Privacy Policy

 

  1. INTRODUCTION
  1. Humphries Associates Limited (“we”, “us”, and “our”) complies with the New Zealand Privacy Act 2020 (“the Act”), when dealing with personal information. Personal information is information about an identifiable individual (a natural person).
  2. We collect and store personal information for the purpose of conducting our business of providing accounting, taxation and business advisory services. We also collect and store personal information to market our services and to comply with applicable laws and regulations, including in relation to our privacy and anti-money laundering compliance obligations.
  3. Depending on the nature of your engagement with us and the services required, the personal information we will collect from you may include:
  1. a) Name, date of birth, gender, address, and contact details.
  2. b) Employment details and employment history.
  3. c) Education and qualification.
  4. d) Payment details and billing information, including bank account details.
  5. e) Government-issued identification information, including drivers licenses and passports.
  6. f) Financial information, including financial accounts, IRD number, payroll information, income, expenditure, salary and assets.
  7. g) Information provided by government departments predominantly Inland Revenue Department.
  8. h) Device and website analytics.
  1. We regard privacy as an important part of our relationship with our customers. The following Privacy Policy applies to all users of our services and visitors to our website.
  2. This policy sets out how we will collect, use, store, protect and disclose your personal information. We also explain your rights to access and correct your personal information.
  3. This policy does not limit or exclude any of your rights under the Act. If you wish to seek further information on the Act, see www.privacy.org.nz. 
  1. USE OF INFORMATION

2.1 In order to access and use our website or services, we may require personal information from you and other sources in order to provide the best service possible. Providing personal information is optional, however, if we are unable to obtain the requested personal information from you or you are unwilling to provide that information to us, it may affect the quality or ability for us to provide services to you and our ability to meet our legal obligations.

2.2 We only use your personal information in connection with our products and services as set out in this Privacy Policy and otherwise as authorised by you.

  1. COLLECTION OF INFORMATION

3.1 We will only ever collect information about you where you directly, or a third party authorised by you, have knowingly provided this information to us, other than where this information is publicly available.

3.2 The circumstances in which we collect personal information about you include the following:

  1. a) Where you interact with us in person, remotely, or through electronic means.
  2. b) Where you use and interact with our website, in accordance with our use of cookies as set out in this Privacy Policy.
  3. c) Where provided by a third party authorised by you. 

3.3 We engage third-party agents to assist with our services. This includes agents engaged to meet Customer Due Diligence (CDD) requirements under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, as well as other third parties ancillary to our services, as described in Section 7. Personal information may also be collected by third parties ancillary to our services in accordance with all applicable laws and the terms of this policy. If we, or those third parties are unable to obtain the requested information from you, or if you are unwilling to provide that information, it may affect the quality of, or ability for us and/or those third parties to provide services to you.

3.4 You must not provide us with the personal information of another person unless you have their authorisation to do so and have taken reasonable steps to inform them of the terms of our Privacy Policy.

  1. STORAGE OF COLLECTED INFORMATION

4.1 The security of your personal information is important to us and we are required to take reasonable care to ensure that your personal information is protected against loss, misuse, or unauthorised disclosure. Our storage procedures are as follows:

  1. a) We hold and store limited hard copies (on paper) of personal information on site at our physical business premises. During and on completion of the required services, all records which need to be retained are scanned digitally and any other records are returned to you. All digital records are stored and processed by our cloud services provider, which is a third party. We do not use off-site facilities to store hard copies of any records.
  2. b) All correspondence may also be stored, particularly in regard to sales, support and accounts, including email, financial information and letters.
  3. c) When you enter sensitive information on our website, we encrypt that information using secure socket layer technology (SSL).
  4. d) We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
  5. e) We will not keep personal information for longer than is necessary for the purpose of which it was collected.

4.2 Where you transmit any personal information to us electronically, you acknowledge that such transmission is at your own risk and that while we take all reasonable care to ensure that your personal information is protected against loss, misuse, or unauthorised disclosure in accordance with this Privacy Policy, we cannot prevent the misuse of your personal information by unauthorised persons.

4.3 Where you publicly share any personal information through your engagement with our social media accounts or activity on any social media sites or platforms, you acknowledge and agree that we are not liable for any misuse of such personal information by unauthorised third parties.

4.4 We will store accounting records that we hold on your behalf for a period of 7 years after the applicable balance date. In the case of trust engagements, trust documents and records will be retained for the life of the trust. At the end of the relevant period, unless you advise us that you wish any remaining hard copy or digital records to be forwarded to you, the records will be destroyed using a secure document destruction method and/or permanently removed from our digital archives, where applicable. We otherwise will not keep personal information for longer than is necessary for the purpose of which it was collected or unless required by law.

  1. ACCURACY AND ACCESS TO COLLECTED INFORMATION

5.1 Under most circumstances you have the right to reasonable access to personal information we hold, and to request that your personal information be updated or corrected.

5.2 We reserve the right, however, to refuse you access to your personal information in circumstances provided for at law, including under the Act. We also reserve the right to charge you a reasonable fee when providing information to you as a result of any privacy request and where otherwise permitted by the Act. 

5.3 You are encouraged to review, correct, and update personal information so that it is maintained as completely, accurately and as up-to-date as possible. If your personal information changes or if you no longer desire our services, you may correct, update, delete or deactivate it by emailing us at ad***@****************co.nz. 

  1. COMMUNICATIONS

6.1 We may use your personal information for the following purposes:

  1. a) Essential Communications: essential communications with you, including emails, accounts information, and critical service details required to provide our services or respond to your enquiries.
  2. b) Marketing and Promotion: providing you with marketing and promotional communications, including emails.

6.2 We are not liable for any security or privacy breach or hacking that occurs as a consequence of your failure to use systems and online procedures that are secure and authenticated when communicating information to us. You acknowledge that you play an important role in protecting your information by taking basic precautions to protect your computer and data. You should keep your computer secure, only deal online with people and organisations you know and trust, and check that your personal information travels across the internet on secure connections. There are many resources about computer security (such as websites, books, and magazines) that can help guide you on what security precautions are appropriate for your situation.

6.3 You consent to receiving promotional or marketing communications by electronic message, phone call, SMS or other communication methods from us or from third parties on our behalf. You may opt out of receiving those electronic messages or other communications by using any unsubscribe facility that accompanies an electronic message or other communication or by emailing us at ad***@****************co.nz. 

  1. THIRD PARTIES AND NON-COMPLIANCE WITH LAWS AND REGULATIONS (NOCLAR)

7.1 We may disclose your personal information to third parties, where necessary, for the following purposes:

  1. a) Where we, at our discretion, use third parties to provide essential services on our website or for our business processes, including:
  2. To undertake checks that are necessary under law on our behalf, including those required under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and other similar laws.
  3. To perform functions and provide services on our or your behalf, including data storage providers, book keeping and other accounting service providers, payment platforms (including payment processing services provided by Stripe, Inc.), audit programs, digital signing, and other IT service providers and our professional advisors.

iii. To government departments, including Inland Revenue Department, to perform services on your behalf and comply with our legal obligations.

  1. To debt collection agencies, to recover debts on our behalf.
  2. As otherwise provided for in our Engagement Letter and/or Terms and Conditions of Engagement.
  3. As otherwise required by law.
  4. b) Where we require certain information from third parties including solicitors, bankers, or other organisations to complete the services agreed, you authorise us to collect and disclose information relating to your affairs direct from and to such third parties as you specifically authorise, either verbally or in writing.
  5. c) As members of Chartered Accountants Australia and New Zealand (CA ANZ), we are subject to and are bound by the rules and procedures of the organisation, so work and files are subject to practice review rules and requirements. Our compliance with professional rules and standards is monitored. These procedures may require us to disclose part or all of your personal information to CA ANZ, its reviewers and/or disciplinary bodies. You therefore acknowledge and agree to disclosure of files and information made for these purposes. We assure you that the same ethical standards regarding confidentiality that we adhere to will apply in these circumstances as well as similar data protection safeguards as those under the Act.
  1. We may be required to disclose your personal information to third parties in the following circumstances:
  1. To comply with our legal obligations, including in response to requests by government or law enforcement agencies, courts, tribunals and regulatory authorities.
  2. To comply with any rules, regulations, by-laws, professional and ethical standards, and/or guidelines.  As members of CA ANZ, we are required to comply with any rules, regulations, by-laws, professional and ethical standards, and guidelines of CA ANZ and the New Zealand Institute of Chartered Accountants (NZICA), including the NZICA Code of Ethics. In accordance with the NZICA Code of Ethics, where in the course of our engagement we become aware of your actual or suspected non-compliance with laws and regulations (NOCLAR), you accept and acknowledge that we may be required to take further action including reporting the non-compliance to an appropriate authority.  We will endeavour to alert you before making any such disclosure, unless we are prohibited from doing so by the NZICA, CA ANZ or any relevant law.
  3. To respond to your questions in relation to our services and to undertake the services you have engaged us to provide to you; or
  4. To comply with any data privacy or security audits or to investigate or respond to a complaint or security threat.
  1. We will not, however, disclose your personal information to third parties except in the circumstances set out in this Privacy Policy.
  2. You acknowledge and accept that we may share with and you may provide personal information directly to third parties based outside New Zealand particularly in terms of third party service providers ancillary to our services including AML providers, data storage providers, book keeping and other accounting service providers, payment platforms, audit programs, digital signing and other IT service providers. This personal information may be stored overseas and may be processed in an overseas country which does not provide the same level of protection to personal information as in New Zealand and you consent to the provision of personal information to these third parties. If at any time you do not consent, please email us at ad***@****************co.nz, but it may affect our ability to provide our services to you.

7.5 We recommend that you review the privacy policy of any third parties you specifically authorise so you can understand how your personal information will be handled by the particular third parties. This Privacy Policy sets out only how we protect your personal information when collecting, using, and storing it and we provide no warranty as to the handling procedures of any third party.

  1. LINKS

Links on our website to websites of external entities are provided for your information and convenience and are not covered by this policy. The terms and conditions set out in this Privacy Policy only cover the domain names directly maintained by us. We recommend that you review any external site’s privacy policy before you provide personal information so that you can understand how personal information will be handled by external entities.

  1. CHANGES TO PRIVACY POLICY

9.1 We reserve the right to modify this Privacy Policy (and associated documents) at any time in our sole discretion.

9.2 Any such amendments will be published on our website and will be considered effective immediately upon publication. We therefore recommend that you review our Privacy Policy frequently.

  1. USE OF COOKIES

10.1 Some pages on our website use ‘cookies’, which are small files that may be placed on your hard disk for record-keeping purposes. A cookie allows us to remember who you are. Cookies can make your subsequent visits to the web page simpler and more seamless. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. By not accepting cookies, however, some web pages may not display properly, or you may not be permitted to access certain information.

10.2 Our website also uses Google Analytics to help us better understand how visitors are engaging with our website. If you wish to seek further information about Google Analytics or review Google’s privacy policy, see https://www.google.co.nz.

  1. COMPLAINTS

If you have any concerns, questions, comments, or complaints about our privacy practices and the way in which we collect, store and use your personal information, please contact our Privacy Officer: Blair Jarvis at bl***@****************co.nz.

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