1. Purpose of policy

This Privacy Policy applies to the collection, use, disclosure and handling of personal information by Papallo Kouchoo Lawyers Pty Ltd (we or us) and including any personal information collected via our www.pklawyers.com.au website (the “Site”).

We are committed to protecting the privacy of individuals and is bound by the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (“the Act”).

We will only collect, use or disclose personal information in accordance with the Act and this Privacy Policy.

Your use of the Site is also subject to the Terms of Use as may be published by us upon from time to time.

2. Collection

We may collect personal information from you in a number of different ways. We may collect personal information directly from you or in the course of our dealings with you, for example when you:

• provide personal information to us;
• apply for a position of employment with us;
• use our Site or services (including via cookies); and
• contact and correspond with us, for example to ask for information.

We may also, if you consent, collect personal information about you from other entities, from publicly available sources of information, or in some cases, from third parties including recruitment agencies, previous employers, and third party service providers which provide criminal, bankruptcy and other checks.

The personal information we collect about you may include (but may not be limited to) your name, date and place of birth, contact details, Internet Protocol (IP) address, occupation and education/work history, employer, legal and industry areas of interest, passport details and information relating to your dealings with us and our clients.

We may also collect sensitive information about you, including health information and criminal background checks.

The purposes for which we collect your information may include:

• verifying your identity;
• contacting you (including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner);
• providing you with legal services or legal information;
• undertaking conflict searches for our own purposes and the purpose of determining if we can represent a client or potential client;
• acting for a client when it acquires a business with employees;
• acting for a client in litigation against an individual;
• acting for a client in a matter against an individual (eg an employment matter); and
• developing and improving our services and obtaining feedback.

If we are not able to collect personal information about you we may not be able to provide you with services and assistance to the extent that they require us to collect, use or disclose personal information.

3. Use and disclosure

We may use or disclose your personal information for the purpose for which it was collected. We will also use and disclose your personal information for a secondary purpose that is related to a purpose for which we collected it, where you would reasonably expect us to use or disclose your personal information for that secondary purpose.

Other instances when we may use and disclose your personal information include:

• where you have expressly or impliedly consented to the use or disclosure;
• in confidence, to our advisers and insurers;
• where the use or disclosure is authorised or required by or under an Australian law or court/tribunal order;

• sharing your personal information with our advisors and consultants; and
• with third party service providers we use in conducting our business, subject to confidentiality provisions as we deem appropriate (including, without limitation, insurance brokers, banks, external photocopying providers, document production, legal outsourcing providers, billing or data storage services, email filtering, virus scanning and other technology services providers, and archival services providers).

4. Information about events, the Site and our services

We may contact you via email, SMS or other means in order to provide you with updated information about the Site, in relation to events or to provide you with other information about our services. If you do not wish to receive any such information, please contact us as set out below.

5. The information we keep about you

You have a right to request access to or correction of your personal information held by us. If you wish to access, correct or update any personal information we may hold about you, please contact us as set out below. However, we may charge for providing access to this information and we may refuse access where the Act allows us to do so.

6. Notifiable Data Breaches Scheme

In the event of any loss, or unauthorised access or disclosure of your personal information that is likely to result in serious harm to you, we will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with the Privacy Act 1988.

7. Complaints process

If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe that we have not complied with this Privacy Policy or the Act, please contact us as set out below. The Privacy & Compliance Officer will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. When contacting us, please provide as much detail as possible in relation to the query, issue or complaint.

We will take any privacy complaint seriously. We will aim to resolve any such complaint in a timely and efficient manner, and our target response time is 28 days. We request that you cooperate with us during this process and provide us with relevant information we may require.

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint with the Office of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia):

Office of the Australian Information Commissioner (OAIC)

Complaints must be made in writing

8. Storage and security of your personal information

We will take reasonable steps to keep any personal information we hold about you secure. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to your personal information. Please notify us immediately if you become aware of any breach of security.

We may store your files in hard copy or electronically in our ordinary IT systems. These may include Australian-based cloud servers or the servers of third parties within Australia.

When we have disclosed your personal information to third parties, as described in section 3 of this Privacy Policy, your files may be stored by or transferred to entities located outside of Australia. The storage or transfer of your personal information by these third parties will be subject to confidentiality provisions as we deem appropriate.

We implement a range of physical and electronic security measures to protect the personal information that we hold, including:

• card and key-restricted access to offices;
• mandatory password protection on all computers;
• hardware encryption on desktops, laptops and portable storage devices;
• secure hard copy document, electronic storage media and hardware disposal procedures;
• firewall and antivirus/malware software; and
• systems and application access controls implemented to restrict access to information (on a need to know basis).

Staff receive periodic training on security issues, to foster a security aware culture.

9. Changes to this Privacy Policy

The date of this Privacy Policy is set out below. We may change this Privacy Policy at our discretion. By continuing to use the Site, or otherwise continuing to deal with us, you accept this Privacy Policy as it applies from time to time.

10. Contact us

Please direct any privacy issues or queries, addressed to Privacy & Compliance Officer at info@pklawyers.com.au

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