This Privacy Policy applies to Ryan Carlisle Thomas (which includes Stringer Clark) ABN 42 645 656 527 and our related entity RCNT Administrative Services Pty Ltd as trustee for Ryan Carlisle Thomas Service Trust ABN 12 072 858 013 (“we”, “our” and “us”).
Not applicable to Institutional Abuse
Please note that this Privacy Policy does not apply to any personal information (including sensitive or health information) we collect, hold, use or disclose in respect of or related to institutional abuse. All such personal information is subject to our Institutional Abuse Privacy Policy which can be found here.
The importance of your privacy
The privacy of your personal information is important to us and we know that how we collect, hold, use, disclose and protect your personal information is important to you.
Please read this Privacy Policy carefully as it sets out important information regarding how we collect, hold, use, disclose and protect your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”).
You do not have to provide any of your personal information to us. However, if you do not provide us with your personal information that we request we may not be able to provide our services or assistance to you.
Application of this Privacy Policy & revisions to this Privacy Policy
By engaging our services, seeking our assistance, providing your personal information to us or authorising another person to provide us with your personal information you consent to your personal information (including any sensitive information) being collected, held, used and disclosed by us in accordance with this Privacy Policy.
We may update this Privacy Policy from time to time so please review it periodically for changes. If the changes are significant or substantive we will notify you of them and/or post them on our website here.
Your continued use of our website or services, requesting our assistance or your provision of further personal information to us (directly or via an authorised person) after this Privacy Policy has been revised constitutes your acceptance of and consent to the revised Privacy Policy.
What personal information do we collect?
We generally collect the following personal information about you:
- your name;
- your gender or gender-neutral description;
- your date of birth;
- your contact details (e.g. mailing address, email address, phone number and fax number);
- details about your occupation;
- your tax file number;
- information about your dealings with us or with our clients; and/or
- other information relevant to the performance of our services for you or our clients, including health information and/or financial information where such is required.
Other than as specifically noted in this Privacy Policy, we will not collect any sensitive or health information about you unless you have consented to such collection or if we are required or permitted to do so by law.
Cookies and web beacons
We may use cookies or web beacons to collect data for aggregation in order to analyse the use of our website. These may collect personal information. You can disable cookies or web beacons on your internet browser.
How do we collect your personal information?
We endeavour to collect your personal information directly from you. However, when necessary and appropriate, we may also collect your personal information from third parties including:
- your insurer;
- a company in which you are a shareholder or officeholder;
- your employer or past employer;
- Government agencies;
- your family members, legal guardian and/or anyone you have authorised to deal with us on your behalf;
- search agents and/or private investigators we engage and police;
- anyone seeking our services in relation to their dealings or interaction with you; and/or
- from publically available sources.
If you provide to us the personal information of another person you warrant that the person or persons to which the personal information relates have consented to such disclosure and to our collection, holding, use and disclosure of their personal information in accordance with this Privacy Policy.
What do we use your personal information for?
We collect, hold, use and disclose your personal information for the purposes for which it was provided to us or as permitted or required by law (“Purposes”). These Purposes may include to:
- provide you and/or our clients with the services requested (generally legal services) and communicate about the same, including in relation to billing;
- improve and market our services including developing our knowledge management resources, maintaining a database of clients and key contacts and supporting internal management reporting requirements;
- respond to your and/or our clients’ enquiries or provide you and/or our clients with assistance as requested;
- process application forms you have completed either in hardcopy or in electronic form or on our website;
- provide you with journals, newsletters, publications and event invitations which we believe will be of interest to you (we note you may unsubscribe from receiving such information at any time);
- perform quality assurance, IT security and training;
- manage our relationships with vendors and contractors;
- manage personnel (including the recruitment of personnel); and/or
- comply with our legal and professional obligations (including checking for conflicts of interest, undertaking anti-money laundering checks and other client take-on procedures).
In certain circumstances we may also collect, hold, use and disclose your personal information as permitted or required by law or a Court or Tribunal order. For example, to take you on as a client we need to collect your name, residential address, date of birth, business name (if any) and directorship appointments (if any) in order to comply with Australian anti-money laundering, counter terrorism, anti-bribery and corruption legislation and relevant professional conduct and practice rules and legislation.
Who do we disclose your personal information to?
We may disclose your personal information to third parties. Where appropriate and reasonably possible we will only disclose your personal information to third parties bound by the APPs or on a confidential basis. Such third parties to which we may disclose your personal information include:
- our third party service providers (including our United States based website hosting provider) for the purpose of enabling them to provide, manage or administer a service offered through or for us or to assist us to otherwise provide our services to you or our clients (such as our IT service providers, costs consultants, mailing houses, organisations providing secure storage and archiving services, search agents, private investigators and our insurers);
- your representatives (including any financial advisors) but only if you have provided consent for such disclosure;
- Government bodies, regulators, law enforcement agencies and any other parties where permitted or required by law;
- any other third parties identified at the time of collecting your personal information; and/or
- third parties we are legally permitted or required to disclose your personal information to.
Our publications, journals and newsletters
In no circumstances will we share your personal information with any person for the purposes of direct marketing. We may send you journals, newsletters, publications and event invitations which we believe will be of interest to you. However, you may unsubscribe from receiving these from us at any time.
How do we protect your personal information?
We take reasonable steps to protect your personal information that we hold from misuse, interference and loss and from unauthorised access, alteration and disclosure. For example, we implement the following security measures:
- physical security procedures for access to our business premises;
- physical security procedures within our offices;
- IT security procedures including password protection, firewalls, intrusion detection and site monitoring;
- mandatory confidentiality guidelines and privacy training for all staff within the business; and
- ensuring all completed files are maintained in a secure facility which can only be accessed by our authorised personnel.
Data protection measures are never completely secure and despite the measures we put in place we cannot guarantee the security of your personal information. You must take care to protect your personal information (e.g. by protecting usernames and passwords). You should notify us as soon as possible if you become aware of any security breaches.
How can you access your personal information?
You may access your personal information that we hold subject to a small number of legal restrictions or exemptions. Where such restrictions or exemptions exist we will advise you of those reasons if we deny your request for access.
If you wish to access your personal information that we hold you should contact us at the details below (see the “Our contact information” section below) and provide us with proof (satisfactory to us) of your identity.
While we do not charge you for a request for accessing your personal information, please be aware that we may charge a reasonable fee (which will be notified to you once you make a request) for our time and costs in complying with your request in the following circumstances:
- if an extended amount of time is required to collate and prepare the material for you; and/or
- if you wish to have your personal information photocopied by us.
How can you correct your personal information?
We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date. However, we rely on you to advise us of any changes to your personal information.
Please contact us at the details below (see the “Our contact information” section below) as soon as possible if there are any changes to your personal information or if you believe the personal information we hold about you is not accurate, complete or up-to-date so that we can update our records accordingly.
How can you make a complaint?
If you wish to make a complaint about our handling of your personal information or if you believe we have breached the APPs please contact us at the details below (see the “Our contact information” section below). You will need to provide us with sufficient details regarding your complaint together with any supporting evidence.
We will investigate your complaint and determine the steps (if any) that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the outcome of our investigation.
If you are not satisfied with our determination, at any time you can complain to the Australian Privacy Commissioner (see www.oaic.gov.au for contact details).
Our contact information
The Privacy Officer
Ryan Carlisle Thomas
41 Robinson Street
Dandenong Vic 3175
Phone: 03 9238 7878
Email: privacyofficer@rctlaw.com.au
Last updated: May 2019