when, or as soon as practicable after, collecting personal information from an individual, Green Light Bookkeeping will take reasonable steps to ensure that the individual is aware of:

a) Green Light Bookkeeping’s identity and contact details
b) how to access the information
c) how to update the information
d) the purpose for which the information is collected
e) the types of entities to which Green Light Bookkeeping usually discloses information of that kind, and, where relevant, the countries in which overseas recipients are likely to be located
f) any law that requires the particular information to be collected
g) the main consequences (if any) for the individual if all or part of the information is not provided
h) Green Light Bookkeeping’s Privacy Policy which contains information about how the individual may access the personal information about the individual and seek the correction of such information, and
i) how to complain about a breach of the Australian Privacy Principles.

3.1.1.7 if personal information is collected from someone other than the individual, take reasonable steps to ensure that the individual is made aware of the matters listed above except to the extent that making the individual aware of the matters would pose a serious threat to the life or health of any individual

3.1.1.8 inform all managers and staff by way of the Privacy Policy that no personal information or business details are to be given to another party without the consent/and or guidance of the National Senior Executive Human Resources or Chief Executive Officer

3.1.1.9 inform the party/s concerned of the reason for collecting, using, storing or disclosing such information

3.1.1.10 inform the party/s concerned of the main consequences if all or part of the information is not provided.

3.1.2 Where our information comes from

Green Light Bookkeeping collects personal information in a number of ways:

3.1.2.1 directly from you when you apply to us for employment as part of our recruitment of employees process, or training services, on an application form

3.1.2.2 from freely available “public domain” information sources e.g. telephone directories

3.1.2.3 from our own records of how and when you use our various services

3.1.2.4 from third parties, such as previous employers or organisations you have dealt with in the past and volunteered by you as a reference for the purposes of employment or credit checks prior to the opening of an account with us.

3.1.3 Unsolicited information

3.1.3.1 If Green Light Bookkeeping receives unsolicited personal information, we will, within a reasonable period after receiving the information, determine whether or not the information could have been collected by lawful and fair means.

3.1.3.2 If Green Light Bookkeeping determines that we could not have collected the personal information, and the information is not contained in a Commonwealth record, Green Light Bookkeeping will, as soon as practicable, but only if it is lawful and reasonable to do so, destroy the information or ensure the information is de-identified.

3.1.3.3 If Green Light Bookkeeping determines that the information could have been collected by lawful and fair means, we will apply the Australian Privacy Principles in relation to the information as if we had collected the information under the Australian Privacy Principles.

3.2 USE AND DISCLOSURE

3.2.1 How we use information

Green Light Bookkeeping will only use this information to:

3.2.1.1 provide the service(s) you have requested. This may be payment for work done, invoicing for work completed by one of our employees, or providing training services and reporting results

3.2.1.2 manage those services in order to provide the optimum level of service for your individual needs

3.2.1.3 conduct appropriate credit, police and/or “Working with Children” checks, and pre-employment checks e.g. reference checking or pre-employment medical advice

3.2.1.4 advise you of other services that we provide, that may be of interest to you.

3.2.2 When we use or disclose information

3.2.2.1 Green Light Bookkeeping will only disclose information about you to others on an as needs basis or where required by law. These people or organisations may include,
a) your authorised representative or legal advisors b) banks or credit providers for payroll purposes or credit related functions such as the provision of account facilities c) government and statutory authorities, where required by law, for example the reporting of training results for a registered trainee; Australian Taxation Office; or nominated superannuation fund d) Green Light Bookkeeping‘s Privacy Officer / National Senior Executive Human Resources who believes that use of the information is necessary to prevent or lessen a serious and imminent threat to the life or health of the individual concerned or another person.

3.2.2.2 Green Light Bookkeeping will only use or disclose personal information for a purpose (the secondary purpose) other than the primary purpose of collection if:
a) the individual has consented to the use or disclosure of the information or b) the individual would reasonably expect the information to be used or disclosed for the secondary purpose and c) if the information is sensitive, it is directly related to the primary purpose or d) if the information is not sensitive, it is related to the primary purpose or e) the use or disclosure of the information is required or authorised by or under an Australian law or court/tribunal order or f) a permitted general situation exists or g) a permitted health situation exists or h) Green Light Bookkeeping reasonably believes that the use or disclosure is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

3.2.3 Record of use and/or disclosure & de-identification

If Green Light Bookkeeping uses or discloses personal information under the previous paragraph we will make a written note of the use or disclosure, and will take reasonable steps to ensure that the information in de-identified before disclosure.

3.2.4 Exceptions

These guidelines on use and disclosure of personal information do not apply for the purposes of direct marketing or the use of government related identifiers,

3.2.5 Direct marketing

3.2.5.1 Green Light Bookkeeping may use personal information (other than sensitive information) about an individual for the purposes of direct marketing if:

a) Green Light Bookkeeping collected the information from the individual and the individual would reasonably expect Green Light Bookkeeping to use the information for that purpose or
b) Green Light Bookkeeping collected the information from someone other than the individual and either
(i) the individual has consented to the use or disclosure of the information for that purpose or
(ii) it is impracticable to obtain that consent.
c) Green Light Bookkeeping may use personal contact details for the purposes of direct marketing if:
(i) Green Light Bookkeeping is a contracted service provider for a Commonwealth contract and
(ii) Green Light Bookkeeping collected the information for the purpose of meeting (directly or indirectly) an obligation under the contract and
(iii) the use is necessary to meet (directly or indirectly) such an obligation.

And for any of the above situations, Green Light Bookkeeping will provide a simple means by which the individual may easily request not to receive direct marketing communications from Green Light Bookkeeping and will make all reasonable efforts to ensure no further direct marketing is sent to those contact details.

3.2.5.2 Green Light Bookkeeping will not disclose personal or sensitive information to any other party through direct marketing. 

3.2.5.3 Green Light Bookkeeping will make all reasonable efforts to remove the individual’s contact and personal details if the individual communicates this request through the response point to the origin of the direct marketing or through any other Green Light Bookkeeping corporate communication media.

3.2.5.4 If Green Light Bookkeeping uses personal information about an individual for the purpose of direct marketing by Green Light Bookkeeping or to facilitate direct marketing by other organisations the individual may:

a) request not to receive direct marketing communications from Green Light Bookkeeping
b) request Green Light Bookkeeping not to use or disclose the information for the purpose of direct marketing by other organisations 
e) request Green Light Bookkeeping to provide its source regarding this information.

3.2.5.5 If and when an individual makes a request under the above sub-clause 3.2.5.4, 

a) Green Light Bookkeeping will not charge the individual for the making of, or to give effect to, the request to remove their details from future direct marketing and
b) if the request is not to receive direct marketing communications from Green Light Bookkeeping for its own direct marketing or for the facilitating direct marketing by other organisations, Green Light Bookkeeping must give effect to the request within a reasonable period after the request is made and c) if the request is that Green Light Bookkeeping provide its source of information, Green Light Bookkeeping will, within a reasonable period after the request is made, notify the individual of its source unless it is impracticable or unreasonable to do so.

3.2.5.6 This principle does not apply to the extent that any of the following apply:

a) the Do Not Call Register Act 2006
b) the Spam Act 2003
c) any other Act of the Commonwealth, or a Norfolk Island enactment, prescribed by the regulations.

Google Adwords advertising
Green Light Bookkeeping uses the following features of Google Adwords for the purpose of promoting its services

remarketing
interest categories
similar audiences
interest-based advertising
demographic and location targeting.
In conducting the above activity with Google Adwords Green Light Bookkeeping will not collect personally identifiable information (PII) including, but not limited to, email addresses, telephone numbers, and credit card numbers use or associate personally identifiable information with remarketing lists, cookies, data feeds, or other anonymous identifiers use or associate targeting information, such as demographics or location, with any personally identifiable information collected from the ad or its landing page share any personally identifiable information with Google through our remarketing tag or any product data feeds which might be associated with our Google Adwords ads send Google precise location information without obtaining people’s consent. Green Light Bookkeeping will abide by the policy for sensitive categories outlined below.

When creating a remarketing list, we will not use any sensitive information about our site or app visitors, whether collected directly or associated with a visitor, based on the visitor’s profile or behaviour on our site or app Ad content will not imply knowledge of personally identifiable or sensitive information.

3.3 DATA QUALITY – Have we got the right information?

Green Light Bookkeeping will:

3.3.1 take such steps

(if any) as are reasonable in the circumstances to ensure that the personal information we collect, use and where appropriate disclose to others is accurate, complete, and up to date

3.3.2 if satisfied that,

having regard to the purpose for which the information is held, the information is inaccurate, out of date, incomplete, irrelevant or misleading or

3.3.3 if the individual requests Green Light Bookkeeping

to correct the information take such steps (if any) as are reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading

3.3.4 when correcting personal information

about an individual that we previously disclosed to another organisation also respondent to the Australian Privacy Principles, and if the individual requests us to do so, we will take such steps (if any) as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so

3.3.5 give the individual a written notice

if we refuse to correct the personal information, as requested by the individual, setting out

(a) the reasons for the refusal except to the extent that it would be unreasonable to do so and
(b) the mechanisms available to complain about the refusal and 
(c) any other matter prescribed by the regulations.

3.3.6 if the individual and Green Light Bookkeeping disagree about whether the information is inaccurate, incomplete, out of date, irrelevant or misleading, and the individual asks Green Light Bookkeeping to associate with the information a statement that the information is inaccurate, incomplete, out of date, irrelevant or misleading, Green Light Bookkeeping will take such steps as are reasonable in the circumstances to associate the statement in such a way that will make the statement apparent to users of the information.

3.4 DATA SECURITY

Green Light Bookkeeping will:

3.4.1 take reasonable steps

to ensure the information held is protected from misuse, interference and loss as well as from unauthorised access, modification or disclosure. Limited access will be given to authorised personnel only, and only where Green Light Bookkeeping believes they reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs

3.4.2 have physical,

electronic, and procedural safeguards in place that comply with federal regulations to protect personal and business information about you

3.4.3 store information

electronically or in paper files secured in locked offices where necessary

3.4.4 take reasonable steps

to destroy or permanently de-identify personal information if it is no longer required, is not contained in a Commonwealth record, and Green Light Bookkeeping is not required by or under an Australian law, or a court/tribunal order, to retain the information.

3.5 OPENNESS

3.5.1 This Privacy Policy

sets out Green Light Bookkeeping’s corporate policy on management of personal information and is available to anyone who asks for it. It can also be accessed via our website: www.greenlightbookkeeping.com.au

3.5.2 If a copy of Green Light Bookkeeping’s Privacy Policy

is requested in a particular form, Green Light Bookkeeping will take such steps as are reasonable in the circumstances to provide a copy in that form.

3.5.3 On request Green Light Bookkeeping

will take reasonable steps to let a person know, generally, what sort of personal information it holds, for what purposes, and how it collects, holds, uses, updates and discloses that information about a person.

3.6 ACCESS AND CORRECTION

3.6.1 Your rights to access

3.6.1.1 You have the right to access any information held by Green Light Bookkeeping about you, subject to some restrictions listed in Federal Government legislation

For example:
a. if providing access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety or
b. if providing access would have an unreasonable impact upon the privacy of other individuals or
c. the request for access is frivolous or vexatious or
d. the information relates to existing or anticipated legal proceedings between Green Light Bookkeeping and the individual, and would not be accessible by the process of discovery in those proceedings or;
e. providing access would reveal the intentions of Green Light Bookkeeping in relation to negotiations with the individual in such a way as to prejudice those negotiations or
f. providing access would be unlawful or;
g. denying access is required or authorised by or under an Australian law or a court/tribunal order or
h. Green Light Bookkeeping has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to Green Light Bookkeeping’s functions or activities has been, is being, or may be engaged in and
i. providing access would be likely to prejudice the taking of appropriate action in the matter or
j. providing access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body, or 
k. providing access would reveal evaluative information generated within Green Light Bookkeeping in connection with a commercially sensitive decision-making process.

3.6.1.2 However where providing access would reveal evaluative information generated within Green Light Bookkeeping in connection with a commercially sensitive decision-making process, Green Light Bookkeeping may give the individual an explanation for the commercially sensitive decision rather than direct access to the information.

3.6.1.3 If Green Light Bookkeeping is not required to provide the individual with access to the information because of one or more of above-stated reasons, Green Light Bookkeeping will, where reasonable in the circumstances, give access in a way that meets the needs of both Green Light Bookkeeping and the individual, including through the use of a mutually agreed intermediary.

3.7 GOVERNMENT RELATED IDENTIFIERS

3.7.1 Green Light Bookkeeping

will not adopt a government related identifier of an individual as its own identifier of the individual unless:

a) required or authorised by or under an Australian Law or a court/tribunal order or
b) the identifier is prescribed by the regulations and 
c) Green Light Bookkeeping is prescribed by the regulations, or is included in a class of organisations prescribed by the regulations and
d) the adoption, use or disclosure occurs in the circumstances prescribed by the regulations.

3.7.2 Green Light Bookkeeping

will not use or disclose a government related identifier of an individual unless:

(a) the use or disclosure of the identifier is reasonably necessary to verify the identity of the individual for the purposes of our activities or functions or
(b) the use or disclosure of the identifier is reasonably necessary to fulfill our obligations to a government agency of State or Territory authority or
(c) the use or disclosure of the identifier is required or authorised by or under an Australian law or a court/tribunal order or
(d) a permitted general situation exists in relation to the use or disclosure of the identifier or
(e) Green Light Bookkeeping reasonably believes that the use or disclosure of the identifier is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, and enforcement body.

3.8 ANONYMITY

Wherever it is lawful and practicable, individuals will have the option of not identifying themselves, or of using a pseudonym, when dealing with Green Light Bookkeeping, except:

3.8.1 when Green Light Bookkeeping

is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves or

3.8.2 it is impracticable for Green Light Bookkeeping

to deal with individuals who have not identified themselves or who have used a pseudonym.

3.9 CROSS-BORDER DISCLOSURE OF PERSONAL INFORMATION

3.9.1 Green Light Bookkeeping

will only transfer personal information about an individual to someone (other than within our organisation or to the individual) who is an overseas recipient if:

a. Green Light Bookkeeping has taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to the information or
b. Green Light Bookkeeping reasonably believes that the recipient of the information is subject to a law or binding scheme that has the effect of protecting the information in a way that is substantially similar to the Australian Privacy Principles, and
c. there are mechanisms that the individual can access to take action to enforce that protection of the law or binding scheme or 
d. the individual consents to the disclosure, in which case
e. Green Light Bookkeeping will expressly inform the individual that if he or she consents to the disclosure of the information, we will not take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to the information, however, we will then re-check that the individual still consents to the disclosure
f. the disclosure of the information is required or authorised by or under an Australian law or a court/tribunal order or;
g. a permitted general situation exists in relation to the disclosure of the information by Green Light Bookkeeping
h. the disclosure of the information is required or authorised by or under an international agreement relating to information sharing to which Australia is a party or
i. Green Light Bookkeeping reasonably believes that the disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body and
j. the recipient is a body that performs the functions, or exercises powers, that are similar to those performed or exercised by an enforcement body.

3.10 SENSITIVE INFORMATION

3.10.1 Green Light Bookkeeping

will not collect sensitive information about an individual unless:

a. the individual has consented to the collection of the information and
b. the information is reasonably necessary for one of more of our functions or activities and
c. the information relates solely to individuals who have regular contact with Green Light Bookkeeping in connection with our activities or
d. the collection of the information is required or authorized by or under an Australian law or a court/tribunal order or
e. a permitted general situation exists in relation to the collection of the information or
f. a permitted health situation exists in relation to the collection of the information.

3.11 REQUESTS FOR INFORMATION

3.11.1 Green Light Bookkeeping will not disclose any personal information without first establishing the identity of the person requesting the information.

3.11.2 If access to personal information held by Green Light Bookkeeping is required, a written request specifying the information sought may be made to an individual’s usual contact at Green Light Bookkeeping or the Privacy Officer / National Senior Executive Human Resources. Adequate identification by or authority from an individual must be supplied to Green Light Bookkeeping before any personal information will be provided

3.11.3 Access to personal information will be provided within five business days of receiving a request. If this cannot be complied with Green Light Bookkeeping will advise within the five-day period when access will be provided.

3.11.4 The nature and the timing of access will be agreed between Green Light Bookkeeping and the individual.

3.11.5 Green Light Bookkeeping may charge a reasonable fee for providing access to personal information, (but not for lodging a request for access).

3.11.6 If Green Light Bookkeeping refuses access due to subclause 3.6.1.1, we will provide written notice to the individual which sets out:

(a) the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so
(b) the mechanisms available to complain about the refusal, and
(c) any other matter prescribed by the regulations.

3.12 COMPLAINTS

3.12.1 Any complaint by an individual regarding Green Light Bookkeeping’s management or handling of personal information should be directed to Green Light Bookkeeping’s Privacy Officer. Contact details are set out below.

3.12.2 To enable a complaint to be properly understood and acted upon it is requested that it be made in writing, specifying the personal information involved and the contact or process at Green Light Bookkeeping that is the subject of the complaint.

3.12.3 All complaints will be acknowledged within three (3) working days of receipt. Contact details of the person dealing with the complaint and the Privacy Officer will also be advised to the individual making the complaint at this time.

3.12.4 Complaints will be responded to within fifteen (15) working days. If this is not possible the individual will be advised as to when Green Light Bookkeeping expects to be able to respond.

3.12.5 If Green Light Bookkeeping’s response does not resolve the complaint Green Light Bookkeeping and the individual will, in good faith, promptly agree to a process and time frame for dealing with the complaint.

4. RESPONSIBILITIES

4.1 Privacy Officer / National Senior Executive Human Resources

The responsibilities of the Privacy Officer will include:

4.1.1 investigating any complaints raised with respect to privacy and personal information

4.1.2 reviewing he organisation’s current and future practices and procedures to ensure compliance with this policy and current legislation

4.1.3 reviewing this policy and advising on the education of management and staff of their responsibilities under this policy and providing information on the Privacy and Health Records Acts.


If you have any questions relating to privacy or the storage of information about you, please contact us on online at Green Light Bookkeeping and ask for the Privacy Officer in relation to Green Light Bookkeeping’s Privacy Policy.