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Privacy Policy

EE Pacific Australia Pty Ltd (ABN 29 146 613 514), trading as EE Accounting

Version 1.0 | Effective 1 November 2026

1. About this policy

EE Pacific Australia Pty Ltd, trading as EE Accounting (we, us, our), is a Chartered Accounting practice and registered tax agent based in Sydney. We respect your privacy and are committed to handling your personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs) and the Privacy (Tax File Number) Rule 2015.

This policy explains what personal information we collect, how we collect, hold, use and disclose it, how we protect it, and how you can access or correct it or make a complaint. It applies to our clients and their directors, shareholders, beneficial owners, trustees, beneficiaries, partners, employees and other associates, as well as to visitors to our website, prospective clients, suppliers and anyone else who deals with us.

We are a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) for certain services. The Privacy Act applies to all personal information we handle in connection with our AML/CTF obligations, and we apply the same standards to all personal information we hold.

2. The kinds of personal information we collect

The personal information we collect depends on the services we provide to you and may include:

  • name, date of birth, gender, residential and postal address, email address and telephone number;

  • identity documents and information, such as driver licence, passport, Medicare card, citizenship or visa details, and Director ID;

  • tax file numbers (TFNs), Australian Business Numbers and other government-issued identifiers;

  • financial information, including income, bank account details, investments, shareholdings, assets and liabilities, superannuation, insurance and loan arrangements;

  • employment, occupation and business information;

  • information about your spouse, dependants and other family members where relevant to your tax affairs;

  • information about the ownership and control of companies, trusts and other entities, including beneficial owners;

  • information required for customer due diligence under the AML/CTF Act, including whether you are a politically exposed person, whether you are subject to sanctions, and, where required, the source of your funds or wealth;

  • records of our communications and dealings with you; and

  • information about your use of our website (see section 13).

Sensitive information. We only collect sensitive information (such as health information relevant to a tax deduction, professional or trade association memberships, or information about criminal records revealed by sanctions or adverse media screening) where it is reasonably necessary for our services or legal obligations and you have consented, or where the collection is required or authorised by law.

Anonymity. You may contact us for general enquiries without identifying yourself. However, because of our obligations under tax and AML/CTF laws, we are generally unable to provide our services to you anonymously or using a pseudonym.

3. How we collect personal information

We collect personal information directly from you wherever practicable, including in meetings, by telephone, by email, through our client onboarding and engagement forms, through our accounting software, and through our website.

We may also collect personal information from third parties, including:

  • government agencies such as the Australian Taxation Office (ATO), the Australian Securities and Investments Commission (ASIC) and the Australian Business Register, including through the online services available to registered agents;

  • your previous accountant or tax agent, your bank, your financial adviser, your lawyer or other professional advisers, with your authority;

  • a related person or entity, such as a director, trustee or family member who provides information on your behalf;

  • public registers and information sources, such as the ASIC registers, the ABN Lookup, the Australian Sanctions Office Consolidated List and publicly available media; and

  • an accredited data recipient under the Consumer Data Right, where you have nominated us as your trusted adviser.

If you give us personal information about another person (for example, a co-director, beneficial owner, spouse or employee), you must make sure you are authorised to do so and that the person knows that you have given it to us and how they can access this policy.

4. Why we collect, use and disclose personal information

We collect, hold, use and disclose personal information to:

  • provide our accounting, taxation, business advisory, company secretarial and related services, including preparing and lodging returns, statements and forms with the ATO, ASIC and other bodies;

  • verify your identity and the identity of related persons, and meet our customer due diligence, ongoing monitoring, reporting and record-keeping obligations under the AML/CTF Act;

  • meet our obligations as a registered tax agent under the Tax Agent Services Act 2009 (Cth) and the Code of Professional Conduct, and our professional obligations as members of Chartered Accountants Australia and New Zealand (CA ANZ);

  • manage conflicts of interest;

  • manage our relationship with you, including communicating with you, invoicing and collecting fees;

  • send you updates and information about our services that may interest you (see section 12);

  • manage our business, including quality control, insurance, risk management and dealing with complaints; and

  • comply with other legal obligations and respond to lawful requests from regulators, courts and law enforcement agencies.

If you do not give us the information we request, we may not be able to provide some or all of our services to you.

5. Anti-money laundering and counter-terrorism financing

Some of our services, such as establishing companies and trusts, acting as company secretary, providing a registered office address and assisting with the transfer of shares or units, are designated services under the AML/CTF Act. Before we provide these services, we are required by law to collect and verify information about you and, where relevant, your beneficial owners and representatives.

For these purposes:

  • we may verify the information you provide against original documents and reliable and independent sources, including government databases and public registers;

  • we check whether you or related persons are politically exposed persons or are subject to targeted financial sanctions;

  • we may be required to report certain matters to the Australian Transaction Reports and Analysis Centre (AUSTRAC). The law prohibits us from telling you about some of these reports;

  • we keep records relating to our customer identification and due diligence for at least 7 years after our relationship with you ends, as required by the AML/CTF Act; and

  • if we are unable to complete these requirements, we cannot provide the relevant services to you.

We do not keep copies of identity documents unless we need them to demonstrate our compliance or another law requires us to. Where we do, we hold them securely and only for as long as required.

6. Tax file numbers

We only collect, use and disclose tax file numbers for purposes permitted by taxation, superannuation and other laws, such as lodging your returns. You are not legally required to give us your TFN, but we may be unable to lodge returns or deal with the ATO on your behalf without it. We store TFNs securely, restrict access to them, and do not use them to identify you for any other purpose. We follow the Privacy (Tax File Number) Rule 2015, including by securely destroying or de-identifying TFN information when we no longer need it for a lawful purpose.

7. Who we disclose personal information to

We only disclose personal information for the purposes described in this policy, with your consent, or where required or authorised by law. Depending on the services we provide, we may disclose personal information to:

  • the ATO, ASIC, AUSTRAC, the Tax Practitioners Board and other government agencies and regulators;

  • your other professional advisers (such as your lawyer, financial adviser or bank), at your request or with your consent;

  • your previous or future accountant or tax agent, at your request;

  • the service providers described in section 8, who help us run our practice;

  • CA ANZ, as part of its quality review program, and our professional indemnity insurers and professional advisers;

  • other parties involved in a transaction you have asked us to help with; and

  • a potential purchaser of our practice, on a confidential basis and only to the extent reasonably necessary.

We do not sell, rent or trade personal information, and we do not disclose personal information to third parties so that they can market their products or services to you.

8. Service providers and overseas disclosure

We use a small number of trusted cloud-based service providers to run our practice:

  • Microsoft 365 (Microsoft) – email, document storage (OneDrive and SharePoint) and office software;

  • Xero – accounting software and practice management, including electronic signing of documents; and

  • Claude (Anthropic) – artificial intelligence tools used as described in section 9.

These providers may store or process personal information on servers in Australia or overseas, including in the United States, and in other countries where they or their sub-processors operate. Before using a provider, we take reasonable steps to make sure it handles personal information securely and in a way that is consistent with the APPs, including by relying on its contractual privacy and data security commitments. Apart from these providers, we do not otherwise disclose your personal information to recipients overseas unless you ask us to (for example, to deal with your adviser or a tax authority in another country) or the law requires it.

9. Use of artificial intelligence

We use artificial intelligence (AI) tools to help us work efficiently, for example to read and summarise documents, draft correspondence and working papers, perform calculations and check our work. When we do so:

  • we never allow our AI providers to use your information to train their AI models. We only use AI services under business terms or settings that prohibit the provider from training its models on our data, and we will not change this without updating this policy;

  • every piece of advice and work we give you is reviewed and approved by a qualified accountant, who remains responsible for it;

  • we only give an AI tool the information it needs for the task; and

  • we protect the information in the same way as all other personal information we hold.

Automated decisions. We do not use computer programs, including AI, to make decisions that could reasonably be expected to significantly affect your rights or interests. In particular, decisions about whether to accept you as a client, your AML/CTF risk rating, and whether to report a matter to a regulator are made by a qualified person in our practice. If this changes, we will update this policy to describe the kinds of decisions and the kinds of personal information involved.

10. How we hold and protect personal information

We hold personal information mainly in electronic form, in secure cloud-based systems. We take reasonable steps to protect it from misuse, interference, loss, and unauthorised access, modification or disclosure, including:

  • multi-factor authentication and strong passwords on our systems, with access limited to people who need it;

  • encryption of data in transit and at rest by our cloud service providers;

  • secure storage and disposal of any paper records; and

  • privacy and information security training for our personnel.

No method of electronic transmission or storage is completely secure. If we suspect a data breach, we will act promptly to contain and assess it. If an eligible data breach occurs that is likely to result in serious harm, we will notify you and the Office of the Australian Information Commissioner (OAIC) as required by the Notifiable Data Breaches scheme.

11. How long we keep personal information

We keep personal information only for as long as we need it for the purposes described in this policy or as required by law. In general, we keep client records for 7 years after our engagement ends, to meet our obligations under taxation laws, the AML/CTF Act, the Corporations Act 2001 (Cth) and professional standards. When we no longer need personal information, we take reasonable steps to securely destroy or de-identify it.

12. Direct marketing

We may use your contact details to send you newsletters, tax updates or information about our services. You can opt out at any time by using the unsubscribe link in our emails or by contacting us. We will not disclose your personal information to anyone else for their marketing purposes.

13. Our website

You can generally visit our website without telling us who you are. If you contact us through the website, we collect the information you provide so that we can respond to you.

Our website may use cookies and analytics tools that collect general information about how visitors use the site, such as pages viewed, browser type and approximate location. This information does not usually identify you, and we use it to improve our website. You can set your browser to refuse cookies, although some parts of the site may not work properly.

Our website may contain links to other websites, such as those of the ATO, ASIC and the Tax Practitioners Board. We are not responsible for the privacy practices of those websites.

14. Children

Our website and services are not directed at children. We only collect personal information about children where it is necessary for our services, for example where a child is a dependant, a beneficiary of a trust or a taxpayer, and it is provided by a parent, guardian or other authorised person.

15. Accessing and correcting your personal information

You can ask for access to the personal information we hold about you, or ask us to correct it, by contacting us using the details in section 17. We will respond within 30 days. We do not charge for making a request, but we may charge a reasonable fee for the cost of providing access, which we will tell you about in advance.

We may refuse access in the circumstances permitted by the Privacy Act, for example where giving access would unreasonably affect the privacy of others, would be unlawful, or would be likely to prejudice an investigation. In particular, the AML/CTF Act prohibits us from disclosing information about certain reports made to AUSTRAC. If we refuse access or correction, we will tell you why in writing and how you can complain.

Please tell us promptly if any of your details change, so that the information we hold is accurate, up to date and complete.

16. Complaints

If you have a concern about how we have handled your personal information, please contact our Privacy Officer in writing using the details in section 17, describing your concern. We will acknowledge your complaint promptly, investigate it and aim to give you a written response within 30 days.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner:

  • Website: www.oaic.gov.au

  • Phone: 1300 363 992

  • Post: GPO Box 5288, Sydney NSW 2001

If your complaint relates to the tax agent services we provide, you may also complain to the Tax Practitioners Board at www.tpb.gov.au/complaints.

17. Contact us

Privacy Officer

EE Pacific Australia Pty Ltd (trading as EE Accounting)

Email: admin@eeaccounting.com.au

18. Changes to this policy

We may update this policy from time to time, for example to reflect changes in the law, our services or the technology we use. The current version is always available on our website at www.eeaccounting.com.au/privacy-policy, and you can ask us for a free copy at any time.

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