IMP Privacy Policy
1. About this policy
IMP Partners (we, us, our) is a registered tax agent practice in Queensland led by Ivy Sujin Ma FCPA CTA (Registered Tax Agent 27883007). We provide tax agent services, BAS services, accounting and tax advisory services to individuals, families and businesses.
This policy explains how we collect, hold, use and disclose personal information, and how you can access or correct it or make a complaint. We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), the Privacy (Tax File Number) Rule 2015 (TFN Rule), the Tax Agent Services Act 2009 (Cth) and the Code of Professional Conduct, and the confidentiality requirements of APES 110 Code of Ethics for Professional Accountants.
By engaging us or giving us your information, you consent to us handling it as described in this policy. A Chinese summary is available on request. If there is any difference, the English version applies.
2. What personal information we collect
We only collect information that is reasonably necessary to provide our services and meet our legal obligations. Depending on the services, this may include:
- Identity and contact details: name, date of birth, address, phone, email, WeChat or other messaging ID, and identity documents such as a driver licence or passport.
- Tax and government identifiers: tax file number (TFN), ABN, ACN, Medicare and Centrelink details, ATO and ASIC records, and myGov-linked information we access with your authority.
- Financial information: income, bank statements, investment, property, superannuation and loan records, business accounts, payroll and employee records, and details of assets and liabilities.
- Family and relationship information: details of spouses, children, beneficiaries, directors, shareholders and other related parties, where relevant to the tax affairs of you or your family group.
- Sensitive information: only where needed for a tax purpose and with your consent, for example health information relevant to a medical expense, or a disability or carer status relevant to an offset or exemption.
- Website and communication data: information you enter in enquiry, booking and quote forms, and basic technical data such as browser type and pages visited.
If you give us information about another person, such as a spouse, employee or beneficiary, please make sure they know you are doing so and that they can read this policy.
3. How we collect it
We collect information directly from you wherever we can: in meetings, by phone or video, through our secure client portal, by email, and through forms on our website. With your authority, we also collect information from the Australian Taxation Office, ASIC, the Australian Business Register, your bank or financial institutions, your bookkeeper, previous accountant or tax agent, lawyers, financial advisers and other parties acting for you.
You can choose not to give us certain information or to deal with us using a pseudonym for general enquiries. If you do not give us the information we need for an engagement, we may not be able to provide the service or meet our obligations to the ATO.
4. Why we collect, use and disclose it
- to prepare and lodge tax returns, BAS, activity statements and other documents with the ATO, ASIC and other regulators;
- to give tax advice, plan business and family structures, and represent you in ATO reviews, audits, objections and payment arrangements;
- to verify your identity and meet our obligations under the Tax Agent Services Act 2009, the TPB Code of Professional Conduct and, where applicable, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
- to manage our engagement with you, including quotes, invoicing, payment and record keeping;
- to send you reminders about deadlines and relevant tax changes, which you can opt out of at any time; and
- to meet our professional obligations, including quality reviews by CPA Australia and requirements of our professional indemnity insurer.
We do not sell personal information, and we do not use it for direct marketing by third parties.
5. Tax file numbers
We collect, use and disclose TFNs only for purposes permitted by taxation, personal assistance or superannuation law, as required by the TFN Rule. We ask you not to send your TFN by unencrypted email or messaging apps. Please give it to us in person, by phone or through our secure client portal. We store TFNs securely, restrict access to them, and securely destroy or de-identify them when they are no longer required by law.
6. Who we disclose it to
We disclose personal information only for the purposes in section 4, to:
- the ATO, ASIC, the Tax Practitioners Board, the Australian Business Register, State revenue offices and other government agencies;
- service providers who help us run the practice, such as practice management, accounting, document storage, e-signature, client portal and IT support providers, under confidentiality obligations;
- other professionals acting for you, such as your lawyer, financial adviser, mortgage broker or bookkeeper, with your consent;
- a colleague practitioner who provides cover during leave or illness, under a written confidentiality agreement;
- CPA Australia, our professional indemnity insurer and our legal advisers, where needed for quality review, insurance or a claim; and
- anyone else where you consent or where the law requires or authorises it.
7. Overseas disclosure and cloud services
Some of our software providers store or process data outside Australia, including in the United States. Where this happens we take reasonable steps to make sure the provider handles your information consistently with the APPs. We do not otherwise disclose your personal information overseas unless you ask us to, for example to send documents to an adviser in another country.
8. Security and retention
We keep personal information in secure cloud systems with multi-factor authentication, encryption and access limited to people who need it, and in locked storage for any paper records. We train anyone with access to keep client information confidential.
We keep records for as long as needed to provide our services and meet legal and professional requirements, generally at least five years after the relevant lodgement or the end of the engagement, and longer where an ATO review, dispute or law requires it. After that we securely destroy or de-identify them.
9. Data breaches
If a data breach is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner (OAIC) under the Notifiable Data Breaches scheme, and tell you what steps you can take to protect yourself. Where a breach affects your ATO records, we will also notify the ATO so it can protect your tax account.
10. Our website
Our website may use cookies and analytics tools to understand how it is used. These tools collect technical information that does not identify you by name. You can disable cookies in your browser. The calculators and tools on our website run in your browser. Information you type into them is not sent to us unless you submit a form.
11. Access and correction
You can ask for access to the personal information we hold about you, or ask us to correct it, by contacting us using the details below. We will respond within 30 days. We may need to verify your identity first. If we refuse access or correction, we will tell you why in writing and how to complain. We do not charge for making a request, but may charge a reasonable fee for providing a large volume of records.
12. Complaints
If you are concerned about how we have handled your personal information, please contact our Privacy Officer in writing. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days.
If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner at www.oaic.gov.au or 1300 363 992. You may also raise concerns about our professional conduct with CPA Australia (www.cpaaustralia.com.au) or the Tax Practitioners Board (www.tpb.gov.au).
13. Contact us
- Privacy Officer
- Ivy Sujin Ma FCPA CTA
- hello@imppartners.com.au
- Phone
- 07 3186 9186
- Post
- IMP Partners, Building 6, 2404 Logan Road, Eight Mile Plains QLD 4113
14. Changes to this policy
We review this policy at least once a year and when the law changes. The current version is always available at imppartners.com.au/privacy or on request.