Crichton & Co Legal (C&C) takes privacy seriously. We are committed to the protection of your personal data and the transparency of our privacy practices.
This policy explains how and why we collect, use hold and disclose your personal information.
‘Crichton & Co Legal’, ‘C&C’, ‘we’, ‘us’ and ‘our’ mean ANCLC Pty Ltd t/a Crichton & Co Legal ACN 629 274 862 of Level 3/223 Liverpool Street, Darlinghurst, NSW 2010.
WHAT IS PERSONAL INFORMATION?
Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.
WHAT PERSONAL INFORMATION DOES C&C COLLECT & HOLD?
C&C is a boutique corporate Australian law firm. The types of personal information that C&C collects will depend on the nature of your dealings with us. We may collect personal information from you when you:
instruct C&C to provide you with legal advice;
purchase or subscribe to a C&C online service;
subscribe to a C&C newsletter;
subscribe to our website;
attend a C&C seminar;
have business dealings with us; or
apply, or register your interest for, employment with C&C.
The personal information we will collect from you will usually include your name, title, address and e-mail address and contact numbers (telephone, mobile). If necessary, for the purposes of providing advice to you, or for providing you with other information (such as email updates), we may collect other personal information from you, such as the areas of our practice which you are interested in. However, we do not collect personal information that we do not need.
While we seek to minimise the personal information we collect, if you do not provide us with the personal information we request, we may not be able to provide you with the services and other assistance you seek.
Generally, we endeavour to collect personal information directly from the individuals concerned. However, if this is not practicable, we may collect personal information about individuals from third parties, including from publicly available sources or third party providers.
If you are one of C&C’s ‘business contacts’ (e.g. a contact person in one of our suppliers, or in a government agency or company with which we deal), we may collect basic business contact information from you (e.g. your name, title and work contact details) automatically using the details in your email signature.
C&C will not ask to collect sensitive information about you (such as details of your racial or ethnic origin, political affiliation, religious beliefs, sexual preferences, criminal convictions or health information) unless it is needed for the purposes of providing legal advice. In that case, we will only collect and use sensitive information with your consent, in accordance with applicable laws or in a de-identified aggregated manner.
HOW DOES C&C USE PERSONAL INFORMATION?
C&C’s policy is only to use personal information collected from business contacts for the business purpose for which it was collected.
We collect, hold and use your personal information so that we can:
verify your identity;
provide you with products and services, and manage our relationship with you;
develop new products and improve our services to you;
contact you, for example, to respond to your queries, to seek your feedback, or if we need to tell you something important;
effectively undertake administrative purposes including processing payment transactions, charging and billing;
engage and manage our consultants, contractors and sub-contractors;
undertake governance and compliance purposes including quality, conduct or risk management issues;
comply with our legal obligations and assist government and law enforcement agencies or regulators;
undertake various business transactions, collaborations or arrangements such as part of an acquisition, disposition, merger or de-merger of a business or entering a joint venture or referral arrangement.
We may collect information about how you access, use and interact with the C&C website or social media platforms. We do this by using a range of tools such as Google Analytics, Adobe Analytics and analytics embedded into our website. This information may include:
the location from which you have come to the site and the pages you have visited; and
technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system; and
search terms or referral sources which have lead you to our website.
We also collect personal information so that we can communicate new legal or firm developments, including advertising new products or services that we offer to our clients and to those people who have subscribed to our website, alert services or mailing lists.
If, at any time, you do not wish to receive these kinds of communications, please let us know using the contact details set out below.
HOW DOES C&C HANDLE PERSONAL INFORMATION OF JOB APPLICANTS?
C&C also collects personal information about, and from, individuals who apply for employment with C&C. The information we collect may include the applicant’s:
personal contact details and gender;
educational and employment history, and relevant qualifications and employment history;
eligibility to work in Australia; and
referees’ contact details.
We may collect this information directly from the job applicant or indirectly from a third party, including from a recruitment agency. If necessary, we will also collect information about applicants from referees and from professional social networking sites like LinkedIn, including in relation to the applicant’s performance.
C&C uses the personal information we collect about job applicants to assess their eligibility and suitability for employment with C&C. Generally, our assessment of applicants’ personal information will relate to a particular role. However, we may also retain and use applicants’ personal information to assess their suitability for other roles with C&C. We may disclose personal information to service providers that conduct background and eligibility checks on our behalf.
For information as to how an applicant may access and correct the personal information we hold about them, or make a privacy complaint, please see below.
WILL YOUR PERSONAL INFORMATION BE GIVEN TO ANYONE ELSE?
C&C does not sell, rent or trade personal information. Personal information may be disclosed outside of C&C in the circumstances described below:
DISCLOSURES TO EXTERNAL SERVICE PROVIDERS
C&C may disclose personal information to external service providers who provide services to you and help us operate our business. Examples of our external service providers include: third party data storage providers; IT and other software and systems providers; companies who provide photocopying and archiving services; advertising and marketing agencies who assist us with our campaigns and programs; referral agencies who provide us with specialist practitioners to support your matters; and research organisations and consultants who conduct research or provide legal services on our behalf. If C&C engages external service providers, C&C takes steps to ensure that those external service providers: take all reasonable steps to protect personal information about you; and are authorised only to use personal information that we provide to them for the limited purposes specified in our agreement with them.
Where C&C engages external information technology service providers, we ensure that, wherever possible, our data is stored within Australia. We may however disclose your personal information to recipients located outside Australia including, but not limited to, locations in the UK, New Zealand and USA.
DISCLOSURES PERMITTED OR REQUIRED BY LAW
Other than the scenarios above, C&C will only disclose personal information if disclosure is required by law, permitted under applicable laws, or with your express consent. C&C is also bound by professional obligations of confidentiality, including in relation to personal information.
SECURITY OF PERSONAL INFORMATION
C&C takes reasonable steps to ensure the security of your personal information. We store most information about you in computer systems and databases operated by either us or our external service providers. Some information about you is recorded in paper files that we store securely.
Our IT systems are password protected and we conduct regular audit and data integrity checks. We frequently update our anti-virus software in order to protect our systems (and the data contained in those systems) from computer viruses. In addition, all C&C consultants, contractors and employees are required, as a condition of engagement, to treat personal information held by C&C as confidential.
We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under any relevant laws.
ACCESS & CORRECTION
You have the right to:
seek access to your personal information handled by C&C;
ask us to update or correct your personal information when it is inaccurate, incomplete or out of date; and
opt-out of receiving direct marketing communications from us.
To provide you with access to your personal information held by us on our current records, C&C can provide you with a copy of the relevant personal information (ordinarily, an electronic print-out or a photocopy). C&C will not charge you for the cost of providing this type of access to these current records.
For legal and administrative reasons, C&C may also archive non-current records containing personal information, such as back up data files and offsite storage. Please note that if we do provide access to old records, we may charge you for the cost of providing such access.
If you are of the view that personal information about you is inaccurate or out of date, or if you have any other queries about access and correction, please contact our Privacy Officer using the contact details set out below.
Some of our websites and services may include functionality to enable information sharing via third party social media applications, such as LinkedIn, Instagram, Facebook and Twitter. These social media applications may collect and use information regarding your use of our websites. Any personal information that you provide via such social media applications may be collected and used by members of that social media application separate to us and are subject to the privacy policies of the relevant companies that provide the applications. We do not have control over, or responsibility for, those companies or their use of your information.
Any personal information that you provide on our social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.
THIRD PARTY WEBSITES
Sometimes our website contains links to other websites, for your convenience and information. When you access a website other than crichtonand.co, C&C is not responsible for the privacy practices of that site. We suggest that you review the privacy policies of each site you visit.
MAKING A COMPLAINT
If you wish to make a complaint about how C&C handles your personal information, please contact us setting out your complaint in writing, and forward it to our Privacy Officer, using the contact details below.
We will deal with all requests for access to personal information or complaints as quickly as possible and will endeavour to get back to you within a reasonable timeframe.
ADDITIONAL INFORMATION & HOW TO CONTACT C&C
a: Crichton & Co Legal, Level 3/223 Liverpool Street, Darlinghurst, NSW, 2010