At Flagstaff Partners 100% of our staff have received at least two doses of COVID-19 vaccine. This is a decision that we have each taken for the benefit of our own and each other’s health and safety, and that of our clients, communities and families.
In order to ensure the continued safety of our staff and visitors to our office, we request that you do not attend any meetings or events in-person at Flagstaff until you have been able to receive at least two doses of COVID-19 vaccine (subject to medical exemptions). In the meantime, we can make alternate arrangements for meeting with you. You may be asked to show proof of your vaccination status on arrival.
We also ask that you continue to excuse yourself from attending any meetings or events at Flagstaff if you feel unwell. We will understand if you are only able to give us short notice and in these circumstances will make alternate arrangements for meeting.
In this Policy, “Flagstaff”, “we”, “us” and “our” refer to Flagstaff Partners Pty Ltd (ABN 52 132 820 985 and AFSL No. 348370) and its related bodies corporate.
Flagstaff is committed to protecting the privacy of our clients, personnel and all other parties that interact with us.
The purpose of this Policy is to explain:
This Policy applies to all personal information collected by us, including via our website or under any agreement or arrangement you have with us.
We are subject to the Australian Privacy Principles in the Privacy Act 1988 (Cth).
We will collect and hold personal information:
The types of personal information we will collect about you commonly include your name, address, telephone numbers and email addresses. We may also collect details about your employment, such as which organisation you work for and your title.
If you work with us or apply to do so, we may collect certain sensitive information about you, such as memberships of professional or trade associations and police records. We may also collect your tax file number, bank account and superannuation fund details and details of past employment.
We will generally collect personal information directly from you, but we may sometimes need to source personal information about you from another person or organisation. For example, if you apply to work with us, we may collect personal information from a past employer, recruitment agency or other service provider.
We will take steps that are reasonable in the circumstances to ensure that the personal information about you that we collect is accurate, up-to-date and complete.
You may choose to remain anonymous or to use a pseudonym when dealing with us, except if we are required by law to ascertain your identity or where it is not practical for us to deal with you unless you have identified yourself.
We do not use cookies on our website for tracking or analytical purposes or to remember user preferences or enhance user experience. The only cookie used on our website is a legacy feature which has no current active purpose and may be disabled without impacting user experience. We do use standard web server log files on our website, which log user activity (including users’ IP addresses, browser types and dates and times of access). This information may be used for website security purposes (for example, security audits or to block malicious users).
We will use and disclose your personal information:
We do not disclose your personal information to entities located outside Australia, unless specifically arranged with you.
We will take reasonable steps to ensure that personal information about you that we use or disclose is accurate, up-to-date, complete and relevant.
Your personal information is generally held in our physical files or on our electronic systems and databases. Personal information may also be stored in back‑up systems, disaster recovery environments and archives, including systems operated or hosted by third‑party service providers (for example, cloud‑based storage and hosted IT platforms) located in Australia, which may change from time to time.
We take reasonable steps to protect the confidentiality and security of personal information that we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. Access to personal information is restricted on a need‑to‑know basis and we maintain appropriate physical, technical and organisational safeguards. These include confidentiality obligations for personnel, secure premises and document storage, access controls and password protection, and restrictions on access to electronic folders and systems.
We retain personal information only for as long as is reasonably necessary for the purposes for which it was collected, or for any related purposes, unless a longer period is required or authorised by law. This may include retention for regulatory, legal, accounting, audit, risk management, dispute resolution or record‑keeping purposes, including to comply with our obligations as an Australian financial services licensee.
Where personal information is no longer actively required for operational purposes but may be relevant to future legal, regulatory, compliance or risk management matters (including where a transaction or engagement may resume, or questions or disputes may arise after completion), we may move that information to restricted archive. Archived information is subject to appropriate access controls and is not used for day‑to‑day operational purposes.
When personal information is no longer required for any permitted purpose, and there is no legal or regulatory requirement to retain it, we take reasonable steps to destroy or de‑identify that information. This may include the destruction or de‑identification of information relating to unsuccessful candidates, prospective clients where no engagement proceeds, and other information where the purpose of collection has clearly ended. Residual copies of information may continue to exist for a period in routine back‑ups or disaster recovery systems, but are not actively accessed except for restoration, legal hold or compliance purposes.
In the event of an eligible data breach (as defined in the Privacy Act 1988 (Cth)), we will comply with our obligations under the Notifiable Data Breaches scheme, including any required notifications to affected individuals and the Office of the Australian Information Commissioner (OAIC).
If you ask us to, we will:
Your request will be addressed within a reasonable time after it is received.
If we deny your request for access or correction, we will provide you with our written reasons and explain how you can complain if you are not satisfied with our decision.
If you have questions about our handling of your personal information, wish to gain access or request correction, or if you believe we may have breached the Australian Privacy Principles, you can contact us on the details provided in section 8 of this Policy.
We will consider the matter and respond to you as soon as we reasonably can. Where you have made a complaint, this may include investigating the matter before responding to you with a suggested resolution.
If we do not respond to your complaint within 30 days or if you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC). Further information on how to do this can be found by visiting the OAIC’s website at https://www.oaic.gov.au/ or by calling the OAIC on 1300 363 992.
The Compliance Officer is responsible for overseeing the implementation, monitoring, annual review and update of this Policy (including with the assistance of relevant personnel) and reporting to the Board as appropriate.
We must monitor compliance with this Policy and keep appropriate records of any monitoring and reviews.
We may review and update this Policy from time to time to ensure it meets our legal obligations and accurately reflects our personal information handling practices. This Policy will be reviewed annually (and sooner if there are any material changes to our business, systems, services or legal obligations that may affect our handling of personal information).
An up-to-date copy of this Policy will be posted on our website at http://www.flagstaffpartners.com/ and is also available free of charge on request.
The Compliance Officer
Phone: +61 3 9664 4555
Fax: +61 3 9664 4599
Email: info@flagstaffpartners.com
