Privacy Policy

This Privacy Policy outlines how Douglas Partners Pty Ltd ABN 75 053 980 117 and its related bodies corporate (we, our, us) manage your personal information.^[1]

We treat your personal information with integrity and respect, which are values that are at the core of our company. We comply with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) to protect your personal information.

This Privacy Policy can be accessed freely at any time via our website at www.douglaspartners.com.au. We may update this Privacy Policy from time to time. We will notify you of any changes by uploading an updated version of the Privacy Policy to our website at www.douglaspartners.com.au.

1. What personal information do we collect?

‘Personal information’ is information or an opinion about an identified individual or an individual who is reasonably identifiable. We only collect personal information that is reasonably necessary for the conduct of our business. The kinds of information we may collect include:

your name, physical address, postal address, email address, telephone number, tax file number, occupation, qualifications, employer, position;
your bank account and credit card details if you provide them to us for payment of an account;
information relating to you that you provide to us directly through our website or indirectly through use of our website;
information about services you have engaged us for or enquired about;
information including your image collected via our surveillance systems;
your opinion about our services or staff;
your employment history and other information provided to us during the recruitment process, if you apply for a job with us.

The information must be collected directly from you unless an exemption applies. For example, collection can be required or authorised by an Australian law or a court/tribunal order or it may be unreasonable or impracticable to collect the personal information from you.

Sensitive personal information includes health information about an individual. Sensitive personal information can only be collected where it is reasonably necessary for the conduct of our business and with your consent, unless an exemption applies. Exemptions include where the collection is required or authorised by Australian law. The kinds of sensitive personal information we may collect from you include your COVID-19 vaccination status.

2. How do we collect your personal information?

Whenever it is reasonable and practicable to do so, we will collect personal information directly from you in a lawful and fair manner.

We may collect personal information in ways including:

through your access to and use of our website or Wi-Fi services;
when you make an enquiry, complete a purchase order or enter into a contract for services with us;
through your participation in feedback surveys or questionnaires;
through our CCTV systems;
through your communications with us including conversations, letters, emails or other methods of communication.

We may also collect personal information from third parties, such as our subcontractors, our service providers, law enforcement agencies, other government entities, your agent or your employer.

When you apply for a job with us we may collect personal information from you, recruitment consultants, previous employers and referees.

We may collect sensitive personal information when you are applying as a prospective employee. For example, in collecting information about your COVID-19 vaccination status, we will outline that this information is collected to create a safe work environment and comply with relevant Australian laws where applicable.

3. What happens if we are not able to collect your personal information?

If you decide not to provide us with the personal information described above, the following may happen:

we may not be able to provide our services to you, to the same standard, or at all;
we may not be able to provide you with information about our services;
we may not be able to consider your application for employment.

4. Use of cookies

We use third party applications, such as Google Analytics, to perform data analysis. Google uses cookies to tell us how you use our website. You can turn these off at any time through your own browser settings. Cookies are small text files that are placed on your computer by websites that you visit. You can turn these off at any time through your own browser settings.

5. How and why do we collect, store, use and disclose your personal information?

We collect, store, use and disclose your personal information for the following purposes:

to administer our relationship with you, communicate with you, provide you with our services and receive payment for our services;
to answer your enquiries and provide you with information and updates about our services;
to assess the performance of our website and make improvements to it;
for security and risk management purposes, such as incident investigation and loss prevention;
for business planning and quality control;
to process and respond to any request or complaint made by you;
to update our records;
to administer your shareholding in a related body corporate;
to comply with any applicable law, rule or regulation;
to consider and process your employment application.

6. Who do we disclose your personal information to?

We may disclose your personal information for the purposes described in this Privacy Policy to:

consultants, agents or contractors acting on our behalf;
parties to whom we have outsourced various functions, including contractors and services providers for the purposes of operating our website and our business, IT systems administrators such as Microsoft, couriers, payment processors, insurance brokers, insurers, debt collectors and professional advisors such as lawyers, accountants and business advisors;
regulatory authorities or government agencies where required by law; or
third parties who have a lawful reason to request the information.

If all or part of our business is sold to or merged with a third party we may transfer any personal information we hold about you to that third party. We may also disclose personal information to prospective purchasers on a confidential basis.

Where we disclose any personal information to a third party we request that those parties do not use the information for their own purposes and comply with this Privacy Policy.

Your personal information cannot be disclosed for another secondary purpose unless you consent to the disclosure or it is reasonable.

7. Do we disclose your personal information outside Australia?

We store your personal information within Australia. Some of the third party suppliers and service providers that we use may store your personal information outside of Australia in countries such as the USA.

We will take reasonable steps to ensure that overseas recipients deal with your personal information in a manner that is consistent with the Privacy Act and this Privacy Policy.

8. Direct marketing communications

We may send you direct marketing communications consisting of information about our services that we think may be of interest to you. Your personal information can be used for direct marketing when the information has been collected from you and it can be reasonably expected that this information would be used for that purpose. These communications may be sent by email in accordance with the Spam Act 2003 (Cth) or post in accordance with Australian Privacy Principle 7. You may opt-out of receiving marketing communications from us at any time by contacting the sender, by using our contact details provided below, or using opt-out facilities provided in an electronic communication (such as an unsubscribe button).

9. How do we keep your personal information secure?

We may hold your personal information in either electronic or hard copy form. We use reasonable technical and organisational security safeguards to protect your personal information against unauthorised access, collection, use, disclosure, copying, loss, modification or destruction.

Our staff are required to maintain the confidentiality of the personal information we hold.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

We will retain your personal information only for as long as we have a lawful purpose to use it. This means we may retain your personal information for a reasonable period after your last interaction with us. We take all reasonable steps to ensure that personal information we no longer need is securely destroyed.

10. Third party links

Our website may contain links to websites operated by third parties. We are not responsible for the privacy practices or the content of any third party websites. The privacy policies of those websites may differ from this Privacy Policy.

11. How can you access and correct your personal information?

You may request access to or correction of the personal information we hold about you by contacting our Privacy Officer using the contact details provided below.

Where we hold information that you are entitled to access, we will provide a suitable means for you to access it, such as by emailing or mailing it to you. We will not charge you for making the request or for providing the information to you.

There may be instances where we cannot provide you with access to your personal information. For example, we may need to refuse access where giving access would breach the privacy of another individual or would result in a breach of confidentiality. If your request to access your personal information is frivolous or vexatious then we are not required to give you access. If these situations occur, we will give you written reasons for the refusal.

If you believe your personal information is incorrect, incomplete or inaccurate, you may request that we amend it. We will consider whether the information requires amendment. In some cases we may not agree that there are grounds for amending your personal information. If that happens, we will add a note to your personal information stating that you disagree with it.

12. How can you make a complaint?

You can make a complaint about the way we have handled your personal information by contacting our Privacy Officer. A complaint should first be made in writing and our Privacy Officer should be given a reasonable period after the request is made to respond. We will endeavour to investigate and respond promptly to your complaint. Our Privacy Officer can be contacted at:

Email: [email protected]
Address: Attention: Privacy Officer, Douglas Partners, PO Box 472, West Ryde, NSW 1685

The complaint may then in the next stage be taken to the Office of the Australian Information Commissioner.

You may also contact the Office of the Australian Information Commissioner at:
Phone: 1300 363 992
Website: www.oaic.gov.au
Address: GPO Box 5218, Sydney, NSW 2001

Last updated February 2022

This Privacy Policy does not apply to employee records. This is covered under our Personnel Records policy.