Privacy Policy

Green & Sternfeld (“we” and “our”) are committed to providing you with the highest levels of service. This includes protecting your privacy. We adhere to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (as updated). This Privacy Policy sets out the practices that will be followed to respect the privacy of individuals who deal with Green & Sternfeld including how we collect, manage and use personal information. There are requirements of the APPs which we will adhere to that are not specifically described in our Privacy Policy but are deemed to be incorporated into this Privacy Policy,

In our Privacy Policy, personal information has the same meaning as in the Privacy Act, namely it means information about an identified individual or an individual who is reasonably identifiable.

Collection of information

The type of information collected by Green & Sternfeld regarding individuals generally includes the following:

names
current and previous addresses (including e-mail addresses)
telephone and facsimile numbers
date of birth
occupation, gender, education
details about next of kin including spouse and children’s names
financial details
membership of professional associations
social interests

We will generally collect any personal information we need in order to conduct our business and/or provide you with our professional services, functions and activities, the administration of our business and our marketing activities.

The Privacy Act also protects your sensitive information (such as information about an individual’s race or ethnicity). If we need to obtain this type of information, we will ask for your consent, except where otherwise permitted by law.

It may not be practical for us to deal with you if you have not identified yourself or you are using a pseudonym. Clients, staff and other associated entities are required to provide personal information to Green & Sternfeld. We cannot provide services to or do business with such parties unless we are able to confirm their identity. However, where it is practical, such as to respond to some general queries about our firm, we will allow individuals to remain anonymous.

How Green & Sternfeld collect and hold personal information

Where it is reasonable and practical to do so, we will collect personal information directly from you. However, we may also need to collect personal information from other sources including:

related and unrelated third parties;
other advisors such as lawyers;
former employers;
employees;
government agencies;
independent contractors;
existing and new contacts and clients of the firm;
our website (our website may record information of those who visit it);
other sources.

We will only collect personal information from you by lawful and fair means. We may also collect your personal information in other ways where permitted by law.

Green & Sternfeld will take reasonable steps to protect the personal information it collects, in both paper and electronic form, from misuse and loss as well as from unauthorised access, modification and disclosure. Such reasonable steps include: confirming the identity of any individual wishing to access personal information, implementing computer system safeguards including password protection in line with appropriate industry standards, lockable physical security for paper records, archiving information in a secure and accessible manner, storing material for a legal period and then disposing of it securely.

The purposes for which Green & Sternfeld uses this information

The purposes for which Green & Sternfeld uses the information referred to above include the following:

to consider potential employee applications for employment by the firm
to open and administer client accounts
to provide financial services to clients, including billing and collection of debts
to administer independent contractors of the firm
for marketing and sales initiatives such as Green & Sternfeld publications, events and business programs

Use and disclosure

Green & Sternfeld will only disclose personal information to third parties if it is necessary for the primary purpose of collecting the information, or for a related secondary purpose, and if the disclosure could be reasonably expected. Where such a disclosure is necessary, Green & Sternfeld will require that the third party undertake to treat the personal information in accordance with the APPs.

Otherwise, Green & Sternfeld will only disclose your personal information to third parties without your consent if:

the individual has consented to the use or disclosure; or
Green & Sternfeld has reason to suspect that unlawful activity has been, or may be engaged in, and uses or discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities; or
the use or disclosure is required or authorised by or under law; or
Green & Sternfeld reasonably believes that the use or disclosure is reasonably necessary for a specified purpose by or on behalf of an enforcement body

Green & Sternfeld will use the information for our own direct marketing purposes relating specifically to our business only where:

Green & Sternfeld will not charge the individual for giving effect to a request not to receive direct marketing communications
the individual has not made a request not to receive direct marketing communications
in each direct marketing communication with the individual, Green & Sternfeld draws to the individual's attention, or prominently displays a notice, that he or she may express a wish not to receive any further direct marketing communications; and
each written direct marketing communication by Green & Sternfeld with the individual (up to and including the communication that involves the use) sets out Green & Sternfeld's business address and telephone number and, if the communication is made by fax or email or other electronic means, a number or address at which Green & Sternfeld can be directly contacted electronically.

Data quality and correction

Green & Sternfeld takes all reasonable precautions to ensure that the personal information collected, used, and disclosed is accurate, complete, and up-to-date. However, the accuracy of that information depends to a large extent on the information provided to us. Consequently, Green & Sternfeld recommends that an individual:

advises us of any errors in personal information, and
keeps us up-to-date with changes to personal information such as an individual’s name and address

If you would like to update or correct the personal information that we are holding, please contact us (our contact details are set out at the bottom of our privacy policy). A dated record will be kept of any corrections to personal information. We will not charge you for any request to correct your personal information.

Access

As a general rule, Green & Sternfeld will, on request by an individual, provide access to personal information, subject to some exceptions allowed by law. For security reasons, an individual may be required to put their request in writing.

Green & Sternfeld will endeavour to respond to a request for access as quickly as possible and will give access to the information in the manner requested unless it is unreasonable or impractical to do so. There are some circumstances in which the APPs provide that we can refuse your request for access to your personal information including if we believe the access would pose a serious threat to the life or health of any individual or if the access would have an unreasonable impact on the privacy of other individuals or if the information contains commercially sensitive information or if we can refuse the request by law. We shall inform you of our decision and reasons for any refusal of your request.

How to complain about a breach of the APPs and how we will deal with such a complaint

If you would like to make a complaint about our handling of your personal information or if you think we have breached the APPs or any other binding APP code that has been registered under the Privacy Act, please contact us with your complaint in writing. We will endeavour to deal with your complaint as quickly as possible. We may give a copy of your complaint to any affected party for their comment so we can properly investigate any issues. We will determine what (if any) action we should take to resolve the complaint and notify you of our decision and our reasons.

If you are not satisfied with the way we have dealt with your complaint you may file a complaint with the Office of the Australian Information Commissioner.

Overseas disclosure of personal information

It is not expected that, under normal circumstances, personal information will be released to any overseas recipients. If there is a request to release information to an overseas recipient then we will contact you and request your consent to release the information to the specific person or organisation. In addition, we will only release information overseas in accordance with the requirements of the APPs and all Australian data protection and privacy laws.

Where we send your information to overseas service providers, we will make sure that appropriate data handling and security arrangements are in place.

The Privacy Act and the Office of the Australian Information Commissioner

Our privacy policy is subject to the Privacy Act and the APPs. Where our privacy policy conflicts with the Privacy Act and the APPs, the Privacy Act and the APPs shall prevail to the extent of such inconsistency.

For more information in relation to Privacy you can contact the Office of the Australian Information Commissioner by visiting their website at http://www.oaic.gov.au.

How to contact us

Please contact us in relation to the matters set out above or in relation to privacy matters generally as follows:

Privacy Compliance Officer
Green & Sternfeld Pty Ltd
PO Box 7005
Glen Iris Victoria 3146

By Email: admin@gsca.com.au
By Phone: +61 3 9527-5041