NCS-Nicholls Chartered Accountants

Your privacy is important to us.

Nicholls Corporate Services Pty Ltd (ABN 99 101 082 928) trading as NCS-Nicholls Chartered Accountants and its associated entities (hereinafter collectively known as "NCS Group") understands that you value your privacy and wish to have your personal information kept secure. For these reasons, NCS Group places a high priority on the security of information we hold and we are committed to providing you with the highest quality professional service whilst also protecting your privacy.

We have developed this policy to inform you of how we manage your personal information to maintain its integrity and security.

We are bound by the National Privacy Principles established under the Privacy Act 1988 (Cth) (as amended by the Privacy Amendment (Private Sector) Act,

2001). You can find more information about the Privacy Act and the National Privacy Principles on the Federal Privacy Commissioner ' s website at www.privacy.gov.au .

We believe in keeping your personal information highly secure, we also believe that you have the right to be informed about how we deal with that information so if on reading this policy you are unclear on any of the matters or simply want more information, please don ' t hesitate to contact us on the telephone number or addresses provided below.

How does NCS Group collect personal information about me?

Most of the personal information about you is collected by NCS Group either directly from you or indirectly from your employer or professional advisers.

The personal information that is collected is considered necessary for the primary purpose of providing a professional service to you.

We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us.

What personal information does NCS Group collect about me?

We aim to collect personal information only if it is relevant and necessary to providing our services. NCS Group may collect any of (but not necessarily all of) the following information about you:

gender, date of birth and next of kin and family details;
contact details;
employment details such as your salary, superannuation contributions and employment status;
business name and address;
account and business records;
Tax File Number and taxation records;
Statements of financial position regarding assets and liabilities; and
any other information that is necessarily incidental to the services provided by NCS Group.

We may also need to ask you for other specific personal information to enable NCS Group to provide its services to you.

We aim to ensure that your personal information is accurate, complete and up to date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested and properly update the information given to us to keep it true, accurate, current and complete. If you believe that the information we hold is inaccurate or incomplete, please contact us and we will use all reasonable efforts to correct the information. In the event that we do not believe the information to be incorrect, we may take reasonable steps to add a statement to the information claiming that we believe the information is not accurate, complete or up-to-date.

Why does NCS Group collect this information?

We collect this information to provide accounting, taxation, banking and finance advisory, strategic business advisory and other related services from time to time supplied by NCS Group.

How does NCS Group use the personal information held about me?

Any personal information about you that we collect and record will
only be used or disclosed by NCS Group lawfully and by fair means for the
purpose of:

helping NCS Group efficiently and effectively deliver and improve on
NCS Group - products and services or any other purpose specified to you at the time of collection; or
any other purpose that you would reasonably expect NCS Group to use or disclose that personal information for that other purpose and that other purpose is related to the above purpose; or
sending you news and other information about NCS Group activities and general promotional material which NCS Group believes may be of interest to you, however, when NCS Group does this, NCS Group will provide you with an express opportunity to decline receiving any further communication from NCS Group of this type via an opt-out mechanism.

If NCS Group wishes to use or disclose any of your personal information other than as set out above, NCS Group will not do so unless:

NCS Group has your express consent to do so;
NCS Group has reasonable grounds to believe that the use or disclosure is necessary to prevent a threat to life or health; or
NCS Group has reasonable grounds to believe that the use or disclosure is required by law or to enforce the law.

What happens if I want to access or correct the personal information held
about me?

You may access your personal information held by NCS Group, subject to
some exceptions by making a request in writing to the NCS Group Privacy
Officer. We will respond to your request for access as soon as practicable and
endeavour to provide the required information within 30 days.

We may charge you a reasonable fee to recover our costs for providing access
based on the quantity of material and time involved in providing access.

We may not be able to provide access to information in some situations
including:

where providing you access will pose a serious threat to the life or health of any individual or will pose an unreasonable impact on the privacy of any individual;
where your request for access is frivolous or vexatious; or
where providing access would be unlawful, may prejudice an investigation of possible unlawful activity, may prejudice enforcement of law, or denying access is specifically authorised by law.

If NCS Group does not allow you to access your personal information, NCS Group will provide you with written reasons for its decision.

Does NCS Group provide my personal information to third parties?

There are some instances when we need to provide your personal information
to third parties. Sometimes we need to outsource some of our administrative
operations to external organisations such as Insurers, Underwriters, IT professionals, banks and other financial institutions, lawyers, auditors and other advisors. We may also provide your information to government authorities such as the Australian Taxation Office. Most of the above organizations are bound by confidentiality obligations to NCS Group.

NCS Group does not sell your personal details to other organisations. We may however use the information about your to assist us with internal marketing and research.

How does NCS Group keep my personal information secure?

We will take reasonable steps to ensure that all information NCS Group collects uses or discloses is stored in a secure environment that is accessed only by persons authorised by NCS Group so as to prevent misuses, loss or unauthorised access, modification or disclosure.

If the personal information is no longer needed for any purpose, NCS Group
will take reasonable steps to destroy or permanently de-identify the personal
information.

In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained for a period of 7 years in order to comply with legislative and professional requirements, following which time the information will be destroyed.

NCS Group endeavours to provide a secure environment and a reliable system but you should be aware that there are inherent risks associated with the electronic storage and transmission of information (particularly via the internet) which cannot be guaranteed to be 100% secure.

Is my personal information transferred outside Australia ?

NCS Group will not transfer your personal information outside Australia . If we are required to transact with, or send information on your behalf to, an overseas organisation, we will seek your consent with regard to the transfer.

Is sensitive information collected about me?

Generally NCS Group does not collect sensitive information about you. If we do need to collect sensitive information (eg. Medical reports) we will only do so with your consent.

What communication occurs as a result of changes to this Privacy Policy?

NCS Group reserves the right to review and amend this Privacy Policy from time to time and to notify you by posting an updated version on our Web site at www.ncsnicholls.com.au

What if I have a complaint or concern?

If you have a complaint or concern you can contact the NCS Group Privacy Officer on:

Telephone: 03 9880 7744

Facsimile: 03 9880 7226

Email: privacy@ncsnicholls.com.au

Postal: PO Box 564 CAMBERWELL VIC 3124

We will do our best to try and resolve your complaint within 90 days.

If we are unable to resolve your complaint within this time, or you are unhappy with the outcome, you may refer your complaint to the Privacy Commissioner in your State capital.