Last Updated: 5 June 2023
a. applies to all instances where personal information is collected from you or from third parties; and
b. must be adhered to by all Cathro & Partners employees, contractors, board members, volunteers, agents and representatives that have access to Personal Information.
a. "personal information" has the definition given to it under the Privacy Act.
b. "sensitive information" has the definition given to it under the Privacy Act.
c. "stakeholders", "you", "your" and "yourself" refers to the individual about whom we collect personal information.
d. "we", "our" and "us" refers to Cathro & Partners.
e. "website" means https://www.cathropartners.com.au/.
Acceptance and amendment of policy
What personal information do we collect?
Where possible, Cathro & Partners will obtain your personal information directly from you. The information may be collected through various means such as use of our website, attendance at one of our events or sites, filling out paper-based or electronic forms (online), over the phone, applying for employment, interacting, contracting and/or engaging with the Cathro & Partners.
We will only collect personal information from you that is necessary and relevant to our relationship with you, including to enable us to provide to you the best possible service and customer experience. While the precise nature of the personal information we may require will depend on the specific service(s) that we are providing to you and the exact nature of our engagement and relationship with you, we may request that you provide some or all of the following information:
• Information that we may require to initially identify you, including your name, date of birth, business or company names and numbers, home address and or business address;
• Information that we can use to contact you, including your telephone number, mobile number, email address, work address, mailing address;
• Information that we need to employ or otherwise make payments to you or your business/company, such as your name, title, date of birth, citizenship, residency status, qualifications, work history, education history, bank account details, superannuation details, details of any relevant licences, uniform size, basic medical information (such as injuries or allergies) and contact details; and
• Information that may assist us to confirm your financial position or credit history, including your credit card details, bank details, purchase history, transaction details, loan and credit information.
We kindly note that the above is not an exhaustive list of the information that we may request.
The Privacy Act places restrictions on us collecting sensitive information about you (which includes information about your religion, political views, ethnicity, criminal records and sexual preferences). Generally, we will not collect sensitive information about you. However, should we need to, for instance if you are applying for a job with us, we would not do so without first obtaining your consent.
We may also collect sensitive personal information where we are provided with such information directly by our clients to provide professional services. This may include:
• Government identifiers such as drivers’ licence, passport and Medicare numbers and visa/work permit status;
• Tax file numbers;
• Health records;
• Information about racial or ethnic origins;
• Information about criminal convictions;
• Membership of a political association or membership of a trade union.
Anonymity and Pseudonymity
Cathro & Partners understands that when dealing with Cathro & Partners some members of the public may wish to remain anonymous or use a pseudonym. Although anonymity is an important element of privacy, there are limited circumstances where Cathro & Partners allows this, such as when you submit a general enquiry with Cathro & Partners or browse our website. Cathro & Partners is not required to allow such anonymity or pseudonymity if it is impracticable to do so, or it is otherwise required by law.
In general, you can browse our website without telling us who you are or revealing any personal information about yourself. We are however able to determine your IP address.
How we collect Personal Information
Cathro & Partners will collect Personal Information in several ways, including but are not limited to:
• directly from you or when relevant another party, for example when you complete forms provided to you by Cathro & Partners including, Cathro & Partners credit applications, site attendance forms or when you provide us with information by phone, email or in agreements;
• at our office or site hosted meetings/events/engagements, we may gather basic contact details from you. This data is utilised for identification purposes for building security and safety measures and extending future invitations to meetings and events.
• from our own records of how you use our services;
• your use of our website and cookies. A 'cookie' is a small file stored on your computer's browser, which assists in managing customised settings of the website and delivering content. Cookies can facilitate a user’s ongoing access to and use of a site. They allow us to track usage patterns and to compile data that can help us improve our content and target advertising. You can change the settings in your browser to control how your browser deals with cookies; and/or
• from a third party or stakeholder as authorised by you.
• if you engage or contract with us
• if you make an inquiry regarding our services
• if you make an inquiry or expression of interest regarding the assets for sale in a liquidation or insolvency
• if you make an inquiry through our website
• if you interact with us via social media platforms
• if you subscribe to any of our mailing lists or use any of our online applications
• if you are a creditor and contact us
• if you login through our creditors portal
We may also collect personal information about you from:
• publicly available sources, including from Australian Government agencies (such as the Australian Securities and Investments Commission), New Zealand Government agencies (such as New Zealand Companies Office), internet search platforms and social media platforms, such as Facebook;
• any person or third party authorised to act on your behalf or authorised to provide your personal information to us;
• any third party authorised and permitted to provide your personal information to us;
• credit reporting bodies and other credit providers;
• anyone sharing information with us for loss prevention and/or law enforcement purposes;
• any persons you nominate, if you submit an employment application to us; and
• our related companies including information about your transactions or other interactions with them, including browsing on their websites and apps
• our clients to enable us to deliver professional services or to perform due diligence checks before we agree to provide services. This information may relate to clients' employees, members or customers or it may relate to third parties.
• other sources or from individuals themselves to enable us to deliver professional services. The types of personal information we may collect or be provided with include, but are not limited to:
• Contact details;
• Dates of birth;
• Bank account details
• Employment records;
• Financial records;
• Creditor records
• Complaint details.
• Claim details
Confidentiality of Personal Information
Except as otherwise described in this notice, all personal information that is not public information will be treated as confidential at all times. We restrict access to personal information about you to employees of Cathro & Partners, who must use that information to provide services to you.
How we store personal information
We want you to have continuing trust in Cathro & Partners and its services, so, we have put in place reasonable physical, electronic, and managerial procedures to safeguard and secure your personal information.
These procedures and safeguards include but are not limited to include implementing strict confidentiality practices for employees, contractors and service providers, and investing in security software to protect against the possibility of cyber-attack or other external threats.
Third party storage providers
We may store electronic records of your personal information with other third parties, including but not limited to:
a. third party database storage providers, which may be based in Australia and/or overseas; and/or
b. third party financial and insolvency software which may be stored on a secured electronic cloud server.
In some cases, the organisations that we may share your information with may be based outside the location where the information is collected. For example, we may share your information with other parties in the United Kingdom.
Cathro & Partners takes all reasonable measures to ensure that third party providers or organisations store any personal information in a safe and secure place and restrict their use of the personal information.
How long do we retain your Personal Information?
• legal and regulatory requirements and guidance;
• limitation periods that apply in respect of taking legal action;
• our ability to defend ourselves against legal claims and complaints;
• good practice; and
• the operational requirements of Cathro & Partners business.
Personal information obtained by mistake or indirect collection
Personal information that is collected by mistake or indirectly and is not required for the purpose of carrying on Cathro & Partners business will be handle such personal data in accordance with applicable data protection laws.
Why we need to collect Personal Information
Cathro & Partners collects Personal Information for a range of purposes relating to our functions and activities, including to:
• provide and improve optimal services and information;
• deliver a more personalised experience and service offering;
• employ you;
• conduct a range of internal administration activities relating to you, including investigating and handling complaints, processing applications, administering billing services and complying with regulatory and legal requirements.
• enter into an agreement or contractual relationship with you.
• to comply to the applicable regulations and laws.
What happens if you don't provide the Personal Information we have requested?
It is entirely your choice as to whether you provide us with your Personal Information. However, if you do not provide the Personal Information we have requested, we might not be able to:
• enter into any agreements or contract with you;
• provide some of the services which you require;
• provide you with specific website features and online browsing features;
• properly investigate or resolve any complaints made by you;
• processes applications for employment or other assistance;
• provide you with tailored made services;
• create a Cathro & Partners account for you; or
• process credit applications.
• process payments
How we use and disclose personal information
We may use or disclose your personal information for the primary purpose for which it was collected ("primary purpose") i.e. providing financial, strategic, commercial, and operational solutions and strategies. In addition, we may use your information to provide you with our latest service offering and promotional information and other information that might be useful to you. We only use personal information for the primary purpose unless you have provided us with your consent.
Any disclosure of your personal information (excluding sensitive information) for a purpose other than the primary purpose or in relation to the primary purpose ("secondary purpose") will be in accordance with requirements under Privacy Act or other applicable laws or with your consent.
Pursuant to the Privacy Act, disclosure for a secondary purpose is generally not allowed unless an exception applies. some exceptions include where:
• you would reasonably expect Cathro & Partners to use or disclose Your Personal Information for the Secondary Purpose;
• the secondary use or disclosure is required or authorised by law or court or tribunal order;
• a permitted general situation or health situation exists in relation to the secondary use or disclosure; and/or
• Cathro & Partners reasonably believes that the secondary use or disclosure is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
We may use your personal information to:
• Set up and activate your account with Cathro & Partners;
• consider your request for our services;
• enable us to provide a service to you;
• coordinate delivery of your service offering;
• facilitate and process your payments;
• carry out or respond to your queries or requests;
• provide information to you that you have requested;
• provide additional information to you as requested by you and to respond to your queries about our services;
• facilitate reviews and to seek your feedback in relation to particular services provided, customer satisfaction and our relationship with you and to manage any customer complaints;
• for use in direct marketing of promotions, and services that we think might be of interest to you, including to add to a database compiled by us for this purpose;
• to monitor or improve the quality and standard of service that we provide to you;
• to consider any concerns or complaints you may raise against us;
• for regulatory reporting and compliance with our legal obligations;
• to contract or engage with you;
• to notify you of offers that may be of interest to you; and
• to better understand your preferences.
• for purposes relating to our service offering including financial, restructuring, insolvency and government advisory solutions
• for any other purpose disclosed to you at the time the relevant personal information is collected
If you have provided us with your personal information and do not wish to receive further information from Cathro & Partners, you can send us an e-mail at firstname.lastname@example.org and tell us that you do not want to receive future communications.
We may share your personal information (excluding information that is considered sensitive information) in circumstances where disclosure is associated with the primary purpose. We may share such information with Cathro & Partners affiliates, dealers, contractors, employees or other business partners to support your customer relationship with Cathro & Partners and to better service you. We will not give or sell this information to any other company for its use in marketing or solicitation and we will not disclose any sensitive information to any other party without your consent.
We may disclose this information:
• third parties to facilitate the provision of products and services to you
• to any third party suppliers, including third party application owners or licensors;
• to our third party service providers to assist us in providing and improving our services to you, and to analyse industry trends and better understand your needs or to develop, improve and market our services to you;
• third parties who provide services to us in connection with our business operations
• for regulatory reporting and compliance with our legal obligations; or
• to our agents, successors and/or assigns.
How to access personal information or ask for a correction
We take reasonable steps to ensure that the personal information that we collect and hold is accurate, complete and up-to-date. However, we rely on you to advise us of any changes to your personal information to help us maintain accurate, complete and up-to-date information.
You can access the personal information we hold by contacting us in writing and confirming who is requesting access to the personal information and for what purpose. On certain occasions, one of our employees may need to identify the person requesting the information. This is usually done by asking the stakeholder to confirm their identity by providing a copy of the stakeholder’s license or coming into our office in person. By taking this extra step, the we are ensuring that the personal information provided is going to the correct person and that personal information is not accessed incorrectly or fraudulently.
If you consider that there is any personal information that we hold about you that is inaccurate, out of date, incomplete, irrelevant or misleading, you are entitled to request correction of the personal information. After receiving a request from you, we will take reasonable steps to correct your personal information. If we make a correction and we have disclosed the incorrect information to others, you may ask that we notify the recipient of the correction
When you browse or use our website, we are able to determine your IP address. We use your IP address to help diagnose problems with our server, to administer our website, to measure the use of our website and to improve the content of our website. Basically, we use your IP address to gather aggregate demographic information.
Our website does not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.
Third Party Links
The Cathro & Partners website contains links to other non-Cathro & Partners websites. Cathro & Partners is not responsible for the privacy practices or the content of such websites and you should exercise your best judgement when sharing personal information on these websites.
Lodging a complaint and complaint handling
Complaints to Cathro & Partners
Your complaint will be referred to our Privacy Officer. The Privacy Officer will investigate the issue and determine the steps that we will undertake to resolve your complaint. You can contact the Privacy Officer using the details set out below. We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation.
Complaints to the OAIC
If you are not satisfied with our response or we fail to provide a response to your complaint within 30 days of receipt of your complaint, you can lodge a privacy complaint with the Office of the Australian Information Commissioner (OAIC). The contact details for the OAIC are set out below:
Post: GPO Box 5288, Sydney NSW 2001
Ph: 1300 363 992
Fax: (02) 9284 9666
How to contact Cathro & Partners
Att: The Privacy Officer
Post: Cathro & Partners Pty Ltd, Level 13, 333 George Street, Sydney NSW 2000.
Ph: 02 9189 1700