entities (“Brooke”, “we”, “us”) operating within Australia and the practices that we will follow to respect
the privacy of individuals who deal with us (“you”). This statement is provided in accordance with the
Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APP’s”) which are set out in that Act.
Collection of Personal Information
The kinds of personal information which we collect and hold generally include the following:
• Addresses (including email addresses)
• Telephone and facsimile numbers
• Date of Birth
• Occupation and Job Title
• Details about next of kin including spouse and children’s names
• Financial Details
• Membership of professional associations
• Social interests
The information which we collect and hold may come from a number of sources including:
• Potential employees
• Independent contractors
• Existing and new contacts and clients of Brooke
• Other individuals
• In the course of carrying out client engagements
Some information which we hold may be “Sensitive Information”
We will only collect your Sensitive Information with your consent or if we are required to do so by law.
Sensitive Information is information or an opinion about an individual’s:
• Race or ethnic origin
• Political opinion
• Membership of a political association
• Religious beliefs, affiliations or philosophical beliefs
• Membership of a professional or trade, association or membership of a trade union
• Sexual orientation or practices
• Criminal record
Sensitive Information also includes health information about an individual.
We will not collect your personal information unless the information is necessary for, or directly related to, one or more of our functions or activities. We will collect your personal information only by lawful and fair means and not in an unreasonably intrusive way.
• Our identity and contact details
• The fact that you can gain access to your information and ask us to correct it
• The purposes for which we collect your information
• The intended recipients or organisations to which we usually disclose your information, including any overseas recipients and the countries in which they are located
• The fact that you may make a privacy complaint and how we will deal with it
• Any law that requires the particular information to be collected
• The main consequences (if any) for you if all or part of the information is not provided
Where it is reasonable and practical to do so, we will collect your personal information only from you. If however we collect this information from someone else, we will act reasonably to ensure that you are or have been made aware of the matters listed above.
The Purposes for which we use Personal Information
The purposes for which we use personal information include the following:
• To respond to requests from individuals
• To consider potential employee’s applications for employment with us
• To open and administer our client accounts
• To provide professional services to our clients
• To administer our independent contractors
• For marketing and sales initiatives such as Brooke publications, information about our service offerings, events and seminars
• For any other purpose related to the business we carry out
If you do not provide us with all or part of your personal information, we may not be able to carry out the purposes which are set out above, including the provision of professional services to you.
Use and Disclosure
As a general rule, we will not use or disclose your personal information other than for its primary purpose of collection, unless:
• You have consented to the use or disclosure; or
• You would reasonably expect us to use or disclose your non-Sensitive Information for a secondary purpose and the secondary purpose is related to the primary purpose; or
• We have reason to suspect that unlawful activity has been, or may be engaged in, and use or disclose your personal information as a necessary part of our investigation of the matter or in reporting our concerns to relevant persons or authorities; or
• The use or disclosure is required or authorised by or under law; or
• We reasonably believe that the use or disclosure is reasonably necessary for a specified purpose by or on behalf of an enforcement body; or
• We reasonably believe the use or disclosure is necessary to prevent or lessen a serious and imminent threat to public health or public safety or the life or health of an individual.
We may also disclose your personal information to our service providers who assist us with the provision of client services, administrative support or our general business operations. These service providers are generally located within Australia, however in some cases they may operate outside of the jurisdiction. We remain responsible for maintaining the confidentiality of information which we disclose to our service providers and ensure that contracts with these parties contain terms that confirm personal information is managed according to the same standards which we have implemented within our organisation.
Disclosure of Personal Information outside of Australia
We are a member of the global network of Brooke companies (Brooke Network) and in this capacity we may disclose your personal information to other members of the Brooke Network and their personnel for purposes related to the provision of services to you, to comply with regulatory requirements, to check conflicts, for quality, risk management or financial accounting purposes, or the provision of other administrative support services. Your personal information may be processed for these purposes in the various countries in which we and the other members of the Brooke Network operate.
Brooke Network office locations are listed on our website, brooke.global.
We may use your personal information for our direct marketing purposes where:
• The information has been collected from you and you would reasonably expect us to use it for that purpose; or
• The information has been collected from someone other than you and we have either obtained your consent, or it is impractical for us to obtain your consent before that particular use
• We provide a simple means by which you may easily request not to receive direct marketing communications from us
• In each direct marketing communication with you, we draw to your attention, or prominently display a notice, that you may express a wish to “unsubscribe” or not to receive any further direct marketing communications
• You have not made a request to us not to receive direct marketing communications.
When engaging in direct marketing activities we will:
• Not charge you for giving effect to a request not to receive direct marketing communications from us
• Only use Sensitive Information about you if you have consented to the use or disclosure of your information for that purpose
• Always be subject to any overriding obligations under anti-spam or do-not-call legislation
We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete, up to date and not misleading.
We will take reasonable steps to protect the personal information we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.
We will not keep personal information for longer than is necessary and will take reasonable steps to destroy or permanently de-identify personal information if there is no longer a legal or business requirement for us to retain it.
We have set out in this document our policies on management of personal information and will make this document available free of charge to anyone who asks for it.
On request by a person, we will take reasonable steps to let the person know, generally, what sort of personal information we collect and hold, for what purposes, and how we collect, hold, use and disclose that information.
Access and Correction
As a general rule, we will on request by you, provide you with access to your personal information within a reasonable time after such request is made and consider any further request from you for correction of that information. We may impose a reasonable charge upon you to cover the cost of locating, retrieving, reviewing and copying any material requested.
We may in some limited circumstances choose not to provide you with access to your personal information where we are permitted to do so. This may include instances where providing access would be unlawful or providing access would have an unreasonable impact on the privacy or affairs of other individuals.
In circumstances where we have refused you access to, or correction of, your personal information, we will give you a written notice that sets out:
• the reasons for the refusal where it is reasonable for us to do so; and
• the way in which you may make a complaint about such refusal.
We will not adopt a government related identifier or other unique identifier (such as a tax file number or Medicare number) as our identifier of you.
We will not use and/or disclose government related identifiers unless such use or disclosure is reasonably necessary for us to verify your identity for the purpose of our activities, or alternatively, the use or disclosure is required or authorised under law.
Wherever it is lawful and practical, we will allow you the option of not identifying yourself or of using a pseudonym when entering into transactions with us.
Changes to this policy
How can an Individual Complain about Possible Breaches of Privacy by Brooke
A complaint by you regarding an alleged breach of privacy by us should be forwarded in writing to the following mailing address or email:
Privacy Compliance Officer Brooke Global Level 14, 309 Kent Street Sydney, NSW, 2000
A Privacy Complaints Officer will be made available to investigate and resolve the complaint internally through mediation with you.
If you are not satisfied with the outcome of your complaint, you can refer your complaint to the Office of the Australian Information Commissioner.