Privacy Policy — Fluid Business Advisory

Counting House Associates Pty Ltd trading as Fluid Business Advisory ACN 159 770 279 (“we”, “our”, “us”) is committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Policy explains how we collect, use, disclose, and secure personal information across our professional services, websites and portals, offices and events, and other interactions. It also explains how you may access and correct your information and make a privacy complaint.

Who this Policy applies to

Clients and prospective clients; individuals connected with our clients; suppliers and business partners; job applicants; event attendees; and visitors to our sites, portals and offices. Personal information about our current and former employees is handled in accordance with law and internal policies and is not covered here to the extent the employee records exemption applies.

Personal information we collect

Depending on our dealings with you, we may collect:

Identification and contact details: name, title, date of birth, address, email, phone, organisation and role.

Government identifiers and regulatory details (where permitted): TFN, ABN, Director ID, licence/registration numbers and proof-of-identity documents (e.g. driver licence, passport). We handle TFNs in line with the Privacy (Tax File Number) Rule 2015.

Financial and tax information: bank details, payroll and superannuation details, income/expense records, assets and liabilities, shareholdings and related data relevant to accounting, tax, audit and advisory services.

Engagement information: instructions, communications, working papers, documents and files created or received in providing services.

Online and device data: IP address, device identifiers, browser type, pages visited, timestamps and cookie data used for functionality, security and analytics.

Sensitive information: only where reasonably necessary for our functions and with consent or as permitted by law (e.g., accessibility needs for events, professional-association membership, criminal history checks for onboarding where applicable).

We generally do not collect information about children unless relevant to our services and with appropriate authority.

How we collect information

Directly from you (e.g., emails, forms, portals, calls, meetings, events/webinars) and from third parties (e.g., your employer, other advisers, regulators, service providers, public sources or information brokers) where reasonably necessary for our functions and activities.

Why we collect, use and disclose information

To:

provide and improve professional services (accounting, tax, audit, advisory and related services);

verify identity, conduct client acceptance/onboarding and conflicts checks;

manage engagement administration, billing and payments;

operate, maintain and secure our websites, portals and IT systems;

send service messages, updates and (where permitted) marketing communications;

comply with laws, professional/ethical obligations and respond to lawful requests;

manage business operations, risk and quality assurance (including training, audits and analytics); and

consider applications for employment and manage recruitment.

Marketing communications

We may send information about our services, events and insights. You can opt out at any time (unsubscribe link or via our contact details). We comply with the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth) for electronic marketing and telemarketing.

Cookies and analytics

We use cookies and similar technologies for site operation, remembering preferences, security and analytics. You can manage cookies through your browser; some features may not function properly without them. We may use third-party analytics tools that process de-identified or aggregated data to help improve our services.

Disclosure of personal information

We may disclose information to:

our partners, employees and contractors who need it to perform their work;

related entities and associated firms in Australia and (where relevant) overseas that assist with services;

third-party service providers (e.g., IT/cloud hosting, practice management, CRM/billing, document storage/e-signature, cyber-security monitoring, analytics, mailing houses and archiving);

your authorised representatives and other advisers as instructed;

regulators and government bodies (e.g., ATO), courts and law enforcement where required or authorised by law; and

a purchaser or prospective purchaser in connection with a restructure, sale or transfer of all or part of our business.

We contractually require service providers to handle personal information in accordance with the Privacy Act and with appropriate security safeguards.

Overseas disclosures

Some recipients (e.g., cloud hosting, IT support or network firms) may be located outside Australia, including New Zealand, United States, United Kingdom, EU member states, India, Philippines, Singapore. We take reasonable steps to ensure overseas recipients do not breach the APPs (APP 8) unless an exception applies.

Data security

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure (APP 11). Measures include role-based access, MFA for key systems, encryption in transit and/or at rest where appropriate, secure disposal and retention controls, staff training, monitoring and incident response.

Notifiable Data Breaches (NDB) scheme

If a data breach is likely to result in serious harm, we will promptly assess and, where it is an eligible data breach under the Privacy Act’s NDB scheme, notify affected individuals and the OAIC.

Access and correction

You may request access to personal information we hold about you and request corrections where it is inaccurate, out-of-date, incomplete, irrelevant or misleading (APPs 12–13). We may ask you to verify your identity and specify what you seek. In some cases we may refuse access under a lawful exception; if so, we will tell you why.

Client confidentiality and professional obligations

We comply with confidentiality obligations under taxation laws (including the Taxation Administration Act 1953), the Tax Agent Services Act 2009 and its Code of Professional Conduct, as well as applicable professional and ethical standards (e.g., APES 110). Nothing in this Policy limits those obligations.

Retention

We retain personal information as needed for the purposes above and to meet legal, regulatory and professional record-keeping requirements. When no longer required, we take reasonable steps to destroy or de-identify it.

Questions and complaints

Contact our Privacy Officer using the details below. We will acknowledge and respond within a reasonable period. If you are not satisfied, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

Privacy Officer

Fluid Business Advisory
PO Box 344, Smithfield QLD 4878
Phone: 07 4041 2581 Email: info@fluidadvisory.com.au

Changes to this Policy

We may update this Policy to reflect changes in law, technology or our practices. The latest version will be available on our website.