Privacy Policy

We take our privacy responsibilities seriously. Please read our privacy policy below in full and get in touch with our team should you have any concerns.

Policy Statement

This policy states DA’s commitment to safeguarding the confidentiality and integrity of the personal or sensitive information it may collect, process and store at any time in respect of any individual in accordance with the requirements of the Privacy Act 1988 (Cth) and the accompanying 13 Australian Privacy Principles.

Personal Information Definition

The Privacy Act 1988, defines “personal information” as: “information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or ”

The types of information that are deemed personal information are unlimited and can vary widely.

Individual Identifiers and Identification Information

The Privacy Act defines the “identifier of an individual” as:

“a number, letter or symbol, or a combination of any or all of those things, that is used to identify the individual or to verify the identity of the individual, but does not include:

• the individual’s name; or
• the individual’s ABN (within the meaning of the A New Tax System (Australian Business Number) Act 1999); or
• anything else prescribed by the regulations.”

Further, identification information about an individual is defined as:

• “the individual’s full name; or
• an alias or previous name of the individual; or
• the individual’s date of birth; or
• the individual’s sex; or
• the individual’s current or last known address, and 2 previous addresses (if any); or
• the name of the individual’s current or last known employer; or
• if the individual holds a driver’s licence, the individual’s driver’s licence ”

Personally identifiable information (PII), while not defined under the Privacy Act, is a commonly used term in the finance industry. Common examples of a personal identifier of an individual (PII) are a Bank Account Number, a Tax File Number or Medicare Number, passport number, credit information and employee record information.

Sensitive Personal Information

In addition to “personal information”, the act also defines a subset of personal information called “sensitive information”. “Sensitive personal information” is generally given a higher level of protection under the Privacy Act than other personal information. Examples include an individual’s health, genetic and biometric information, and information about an individual’s race or ethnicity, political opinions or associations, religious or philosophical beliefs, sexual orientation or criminal record.

Policy Detail: Australian Privacy Principles

There are 13 Australian Privacy Principles (APPs) embedded within the Privacy Act that entities must adhere to, which govern the standards, rights and obligations around:

• the collection, use and disclosure of personal information;
• an organisation or agency’s governance and accountability;
• integrity and correction of personal information; and
• the rights of individuals to access their personal information

Personal Information Collection

DA collects personal information in a variety of ways, including electronic interaction, physical documentation, in person and through the provision of services and products we provide. DA does not collect personal information via social media platforms.

DA will only collect personal information by lawful means for the purposes related to the business function or activity

We will endeavor to collect personal information directly from the individual. However, in the course of operating our business, we may collect personal information from third parties such as suppliers, recruitment agencies, contractors, our clients and business partners.

Where appropriate, if we collect personal information from a third party, we will request that the third party informs you, and directs you to our Privacy Policy.

Use Of Personal Information

DA will limit the collection and use of any personal data to the primary purpose for which it was collected, except:

• Where the purpose is related to the primary purpose and necessary for valid business purposes;
• Where our client consents to us using it for any purpose to meet client business requirements;
• Where personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order or legal process;
• Where it is used to design new or enhance existing products, information and services provided by DA;
• Where employee personal information collected will be used by the leaders and DA’s HR team to support employees and day to day operations; and
• where DA has identified other purposes as notified at the time of

DA does not sell or trade personal identification information with others, including entities overseas.

Quality and Security Management of Personal Information

It is important to us that your personal information is up to date. DA will take all reasonable steps to ensure:

• personal information is accurate, up to date and complete; and
• protection of personal information from misuse, interference and loss or from unauthorised access, modification, disclosure or other misuse.

If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

DA ensures that personal information is only accessed within the secure environment of the network or an authorised cloud or storage service.

DA uses secure methods to destroy or de-identify any personal information when the law permits, provided the information is no longer needed by us or our clients for any purpose.

Access and Correction

Individuals have the right to request access to their personal information and to request that it is corrected if it is out of date or incorrect. DA will not require a reason for such a request however identification may be required before the personal information is released. A reasonable fee may be charged if providing access is manifestly unfounded, excessive, or requires significant amount of time in order to provide it in an appropriate format.

Request for access or correction of personal information should be addressed to DA’s Privacy Officer. Requests will be addressed in a timely manner, and if we are unable to provide access, we will inform the requestor of the reason for the decision.

DA will not provide access to, or correct, personal information collected by our clients from their members, employees and suppliers, except for accepted business as usual activities, or as directed by the client in writing, or unless as directed by law.

Non-Disclosure of Personal Information

All contractors and third parties, business partners and vendors are required to sign a Non- Disclosure Agreement prior to commencement of contractual obligations and are bound to keep data confidential and may not use it for any purpose other than to fulfil their function.

All DA employees are required to sign and comply with confidentiality clauses as part of their employment contracts.

Inquiries and Complaints

DA is committed to dealing with complaints in relation to privacy and resolving issues in a reasonable timeframe.

• Any questions or complaints by an individual in relation to privacy can be raised with DA’s Privacy Officer.
• Any privacy related questions or complaints by our clients in relation to the services we provide should be logged via the standard support channel.
• DA employees or contractors should direct any privacy related questions or complaints to Human Resources.

If you are not satisfied with the handling of the complaint, you may refer your concerns to the Office of the Australian Information Commissioner at www.oaic.gov.au or 1300 363 992.

Non-Compliance

Employees found to be non-compliant with this policy may be subject to disciplinary action, up to and including termination of employment.

Any vendor, consultant, or contractor found to be non-compliant with this policy may be subject to measures up to and including removal of access rights and termination of contract(s).

Changes to our Privacy Policy

This document reflects our Privacy Policy as at August 2023.

Any changes we make to our Privacy Policy will be posted on this page. Please check back from time to time to see any updates or changes to the policy.

How to Contact Us

If you have any further questions regarding our Privacy Policy, please make use of the Contact Us section on this website or contact our Privacy Officer.

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