Your privacy is important to us and we are committed to being open and transparent about how we manage personal information. This helps build community trust and confidence in our organisation. Your Personal Information may be collected by us for the purposes of providing you a service. If you have any concerns on how we manage your Personal Information, please refer to the complaint’s section of this policy or speak to us.
In the Policy, references to ‘we’, ‘our’, ‘us’, and ‘Jarospace’ (as applicable), are references to Jaro Space Operations Pty Ltd (RAN 26220264, ABN: 89 648 528 750). Jarospace is a professional services company that holds an Australian Tax Agent License providing Self Managed Superannuation Fund (SMSF) establishment, administration, accounting, audit, tax and company secretarial services in Australia. We are bound by the provisions of the Privacy Act 1988 and the Australian Privacy Principles.
Service means the provision of SMSF establishment, administration, audit, accounting, tax and company secretarial services.
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not.
Sensitive Information means information or an opinion about an individual’s:
that is also Personal Information, or:
The Policy applies to Jarospace and our employees.
The Policy sets out how we manage your Personal Information. We respect the privacy of any Personal Information we collect about you, and we are committed to ensuring that this is handled in accordance with the provisions of the Privacy Act 1988, the Australian Privacy Principles, and any other applicable privacy related laws.
Where there is specific legislation, this will generally govern how we use Personal Information despite the provisions of the Privacy Act 1988. For example, for certain Financial Services, we are required to collect your tax file number and provide that information to the Australian Taxation Office.
Additionally, individuals located in the European Union may also have rights under EU based rules known as the General Data Protection Regulation (GDPR). The GDPR has harmonised the data privacy laws of each individual EU country, giving more rights to individuals located in the EU and more obligations holding their personal information.
The Policy will be reviewed from time to time or whenever there has been a change to the law or a change in our operations and practices regarding the maintenance of privacy.
The Policy is specific to the services we provide under our Australian Tax Agent Licence. It has been written specifically for clients of Jarospace because of the unique relationship we have with our clients.
Collection of Personal Information
The extent of information we may require from you may vary, however it often involves information required to establish your personal circumstances. The information we collect is necessary to properly provide our services on your behalf and in respect of your SMSF. These can be services provided over the short term; however, they are often part of a long-term relationship with us.
Collecting Personal Information also allows us to meet Australian and international legal or regulatory obligations that we, or product providers, might have to identify our customers. These may include, but are not limited to, our obligation to identify and verify clients under the Anti-Money Laundering & Counter Terrorism Financing Act 2006 or provide information to the US government if a client is considered a US resident for tax purposes under the US Foreign Account Tax Compliance Act.
Collection of Personal Information from Others
In some instances, your information may also need to be collected from third parties such as your accountant, mortgage broker or solicitor. It may also be provided to, or received from, third parties to enable a secondary service, such as when you are referred to a solicitor for SMSF legal advice or documentation. If these third parties approach us and request your Personal Information, we will ask for your consent before it is provided.
Relatives, Dependants and Other Individuals
To enable us to provide services, we will record information regarding your relevant personal circumstances, which may include information regarding your family situation, your partner, dependants, beneficiaries, and children. This information will only be gathered where it is necessary to provide you services, for example, where members of your family may become beneficiaries to your life insurance policy or SMSF. You are not obligated to provide this information; however, it may affect the quality of, or restrict the services provided to you.
Where this information is reasonably required from you, and you willingly provide it, we expect and assume that you have their consent to provide this information to us.
In these circumstances, you need to ensure that they are aware:
How do we use your Personal Information?
The Personal Information we hold is used for the primary purpose of providing you with SMSF administration and accounting services. We may also use your Personal Information for related secondary purposes such as: enhancing our customer service options; communicating with you regarding the services you have with us; handling your complaints; providing you with ongoing educational information including newsletters; and providing you with marketing material that we believe may be relevant to you. Where the secondary purpose is unrelated to the primary purpose for which you have sought our services, we will ask for your consent. You may provide your consent in writing, or via telephone.
Depending on the service concerned, your Personal Information may be disclosed to:
Generally, we require that organisations outside Jarospace who handle or obtain Personal Information as service providers acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy, and comply with the privacy laws.
Independent service providers
We may engage independent service providers to assist us in providing services to you. These services may range from contracting staff for providing back-office duties and administering client relationship management systems, to more complex tasks such as accounting and auditing SMSFs.
We expect these independent service providers to comply with the Policy and the privacy laws and regulations applicable to their jurisdiction.
Sensitive Information is subject to greater restrictions
Some Personal Information we hold is classed as Sensitive Information. Sensitive Information may have further restrictions on its disclosure. Sensitive Information will only be used and disclosed for the purposes for which it was provided, unless you specifically agree otherwise, or the use or disclosure of this information is allowed by law.
We will only collect Sensitive Information from you where it is reasonably necessary for us to require this information in order to provide the service to you. It will only be collected with your consent, or in limited other circumstances specified under privacy laws.
Unless we have your consent, we cannot use or disclose Sensitive Information about you for any purpose other than the primary purpose of the collection or a directly related secondary purpose (unless we are permitted to disclose this information under the law); nor can it be shared by related bodies corporate in the same way that they may share other Personal Information. Documents asking for Sensitive Information will explain this.
Marketing Material
From time to time, Jarospace (and its related entities) may promote services that we believe may be relevant to you. You can inform us if you do not wish to receive marketing material from us.
The ability to ‘opt-out’ does not include important disclosure documents and letters we may send to you that include communications required to be provided as part of our service delivery to you. Please allow up to 60 days for us to fully implement your “opt-out” request.
How does Jarospace keep my Personal Information secure and for how long is it kept?
We take all reasonable steps to ensure that your Personal Information is kept secure and is protected from misuse, loss and unauthorised access, modification, and disclosure.
We retain your Personal Information for as long as we need it to provide the Services you have requested from us and, in some circumstances, to comply with other statutory requirements. As required under the privacy law, we will take reasonable steps to permanently de-identify or destroy Personal Information that is no longer needed.
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the Internet, or other electronic medium. We train our employees who handle Personal Information to respect the confidentiality of client information and the privacy of individuals.
Jarospace has appointed a Privacy Officer to ensure that the management of Personal Information is in accordance with the Policy and the Privacy Act 1988.
Cross-border Disclosure of Personal Information (overseas recipients)
In the course of providing you with Services, we may engage in the services of organisations based overseas, or organisations based in Australia that utilise services themselves from overseas. Where Personal Information is disclosed to these overseas locations, we expect these organisations to comply with this Policy and any relevant privacy laws and regulations applicable to their jurisdiction.
Dealing with breaches
We consider breaches of your privacy to be very serious. If this happens, we will ensure that appropriate investigation occurs in a timely fashion, and where necessary, apply appropriate consequence management and/or remediation.
We will be required to notify you and the Office of the Australian Information Commissioner (OAIC) if an ‘eligible data breach’ occurs in relation to your Personal Information that is held by us or another entity with whom we have shared your information. A data breach may occur if your Personal Information is lost or subjected to unauthorised access, modification, disclosure or other misuse or interference, and it is generally notifiable if there is a risk of ‘serious harm’ (for example, financial or reputational harm) to you due to the breach. This obligation extends to breaches that occur within Australia, and overseas.
We will also report any privacy breach as required under any other applicable laws.
Can I access my Personal Information?
You have the right to access any Personal Information that we hold about you. You can ask us for access to Personal Information that we hold about you at any time. To do so, please email the Privacy Officer at info@jarospace.com
We will respond to your request within 30 days (unless unusual circumstances apply). We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing, and copying any material requested. We will always check this with you first. If the information sought is extensive, we will advise you of the likely cost in advance and can help to refine your request if required.
We will provide you with access to Personal Information held about you except to the extent that we are permitted to refuse access in accordance with the Privacy Act 1988 and the Australian Privacy Principles. If we refuse to provide you with access to some information, we will provide you with our reasons in writing for doing so. If you have concerns, you may lodge a complaint.
Correction of Personal Information
We will correct any Personal Information that we hold about you if we become aware that it is inaccurate, incomplete, out of date, irrelevant or misleading.
If you believe that the Personal Information we hold about you is inaccurate, incomplete, out of date, irrelevant or misleading, you can ask us to correct it and we will take reasonable steps to do so. If there are any instances where we cannot do this, we will let you know in writing.
If we disagree that the information is inaccurate, incomplete, or out of date, we will take reasonable steps to include a note on your record that you believe that such information is inaccurate, incomplete, or out of date.
Enquiries and Complaints
If you consider that any action by us breaches the Policy, the Australian Privacy Principles or otherwise fails to respect your privacy, you can make a complaint. Upon the lodgement of a complaint with us, you will receive an acknowledgement letter and an indication of the timeframe in which we will respond to your complaint.
We will try to resolve your complaint within 30 days. When this is not possible, we will inform you of the reasons for the delay and how long we believe it will take.
To make a complaint, please forward it in writing to:
The Compliance Manager
Jarospace Operations Pty Ltd
C/O Creative Cubes
Level 5, 111 Cecil Street
SOUTH MELBOURNE VIC 3205
If you are not satisfied with our response to your complaint, you can escalate the matter to the Office of the Australian Information Commissioner (OAIC) to complain about the way we have handled your personal information.
The OAIC can be contacted at:
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Email enquiries@oaic.gov.au
Phone 1300 363 992