Privacy policy
Why we have a privacy policy
At Pitcher Partners, we recognise the importance of protecting and maintaining your Personal Information. We appreciate that you may have concerns about your privacy and about the security, accuracy and confidentiality of Personal Information.
Pitcher Partners is committed to providing you with the highest quality professional service whilst also protecting your Personal Information in accordance with the Privacy Act, including the Australian Privacy Principles (APPs) established under that Act.
This Privacy Policy sets out how Pitcher Partners collects, holds, uses, discloses, processes and handles Personal Information in accordance with the Privacy Act and the APPs. It is not intended to cover categories of Personal Information that are not covered by the Privacy Act or the APPs.
This Policy may be modified from time to time to reflect our current privacy practices.
Pitcher Partners recognises that the EU General Data Protection Regulation (GDPR) may apply to residents of, citizens of, or individuals located within, the European Union. You should contact the Privacy Officer if you wish to exercise your rights under the GDPR.
Pitcher Partners is an association of independent firms located in Melbourne, Sydney, Perth, Adelaide, Brisbane and Newcastle.
All third parties (including clients, suppliers, sub-contractors, or agents) that have access to or use Personal Information collected and held by Pitcher Partners must abide by this Privacy Policy.
Definitions and interpretation
For the purpose of this Privacy Policy:
AML/CTF Act means the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), as amended from time to time.
AML/CTF Information means the Personal Information that we collect and hold as part of complying with our AML/CTF Obligations, including (but not limited to) customer due diligence (CDD) related information.
AML/CTF Obligations means our obligations as a reporting entity enrolled with the AUSTRAC and in providing Designated Services, as set out in the AML/CTF Legislation.
AML/CTF Legislation means the AML/CTF Act and the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Cth), as amended from time to time.
AUSTRAC means Australian Transaction Reports and Analysis Centre.
Australian Privacy Principles (APPs) means the principles set out in schedule 1 of the Privacy Act.
Cookies means small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type, or website visiting patterns.
Designated Services has the meaning given in section 5 of the AML/CTF Act.
GDPR means the EU General Data Protection Regulation.
Personal Information has the meaning given in the Privacy Act, and includes information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not, and includes AML/CTF Information.
Pitcher Partners means the national association of independent accounting Firms, located in Melbourne, Sydney, Perth, Adelaide, Newcastle and Brisbane.
Privacy Act means the Privacy Act 1988 (Cth), as amended from time to time.
Privacy Collection Notice means the written notice given by Pitcher Partners to you in accordance with the APPs, outlining why it is collecting Personal Information from you, what Personal Information it collects, how it collects it, and who it shares the Personal Information with.
Privacy Officer means the contact person within Pitcher Partners for questions or complaints regarding Pitcher Partners’ handling of Personal Information.
Privacy Policy means this privacy policy.
Sensitive Information has the meaning given in the Privacy Act, and includes Personal Information that includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information.
Spam Act means the Spam Act 2003 (Cth).
Suspicious Matter Report (SMR) means a report that we are required to submit to AUSTRAC if a suspicious matter reporting obligation arises as defined in section 41 of the AML/CTF Act.
Tipping Off means the criminal offence under section 123 of the AML/CTF Act, including a disclosure to a person that we have lodged, are required to lodge, or have prepared, an SMR to lodge with, AUSTRAC, where such disclosure would or could reasonably be expected to prejudice a criminal investigation and is not otherwise permitted under the AML/CTF Legislation.
Website means the website accessible via the internet or similar network that is owned, operated or made available by or on behalf of Pitcher Partners, including any associated domains, subdomains and content. The URL of the Pitcher Partners’ Website at the date of this Privacy Policy is www.pitcher.com.au/privacy-policy/
You means an individual in respect of whom we have collected and hold Personal Information, or intend to do so.
Who do we collect Personal Information about
The Personal Information we may collect and hold includes (but is not limited to) Personal Information about:
- clients, including potential clients and past clients
- service providers or suppliers
- prospective, current and past employees and contractors
- accountants, solicitors, barristers and other individuals who provide services to our clients
- beneficiaries of trusts and estates administered by our clients
- individuals with a connection to a client that uses our service (for example, an officeholder of a corporate client),
- investors within any fund to which we provide fund administration services, and
- other third parties with whom we come into contact.
What we are doing
Open and transparent management of Personal Information
Pitcher Partners manages Personal Information in an open and transparent way by complying with the APPs. We will remain open with you about what sort of Personal Information we hold, how we collect it, and for what purposes we use and disclose this information.
| The Pitcher Partners Privacy Policy may be obtained by contacting the Privacy Officer. If you have any queries or complaints about Pitcher Partners’ compliance with the APPs, please contact the Privacy Officer using the ‘How to contact us’ information shown below. |
If you believe that Pitcher Partners has breached the APPs, please contact the Privacy Officer in writing. We will respond to you within 30 days. If you are not satisfied with our response, you may take your complaint to the Office of the Australian Information Commissioner (OAIC).
If you believe that Pitcher Partners has breached the GDPR, please contact the Privacy Officer immediately.
Anonymity and pseudonymity
When engaging with Pitcher Partners, you have the option of not identifying yourself or you may use a fictitious name. At times this may not be practicable because we need Personal Information to provide services (including Designated Services) to you and if you do not provide the information requested, we may not be able to provide these services or be otherwise limited in our dealings with you. If it is important to you, and your Personal Information (including identification) is not required by us, you may request that we deal with you anonymously or by using a pseudonym.
What kind of Personal Information do we collect and hold
Our ability to provide you with a comprehensive service is dependent on us obtaining certain Personal Information. We may collect and hold Personal Information from you and other individuals that is reasonably necessary:
- to provide you with our services (which may include Designated Services)
- for us to carry out one or more of our functions or activities, or
- to enable us to comply with our legal obligations (which include our AML/CTF Obligations).
The Personal Information we may collect for these purposes might include:
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Some Personal Information is considered to be Sensitive Information. It may be necessary in some instances for Pitcher Partners to collect Sensitive Information about you, for example, your Tax File Number, professional memberships and health information.
Pitcher Partners will collect Personal Information that is reasonably necessary for the primary purpose of providing a professional service to you and also for complying with our legal obligations. If this Personal Information is considered sensitive, then unless the law provides otherwise, Pitcher Partners will also require your consent to the collection of this Sensitive Information. We will only collect Sensitive Information if it is necessary to provide our services to you.
Pitcher Partners will collect Personal Information in a fair and lawful manner. In most instances, we will collect Personal Information from you unless it is unreasonable and impracticable to do so.
Dealing with unsolicited Personal Information
If Pitcher Partners receives unsolicited Personal Information that we know could have been collected from you, we will afford it the same privacy protection as if we had solicited this Personal Information.
If the Personal Information is not reasonably necessary for one or more of Pitcher Partners’ functions or activities or we know that we could not normally have collected the Personal Information, we will destroy or de-identify the information as soon as practicable, unless it is unlawful or unreasonable to do so.
Notification of the collection of Personal Information
Pitcher Partners will, pursuant to its Privacy Collection Notice, endeavour to collect Personal Information directly from you. However, at times Pitcher Partners may need to collect Personal Information from a third party and when this occurs, we will inform you. In our Privacy Collection Notice, we will also be clear about the purpose of the collection, who we might disclose this information to, whether the Personal Information is required under an Australian law or a court/tribunal order and the main consequences of not collecting this information.
In some circumstances, Pitcher Partners uses third party service providers to carry out part of the services we provide to you. These service providers are typically located in India and the Philippines.
Use or disclosure of Personal Information
Pitcher Partners will not use or disclose Personal Information collected by us for any purpose other than the primary purpose for which it is collected, unless you would reasonably expect us to use or disclose the Personal Information for a secondary purpose or your consent has been obtained to use the Personal Information for additional purposes.
| Exceptions to this include where disclosure is: | |
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We may use and disclose your Personal Information for any of these purposes. We may also use and disclose your Personal Information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act.
Sensitive Information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise, or an exemption in the Privacy Act applies.
Where Pitcher Partners has collected the Personal Information from you, we may use this Personal Information for the purpose of direct marketing, to conduct surveys, to notify of seminars and other events, to seek your feedback and for any other business-related purposes.
Direct marketing
Pitcher Partners may use or disclose the Personal Information we hold about you for the purpose of direct marketing communications and information about our services, articles, opportunities, or events that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, and email, in accordance with applicable marketing laws, such as the Spam Act, if there is a reasonable expectation that your Personal Information will be used for this purpose and you have not opted out of receiving direct marketing communications from us, or where you have provided your consent.
Pitcher Partners will not directly market to you using Personal Information that is considered Sensitive Information unless you have provided consent.
Cross-border disclosure of Personal Information
Pitcher Partners may transfer or store your Personal Information outside Australia if we engage with, or are required to send Personal Information to, an overseas entity to fulfil the purpose for which the Personal Information was collected (or a related or ancillary purpose).
- We will not disclose Personal Information to an overseas recipient unless: we have taken reasonable steps to ensure that this recipient does not breach the Privacy Act or the APPs; or
- the recipient is subject to a similar applicable privacy law in relation to that information; or
- you have consented to the disclosure.
Adoption, use or disclosure of government related identifiers
Pitcher Partners will not adopt, use or disclose government agency identifiers, for example, tax file numbers, as our primary means of identifying you unless it is required or authorised by or under an Australian law (including the AML/CTF Legislation) or a court/tribunal order.
Quality of Personal Information
Our goal is to ensure, that at all times, the Personal Information we collect, hold, use or disclose is up to date, accurate and complete. We will take reasonable steps to correct Personal Information. If you become aware, or believe, that any Personal Information we hold is inaccurate, incomplete or out of date, please contact your relationship manager or the Privacy Officer at the details provided below.
Security of Personal Information
Pitcher Partners takes the security of your Personal Information very seriously. We will keep your Personal Information only for as long as required for our business purposes and as required by law, including as required to comply with our AML/CTF Obligations.
We have implemented significant measures and precautions to protect the Personal Information we hold (electronic and physical) from such risks as misuse, interference and loss, and from unauthorised access, modification or disclosure. We take reasonable steps to destroy or permanently de-identify any Personal Information no longer required.
Access to Personal Information
Individuals may at any time request access to Personal Information that Pitcher Partners holds about them. Where possible, we will provide you with access to that Personal Information either by providing you with copies of the Personal Information requested, allowing you to inspect the Personal Information requested or providing you with an accurate summary of the Personal Information held.
If Pitcher Partners were to refuse to give access to the Personal Information, or in the manner requested, we will provide written notice of the reasons (unless it is unreasonable or unlawful to do so – for example, so as not to engage in Tipping Off) and details should you wish to complain about the refusal. Generally, a refusal will only be in cases where denying such access is permitted or required (as the case may be) under the Privacy Act, Australian Privacy Principles, AML/CTF Legislation or is otherwise lawful.
| All requests for access to Personal Information should be in writing to the Privacy Officer.
We will respond to your request within a reasonable period (but not more than 30 days) after the request is made. Pitcher Partners may charge a fee for supplying Personal Information. |
Correction of Personal Information
If Pitcher Partners holds Personal Information about you for a purpose and knows that the Personal Information is inaccurate, out of date, incomplete, irrelevant or misleading we will take steps to correct the Personal Information. If you request us to correct the Personal Information, we will take reasonable steps to do so. If a third party is relying on this Personal Information, at your request we will also notify them, unless it is impracticable or unlawful to do so.
If we refuse to make a correction, we will let you know why and the complaint mechanisms that are available to you. If we continue to use this Personal Information, you may request us to associate a statement that the Personal Information is inaccurate, out-of-date, incomplete, irrelevant or misleading.
| All requests for correction to Personal Information should be in writing to the Privacy Officer.
We will respond to your request within a reasonable period after the request is made. We will not charge you for making the request for the correction of Personal Information. |
Updates to this Privacy Policy
This Privacy Policy is reviewed from time to time to take account of new laws, regulations and technology, and changes to our operations and the business environment.
We ensure that we stay informed of any issues or developments in relation to the application of the Privacy Act and any changing legal obligations by subscribing to the OAIC’s newsletter (https://www.oaic.gov.au/engage-with-us/networks/information-matters-newsletter).
We monitor for, and address any new security threats or risks, by signing up to alerts from the Australian Signals Directorate (https://www.cyber.gov.au/about-us/register).
Privacy on our Website
When you visit any part of our Website, we collect statistical data about that visit (e.g. what you looked at, the way in which you moved around the site, etc). We use this information to make our sites more useful and easily navigable.
Cookies
The Website uses Cookies to track how users navigate within the site and to recognise returning visitors. Cookies do not contain Personal Information in of themselves, but can be used to identify a person when combined with other information. The information is used to improve the site’s performance and provide users with more relevant content. Most websites you visit will use cookies.
You may withdraw or modify your consent to our use of Cookies at any time by disabling the use of Cookies on your web browser. Please note, that if you set your browser to refuse Cookies, this may impact your experience of our site and its functionality. See ‘Blocking cookies’ below for information on how you can manage your cookie preferences.
Types of Cookies we use
| Essential Cookies | These Cookies are strictly necessary to operate core functions and features on our Website. Without these Cookies our site may not work as you would expect and you may not be able to do such things as logging in or registering with us. |
| Personalisation / Functional Cookies | We use these Cookies to understand how you use our site and consume our information, so we can provide a more personalised experience. |
| Analytics Cookies | We use Google and other Analytics Cookies and tools to analyse how our websites are being used in aggregate, so that we can assess and improve the quality of experience we provide to our site users generally. |
External Web Services
We sometimes use external web services to display embedded content on our Website, for example to display images, videos or feedback surveys. We cannot stop these services collecting information on your use of this embedded content. See ‘Blocking cookies’ below for information on how you can manage your Cookie preferences on your device.
Email Communications
On certain email communications, Pitcher Partners may use technology to determine whether the recipient has read, clicked on, or forwarded the email. This information is used to assess whether the content was relevant to the recipient. Where this technology is used, you will have the option to unsubscribe from the distribution list if you do not wish for Pitcher Partners to receive this information.
Blocking Cookies
Most web browsers give you the option to either allow or block Cookies for selected sites or to delete the Cookies that have already been recorded. Refer to the ‘Help’ section of your browser for instructions on how to do this. Please note, however, some site functionality may be affected if certain Cookies are disabled.
How to contact us
All requests for access or correction to Personal Information, privacy complaints, requests for access to Personal Information, queries in relation to this Privacy Policy, or any other privacy related matter, should be directed to the Privacy Officer at Pitcher Partners.
The Privacy Officer
Pitcher Partners
GPO Box 5193
Melbourne VIC 3001
Phone: (03) 8610 5363
Fax: (03) 8610 5000
Email: [email protected]
Your enquiry may be directed to the Privacy Officer of the firm within the Pitcher Partners association that services your needs.
We will respond to your request within a reasonable time and in accordance with the requirements of the Privacy Act.
| If you have made a privacy complaint and believe that Pitcher Partners has not adequately handled your complaint, you may complain to the Office of the Australian Information Commissioner
Office of the Australian Information Commissioner GPO Box 5218 Phone: 1300 363 992 |