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Privacy policy

Wealthcierge Pty Ltd trading as Stewart Private Accounting

Effective 2 October 2026

1. About this policy

We respect the privacy and confidentiality of information entrusted to us. This policy explains how we collect, hold, use and disclose personal information when providing accounting, taxation, bookkeeping, SMSF compliance and business advisory services, responding to enquiries and operating our website.

Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable. We have adopted the Australian Privacy Principles in the Privacy Act 1988 (Cth) as standards for handling personal information. We also observe applicable tax file number protections and our professional duties of client confidentiality. This policy does not replace your engagement terms or any separate authority or consent we need to obtain from you.

You can read more about Australian privacy requirements at the Office of the Australian Information Commissioner (OAIC).

2. Information we collect and hold

The information needed depends on your enquiry and the services you engage us to provide. It may include:

  • your name, contact details, date of birth and information needed to verify your identity;
  • tax file numbers and other identifiers where lawfully collected and relevant to the service;
  • income, expenses, assets, liabilities, bank details, tax returns, financial statements and supporting records;
  • business, company, trust and superannuation information, including relevant director, trustee, shareholder, beneficiary and member details;
  • employee and payroll information when we provide services to an employer;
  • relevant information about family members, dependants or other people involved in your affairs;
  • communications, instructions, authorities, engagement records and information about payments for our services; and
  • website enquiry details and technical or usage information described in section 7.

We seek information reasonably necessary for the relevant purpose. Financial information is highly confidential, but is not automatically “sensitive information” as defined by the Privacy Act. If we need sensitive information, such as relevant health information, we collect it with consent where required and only where reasonably necessary, unless a legal exception applies.

3. How we collect information

We generally collect information directly from you through meetings, telephone calls, email, questionnaires, website enquiries, documents and our client portal. Where appropriate and lawful, we may also collect information from your authorised representative, previous accountant, other advisers, government agencies, public registers and records you authorise us to access.

Where information comes from another person, we take reasonable steps to make you aware of the collection as required. If you provide information about another person, please ensure you are authorised to provide it and, where appropriate, make them aware of this policy. This does not remove our own privacy obligations.

We explain relevant collection purposes and any legal requirements at or before collection, or as soon as practicable afterwards, as required. If necessary information is not provided, we may be unable to accept an engagement, complete work, verify identity or meet relevant obligations. You can make a general enquiry anonymously or using a pseudonym where practical; client engagements generally require identification.

4. Why we use information

We use personal information to respond to enquiries, provide the services you engage us for, prepare and lodge authorised returns and reports, communicate advice, administer engagements, issue invoices, maintain records, address complaints and meet legal and professional obligations.

We use or disclose information for a secondary purpose only where permitted, including where you consent, where you would reasonably expect a related use or disclosure (directly related for sensitive information), or where a legal exception applies. Marketing is addressed separately in section 7.

5. Tax file numbers

We collect and handle TFN information only as permitted by taxation, superannuation or other applicable law, including the Taxation Administration Act 1953 (Cth) and the Privacy (Tax File Number) Rule 2015. Access is limited to people who need it for the permitted purpose. We do not use TFNs for marketing or as our general client identifier.

When requesting your TFN, we explain the relevant legal authority, purpose and consequences of not providing it. Quoting a TFN is voluntary and refusing is not an offence, although it may affect our ability to complete relevant tax or superannuation work. Please use the secure transfer method we nominate for TFNs and identity records, rather than a general website enquiry form.

We take reasonable steps to securely destroy or permanently de-identify individual TFN information when it is no longer needed for a lawful purpose and retention is not required by law.

6. Disclosure, service providers and overseas handling

Depending on the engagement and applicable authority, recipients may include:

  • the ATO, ASIC and other regulators or government bodies for authorised lodgments or lawful requirements;
  • your authorised representatives, advisers and relevant auditors;
  • service providers, including Xero for accounting services, Microsoft Outlook for email and Microsoft OneDrive for client document storage, together with providers supporting tax preparation, practice management, hosting, backups, client portals and IT support;
  • subcontractors in India and Vietnam who assist with our professional work and may access relevant client information; and
  • other recipients you authorise, or recipients to whom we have a legal duty to disclose.

We protect client confidentiality and obtain your permission before disclosing information about your affairs to a third party unless we have a legal duty to do so. Relevant arrangements may be explained in an engagement letter or a separate authority. Publishing this policy does not, by itself, supply that permission.

We use subcontractors located in India and Vietnam, so information relevant to their work may be disclosed to or accessed by them in those countries. Our cloud, AI and website providers may also handle information overseas, including in the United States and New Zealand, depending on the services, support arrangements and account configuration. For example, Xero identifies overseas group companies and subprocessors; Microsoft and OpenAI operate international services. This does not mean every record is stored in every country listed.

Provider locations and subprocessors can change. Information about these arrangements is available in the Xero subprocessor information, Microsoft privacy information and OpenAI business data privacy information. Contact us for the arrangements relevant to your engagement. We remain responsible for complying with our own privacy and confidentiality obligations.

Where overseas disclosure occurs, we take the steps required by applicable privacy law and our confidentiality obligations, including obtaining any necessary authority and assessing appropriate safeguards. Please contact us if you would like information about the providers or overseas arrangements relevant to your engagement.

7. Website technology and marketing

Our website uses cookies and third-party technologies for website operation, security, enquiries, usage measurement and advertising measurement. Technologies present on the website include Meta Pixel, Google Tag Manager, HubSpot and ClickCease. Depending on the tool and its configuration, information handled may include IP address, device and browser details, pages visited, referring links, interactions and information you submit through an enquiry form. Google Tag Manager manages tags; the data collected depends on the tags configured within it.

Third-party providers may receive information when their technology loads or when you interact with website features. Overseas handling is addressed in section 6. External sites, embedded content and our client portal may have their own privacy information; please review it when using those services.

You can manage cookies through your browser and use applicable advertising settings offered by third-party platforms. Restricting cookies may affect some website functions. You can also contact us to request that we stop using or disclosing your personal information for direct marketing. We will action these requests as required by applicable law. We provide unsubscribe options in marketing communications where required. Opting out of marketing does not stop necessary communications about your engagement.

Please do not submit TFNs, identity documents or detailed private financial records through a general website enquiry form. Contact us for the appropriate transfer method.

8. Artificial intelligence and automated tools

We use ChatGPT, provided by OpenAI, for tax research and reviewing tax work. In reviewing work, we may submit relevant client information, including identifiable information, tax and financial records and supporting documents. Information submitted to ChatGPT is disclosed to OpenAI for processing and may be handled overseas as described in section 6.

We limit information submitted to what is reasonably necessary for the task, and remove identifying details where practical. TFNs remain subject to the restrictions in section 5 and must not be submitted merely because an AI tool requests them. We remain responsible for checking AI-generated research and review outputs used in our professional services; these tools assist our work and do not replace professional judgement.

Provider handling, access and retention depend on the service, contractual terms and account settings. We assess those arrangements when using AI tools with personal information. You can contact our Privacy Officer for information about AI use relevant to your engagement.

Any use of personal information with automated tools remains subject to our privacy and confidentiality obligations and any required client authority. This policy does not authorise unrestricted disclosure of client information to an AI provider.

9. Security and retention

We take reasonable technical and organisational steps to protect personal information against misuse, interference, loss and unauthorised access, modification or disclosure. We limit access according to work requirements and use appropriate safeguards for the information and systems involved. No electronic communication or storage method can be guaranteed completely secure.

We retain information for the period needed to provide services and meet legal, professional, record-keeping and legitimate dispute-management requirements. Most client engagement records are retained for at least seven years, consistent with our existing record-retention practice. The applicable period depends on the record type and the relevant legal and professional requirements. Please contact us for the retention arrangements applying to a particular record. Some records may need longer retention; other information may be removed earlier when no longer needed. TFN information is subject to the specific protections in section 5.

When information is no longer needed for a purpose for which we may lawfully use or disclose it, and retention is not required by law, we take reasonable steps to destroy or permanently de-identify it.

10. Access, correction and data quality

You can request access to personal information we hold about you, or ask us to correct inaccurate, out-of-date, incomplete, irrelevant or misleading information. Contact details are in section 12. Email is helpful, but you do not have to use a particular form or make a written request. We may ask for reasonable evidence of identity or authority to protect your information.

We respond within a reasonable period and generally aim to respond within 30 days. If more time is needed, we explain the reason and expected timing. There is no fee to make an access or correction request, or to correct information. A reasonable, non-excessive charge may apply to providing access; we explain any proposed charge in advance.

Access or correction may be refused where law permits. If we refuse, we provide written reasons unless unreasonable to do so, and explain available complaint options. If we refuse a correction, you may ask us to associate a statement of your disagreement with the information. Where required, we take reasonable steps to notify relevant recipients of a correction on your request.

We take reasonable steps to maintain the quality of information used in our work. Please tell us when your circumstances or contact details change.

11. Privacy incidents

If a privacy or security incident occurs, we take reasonable steps to contain it, assess its impact and respond. Where the law requires notification, we notify affected individuals and the OAIC as required. The Notifiable Data Breaches scheme can apply to individual TFN information even where a small business exemption otherwise applies.

12. Enquiries and complaints

Please direct privacy enquiries, access or correction requests and complaints to:

Privacy Officer — Stewart Private Accounting
Wealthcierge Pty Ltd
Level 1, 9 The Esplanade, Perth WA 6000
Email: info@stewartprivate.com.au
Telephone: (08) 6454 0235

Please explain your concern and the outcome you are seeking. We acknowledge complaints, investigate the relevant circumstances and aim to provide a written response within 30 days. If more time is needed, we explain why and keep you informed. There is no charge for making a privacy complaint.

If you are not satisfied with our response, or have not received a response within 30 days, you may contact the OAIC about matters within its jurisdiction. See OAIC privacy complaints or telephone 1300 363 992.

13. Updates to this policy

We may update this policy as our services, technology or obligations change. The current version is available on our website, with its effective date. You can request a copy by contacting us.