Privacy Policy

  1. ABOUT THIS POLICY

This Policy applies to personal information Gardner Brown Accountants (‘we’, ‘us’, ‘our’) collects through our website (www.gbaccountants.com.au) and in the course of providing accounting, tax and advisory services to our clients. It explains what personal information we collect, how we use, disclose and store it, and your rights — including the additional collection, verification, record-keeping and disclosure obligations we have taken on as a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and the AML/CTF Rules.

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and in accordance with our obligations under the AML/CTF Act. Where these obligations require us to collect, use, retain or disclose information in ways that go beyond what is set out in a client's engagement or terms of engagement, this Policy and the applicable law will apply.

We may, from time to time, review and update this Policy, including to reflect new or amended laws, new technology, or changes to our operations. All personal information we hold is governed by the most recently updated version of this Policy.

2. INFORMATION WE COLLECT

2.1 Information you provide through our website

We collect contact details and other information you provide directly, such as through enquiry forms, and any content you submit for publication (for example, comments or testimonials).

2.2 Information collected automatically through our website

Our website records certain information about your visit, generally against your IP address, including:

•     The type of browser you are using

•     The date and time of your visit

•     Your IP address

•     The website that referred you to ours

•     The pages you accessed and any documents downloaded

This information may be correlated over time using cookies, as described in section 7.

2.3 Information collected to provide our professional services

In the course of providing accounting, tax and advisory services, we collect personal information such as your name, contact details, date of birth, financial information, tax file number, and other information relevant to the services you engage us to perform.

2.4 Information collected for AML/CTF customer due diligence

Where we provide a 'designated service' under the AML/CTF Act (for example, assisting with the formation of a company or trust, acting as, or arranging for someone to act as, a director, secretary, trustee, partner or nominee shareholder, or managing client money or assets as part of such a service), we are required by law to collect additional information to identify and verify our clients, and, where relevant, any beneficial owners. This may include:

•     Certified copies of government-issued identification (e.g. passport, driver licence)

•     Proof of address

•     Information about the ownership and control structure of a company, trust or other entity, including beneficial owners

•     Information about the source of funds or source of wealth involved in a matter

•     Whether you, or a beneficial owner, are a politically exposed person (PEP)

•     Information obtained through electronic verification or screening against sanctions, watchlist and PEP databases

We collect this information because we are legally required to, and we are unable to provide the relevant designated service until this customer due diligence has been completed.

3. WHY WE COLLECT, USE AND HOLD YOUR INFOMATION

Contact details and publishable content are collected when supplied by you either via the website or direct to us by other means.

Click trails are recorded by our servers as each request reaches the website. This includes but is not limited to:

  • The type of browser you are using

  • The date and time of your visit

  • Your IP address

  • The address of the website that referred you to ours

  • The addresses of pages accessed and any documents downloaded

Click trails can be correlated over time by the use of ‘cookies’ as outlined in section 6. In most cases click trail data is not directly individually identifiable.

Activity history is recorded whenever you undertake an activity such as submit an enquiry, make a comment, vote on an object, and may additionally be recorded by us when you contact us offline.

3. WHY WE COLLECT IT AND HOW WE USE IT

We collect, hold, use and disclose personal information collected through our website to:

•     Respond to enquiries or requests you raise with us

•     Confirm your identity

•     Fulfil requests or orders you make

•     Keep you up to date with news, offers or other marketing information you have opted in to receive

•     Measure and monitor the performance of our website, estimate interest in our services, and refine our website's content

We collect, hold, use and disclose personal information collected in connection with our professional services to:

•     Provide the accounting, tax, advisory and other services you engage us for

•     Verify your identity and, where applicable, the identity of beneficial owners, as required under the AML/CTF Act

•     Assess and monitor money laundering and terrorism financing risk on an ongoing basis, including through transaction monitoring

•     Meet our reporting, record-keeping and other obligations to AUSTRAC and other regulators

•     Comply with our other legal and professional obligations (for example, under taxation law and our professional and ethical standards)

•     Manage and administer our relationship with you, including billing

4. CONFIDENTIALITY

We have an ethical duty of confidentiality, which means we must not share or disclose the details of any client engagement to anyone, except as set out in this Policy or your terms of engagement, without your consent, unless required to by law.

We may disclose your personal and confidential information, as part of our working papers of the services provided to you, to CPA Australia Ltd (if requested) for the purpose of conducting a CPA Australia Best Practice Program assessment aimed at maintaining high industry professional standards. Any such disclosure does not change any of our commitments to safeguard your information, and the information remains subject to any existing confidentiality obligations. By signing our engagement letter, you acknowledge that our engagement files relating to this assessment will be made available under this program.

Separately, and as described in section 8 below, the AML/CTF Act requires us to disclose certain information to AUSTRAC and other bodies in specific circumstances, regardless of client consent.

5. CONTENT YOU PUBLISH ON OUR WEBSITE

If you submit content for publication on our website (for example, a comment or testimonial), you give us a transferable, ongoing right to publish that content, and you confirm you own it or otherwise have permission to give us that right. We won't publish information you have specifically marked as private (such as your email address), except where there has been a clear breach of our website terms of use.

If you find your personal information published on our website without your consent, please contact us immediately using the details in section 14.

6. COOKIES

Cookies are small pieces of information exchanged between your browser and our website server, used to maintain your session and to remember information between visits. We use cookies to correlate website activity data and to help authenticate submissions such as enquiries or comments.

7. OPTING IN AND OUT

You can opt out of activity tracking by disabling cookies in your browser, though this may reduce some website functionality. Where you provide your email address, you may be asked to opt in to receive marketing communications, and you can opt out at any time using the unsubscribe link included in those communications.

8. DISCLOSURE OF YOUR INFOMATION

8.1 AUSTRAC

As a reporting entity under the AML/CTF Act, we are required by law to disclose certain information to AUSTRAC (the Australian Transaction Reports and Analysis Centre), including:

•     Suspicious matter reports (SMRs) — where we have reasonable grounds to suspect a matter may be relevant to money laundering, terrorism financing or other offences

•     Threshold transaction reports (TTRs) — for cash transactions above the applicable threshold, where relevant to our services

•     Enrolment and, where applicable, registration information about our firm and the designated services we provide

•     Other records and information AUSTRAC is entitled to request under the AML/CTF Act, including customer due diligence records

We are required to make these disclosures whether or not you have consented, and in some cases we are legally prohibited from telling you that a report has been made (see section 9, Tipping Off, below).

8.2 CPA Australia

As described in section 4 above, we may disclose engagement information to CPA Australia Ltd for professional standards assessment purposes.

8.3 Regulators and law enforcement

We may be required to disclose personal information to AUSTRAC, the Australian Taxation Office, law enforcement agencies, courts, or other regulators where required or authorised by law.

8.4 Service providers and offshore staff

We may from time to time engage third party specialist professionals and other public practitioners, where warranted, to obtain the advice you need or to assist us in providing our services to you. These may include cloud service providers, identity verification and screening providers used to meet our AML/CTF obligations, and outsourced service providers. We will seek your consent if third party involvement is likely to exceed the fixed price of an engagement (if applicable).

We have employment arrangements with offshore employees in the Philippines. The nature and extent of the services completed offshore are administrative. Acceptance of our services in conjunction with our engagement document indicates your acceptance of the use of offshore employees as described above.

8.5 Other circumstances

We may also disclose personal information collected through our website:

•     As part of the sale of all or part of our business

•     Where you have explicitly authorised us to at the time you supplied the information

•     As required for processing of payments by our payment gateway or merchant facility

•     As part of an investigation into a suspected breach of our website terms of use or applicable law

•     To lessen or prevent a serious threat to a person's health or safety

9. TIPPING OFF - IMPORTANT NOTICE

The AML/CTF Act contains 'tipping off' provisions which make it a criminal offence for us to disclose to you, or to any other person, that we have formed a suspicion about a matter, made or are considering making a suspicious matter report, or that such a report has been requested or provided to AUSTRAC. This means that in some circumstances we may not be able to tell you why we have declined to act, delayed a matter, or requested further information from you.

10. Data Storage and Security

In providing our services, we use Accountants Enterprise for the preparation of financial statements and tax returns. Cloud computing and storage is provided by MYOB and we rely on their security measures. MYOB data storage is located with Amazon Web Services, Sydney region. We also store client information, including information collected for AML/CTF customer due diligence purposes, on a data server managed by third party IT providers in Sydney, Australia.

For information collected through our website, we take reasonable steps to prevent loss, misuse or unauthorised access, including firewalls, password protection, truncation of stored card data, encryption of data in transit, and secured servers. No transmission over the internet can be guaranteed completely secure, and you provide information to us online at your own risk. You are responsible for keeping any website login credentials confidential.

11. Record Retention

Under the AML/CTF Act, we are required to retain customer identification, verification and transaction records for at least 7 years after an engagement or transaction ends, which may be longer than the retention period that applies to other tax and accounting records under taxation law. Records are retained securely and are only accessed for the purposes described in this Policy or as required by law.

12. Access, Correction and Complaints

You may request access to, or correction of, the personal information we hold about you, subject to any exceptions under the Privacy Act 1988 (Cth) or the AML/CTF Act (for example, we cannot disclose the existence of a suspicious matter report, and we may need to withhold certain AML/CTF records). We may ask you to verify your identity before actioning a request, and may charge a reasonable fee to cover the cost of responding.

If you have a concern or complaint about how we have handled your personal information, please contact us using the details in section 14. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

13. Changes to this Policy

We may update this Policy from time to time, including to reflect changes in our AML/CTF obligations or other legal requirements. The current version will always be available on our website or from us on request.

This Privacy Policy was last updated on

1 July 2026

14. Contact Us

If you have any questions or complaints about how we collect, use, disclose, manage or store your personal information, or would like to request access or changes to the information we hold, please contact us in writing at:

Gardner Brown Accountants

Suite 3, 11-15 Fitzmaurice Street, Wagga Wagga NSW 2650

PO Box 5257, Wagga Wagga NSW 2650

Phone: 02 5942 3400

Email: office@gbaccountants.com.au

ABN: 39 160 273 825