Purpose and Scope
This Policy sets out how and why each entity within the Halo Group (we, us, our, Halo Group) deals with your Personal Information. It also sets out your rights in relation to our handling of your Personal Information.
The “Halo Group” means the following entities:
- Halo Group Holdings Pty Ltd ABN 81 621 014 515
- Hamilton Locke Pty Ltd ABN 54 621 047 247
- Emerson Operations Pty Ltd ABN 87 627 818 277
- Source Legal Pty Ltd ABN 56 150 668 554
- MacMillan Trade Marks Pty Ltd ABN 40 123 822 140
- The Fold Legal Pty Ltd ABN 13 106 708 856
- The Fold Compliance Pty Ltd ABN 72 100 974 294
This Policy applies between you and the relevant Halo Group entity when it deals with your Personal Information.
We provide tailored professional legal advice and related services. This means that, generally, you will have to identify yourself when dealing with us. However, there may be some circumstances, such as when you use our Website, that you may be able to deal with us anonymously or through a pseudonym. You do not have to provide us with your Personal Information, but this may mean we cannot provide our services or assistance to you.
Halo Group is not responsible for the privacy practices of third-party websites or plugins that you may be directed to through our Website. We therefore encourage you to review the relevant privacy notices of those third parties. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites, products or services.
We may change this Policy from time to time by updating this page.
“Personal information” is information or an opinion about an identified individual, or about an individual who is reasonably identifiable.
“Sensitive information” is a sub-set of Personal Information and includes information about an individual’s racial or ethnic origin; political, religious or philosophical beliefs; political, trade or professional memberships; sexual orientation or practices; criminal record; and information about your health, disability and health services you receive.
“Website” means each of:
2. What types of information do we collect?
The types of Personal Information we collect from you or about you depend on your relationship with us.
If you are a client, a prospective client, or a representative of them, we may collect Personal Information about you or them related to the matter for which we have been engaged. This Personal Information may include:
- your name, address, phone, fax and mobile numbers and email address;
- job title, organisation and/or company name;
- identification documents such as your passport or other official photographic document to verify your identity;
- financial details, such as credit/debit card information;
- the history of, and your relationship with others involved in, the matter; and
- other relevant Personal Information or Sensitive information, depending on the nature of the matter.
If you are a service provider, we may collect Personal Information such as:
- your name, address, phone, fax and mobile numbers and email address;
- your job title, job history, organisation or company name; and
- financial details such as your bank account to make payments to you.
This includes where you are providing services directly to us (such as IT service providers and marketing firms) or on behalf of our clients (such as barristers, experts, valuers, accountants and tax advisers).
If you are another party in respect of one of our client’s matters, or if you represent such a party, we may collect Personal Information about you in the course of the matter. The type of this information will depend on the nature of the matter, but is likely to include:
- your name and possibly contact details; and
- the history of, and your relationship with others involved in, the matter.
Current and prospective employees
We may collect and use your Personal Information when you apply for a job with us and during the course of your employment. We may receive information directly from you when you complete an online job application or through an external party such as a recruitment agency. The information collected may include:
- your resume, covering letter and academic transcript;
- information provided on your application form, including name, address, telephone number, personal email address, education level, tertiary institution, language skills, jurisdictions you are qualified to practice in and any other background information relating to your right to work in Australia; and
- information provided to us during an interview.
Information we collect automatically
Like most Website operators, we automatically collect information from you and your devices when you access our Website. When you visit our Website, the information automatically collected may include:
- your Internet Protocol (IP) address;
- browser type;
- language preference;
- referring site; and
- the date and time of each visitor request.
Our purpose in collecting non-personally identifying information is to better understand how visitors use the Website.
3. How we collect Personal Information
We aim to collect Personal Information only directly from you unless it is unreasonable or impracticable for us to do so. For example, we collect Personal Information from:
- correspondence that you submit to us;
- meetings, calls and interviews with us;
- the instructions you provide to us;
- submissions you make on our Website; and
- registration and feedback forms you may fill in for our marketing-related activities and events.
In some instances we may receive Personal Information about you from the following sources:
- third parties, such as associated businesses, government agencies, local councils, referrers (such as other law firms, accountants, real estate agents, financial planners, insurers and business consultants);
- third parties (such as barristers, experts, and accountants) we engage to provide services in respect of your matter;
- our client, or your legal representatives, where you are another party involved in a matter;
- references you provide to us in the course of a job application;
- authorised third parties; and
- publicly available sources.
4. Purpose of collection
In addition to the specific purposes set out below, we collect, hold, use and disclose Personal Information from you or about you where:
- it is reasonably necessary for us to carry out our business functions and activities, and to provide our services such as legal advice;
- it is required or permitted by law;
- we otherwise have your specific consent; and/or
- for a purpose related to the purpose for which it was collected where you would reasonably expect us to do so.
We will disclose your Personal Information as necessary amongst the other entities within the Halo Group and to our service providers for purposes including conflict checks and the provision of our services.
Our business works closely with other businesses, such as government departments and agencies, other law firms, barristers, accountants, real estate agents, financial planners, insurers, local business and industry networks, business and industry alliances, auditors and other consultants. We routinely disclose your Personal Information to these third parties where it is reasonably necessary for them to assist us to provide our legal services to you, or to enable them to provide related service offerings that you have requested. We may also disclose your Personal Information to banking institutions (to verify and process your payments).
Communications with you
Where we have your consent, we may use and disclose your Personal Information to send you marketing material and/or material specifically tailored to the industry you operate in, the services you or your organisation have engaged us to provide, or the services you or your organisation are or may be interested in.
Where required by applicable law, we will obtain your consent before sending any marketing communications to you. You may withdraw your consent to the use of your Personal Information for marketing purposes at any time by notifying us. Opt-out procedures are also included in our communications.
We will never provide your Personal Information to third parties for marketing purposes without receiving your consent.
In respect of other parties in a matter, we will use your Personal Information to the extent necessary to provide our services.
Under the Privacy Act, Personal Information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship.
Personal Information about prospective employees will be used to evaluate applications to work within the Halo Group.
5. How we hold, store and protect Personal Information
Your Personal Information is held and stored on paper, by electronic means or both. We have physical, electronic and procedural safeguards in place for Personal Information and take reasonable steps to ensure that your Personal Information is protected from misuse, interference, loss and unauthorised access, modification and disclosure.
However, data protection measures are never completely secure and despite the measures we have implemented, we cannot guarantee the security of your Personal Information. You should notify us as soon as possible if you become aware of any security breaches. Any submission of Personal Information is at your own risk.
What are cookies?
You can choose if and how cookies will be accepted by configuring your preferences and options in your browser. However, if you decide not to display cookies you may not experience optimum performance of our Website.
7. Destruction and de-identification
We will retain your Personal Information for any of our business functions, for any other lawful purpose and as required by law. For example, we retain records of client names and the names of opposing parties indefinitely to avoid conflicts of interest.
We destroy or permanently de-identify Personal Information when it is no longer needed as follows:
- paper records are either destroyed securely or returned to you and/or relevant third parties; and
- electronic records may be archived to alternative storage (subject to the procedural safeguards described above) or destroyed when no longer needed.
8. Overseas disclosure
In the course of doing business with you, we may disclose some of your Personal Information to our service providers some of whom may be based overseas, including in India and the Philippines.
Where your matter is international in nature, we may need to disclose your Personal Information to third parties based overseas. You agree that APP 8.1 (which requires entities to take reasonable steps to ensure overseas recipients will not breach the APP’s) will not apply to such disclosures. You warrant that you have obtained the same consent from each individual whose Personal Information you provide to us.
9. Requests for access and correction
Subject to our legal professional privilege obligations, you have a right to request access to, or to correct, your Personal Information we hold. These rights may arise under the Privacy Act, your retainer with us, the relevant legal profession legislation or the common law.
We take reasonable steps to ensure that your Personal Information we hold is accurate, complete and up to date. However, we encourage you to tell us if your Personal Information changes or if you believe or suspect it may not be correct.
In most cases, we will comply with such requests. If, for whatever reason, we do not, we will give you written reasons why. For further information, please contact us.
10. Complaints and concerns
Please contact us at the address below if you would like any further information, or have any concerns or complaints, about our practices in relation to the Privacy Act, the APPs, and any alleged breach of this Policy. We will promptly acknowledge your concern, and will separately respond as soon as possible.
Our Privacy Officer can be contacted to discuss any questions, concerns or complaints relating to this Policy or how we handle your Personal Information. Please contact:
Level 42/264 George Street
Sydney NSW 2000
P: (02) 8072 8271
This Policy was last updated on 20 August 2021