Privacy Policy

PRIVACY NOTICE issued by Strategico Limited

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1. Introduction

The Privacy Act 2020 imposes certain legal obligations in connection with the processing of personal data.

The Strategico Group is a franchise operating in New Zealand. Any reference to “We” or “Strategico” in this

document refers to the franchisor and/or to any of the franchisees.

Strategico is a data controller within the meaning of the Act, and we process personal data. The group’s contact

details are as follows: privacy@strategico.nz

We may amend this privacy notice from time to time. If we do so, we will supply you with and/or otherwise make

available to you a copy of the amended privacy notice.

Where we act as a data processor on behalf of a data controller (for example, when processing payroll), we provide

an additional schedule setting out required information as part of that agreement. That additional schedule should

be read in conjunction with this privacy notice.

2. The purposes for which we intend to process personal data

We intend to process personal data for the following purposes:

 to enable us to supply professional services to our clients

 to act as Tax Agent for our clients with the IRD if applicable

 to fulfil our obligations under relevant laws in force from time to time (eg the Anti-Money Laundering and

Countering Financing of Terrorism Act 2009 (AML/CFT Act))

 to comply with professional obligations to which we are subject as a member of an accounting body

 to use in the investigation and/or defense of potential complaints, disciplinary proceedings and legal proceedings

 to contact our clients about other services we provide which may be of interest to you if you have consented to us

doing so

 providing our clients and prospective clients with information about us and our range of services that we think will

be of interest. This includes industry updates and insights, other services that may be relevant and invites to events;

 for general management and reporting purposes, such as invoicing and account management;

 to comply with our obligations under the Strategico franchise agreement;

 for recruitment purposes;

 for purposes related to the employment of our personnel and providing internal services to our staff;

 security, quality and risk management activities.

3. The legal basis for our intended processing of personal data

Our intended processing of personal data has the following legal base:

 At the time you instructed us to act, you gave consent to our processing your personal data for the purposes

included in your Engagement Letter and/or signed proposal(s).

 The processing is necessary for the performance of our contract with you.

 The processing is necessary for compliance with legal obligations to which we are subject (eg AML/CFT Act).

 The processing is necessary for the purposes of the following legitimate interests which we may pursue: eg

investigating/defending legal claims.

It is a requirement of our contract with you that you provide us with the personal data that we request. If you do not

provide the information that we request, we may not be able to provide professional services to you. If this is the case,

we will not be able to commence acting or will need to cease to act.

4. Disclosure of personal information

Strategico does not disclose personal information unless:

 disclosure is permitted by this policy;

 we believe it is necessary to provide you with a product or service which you have requested (or, in the case of a

partner, employee or contractor of Strategico, it is necessary for maintaining, or is related to, your role at Strategico);

 to protect the rights, property or personal safety of any member of the public or a customer of Strategico or the

interests of Strategico;

 some or all of the assets or operations of Strategico are or may be transferred to another party as part of the sale

of some or all of Strategico's business;

 you give your consent; or

 such disclosure is otherwise required or permitted by law, regulation, rule or professional standard.

We may share your personal data with:

 Companies Register, Charity regulators and IRD

 any third parties with whom you require or permit us to correspond

 any member of the Strategico Group

 subcontractors

 an alternate appointed by us in the event of incapacity or death

 professional indemnity insurers

 our professional body (e.g. ACCA, CAANZ, CIMA, CPA)

 any external party in relation to practice assurance and/or the requirements of the Anti-Money Laundering and

Countering Financing of Terrorism Act 2009 (AML/CFT Act) (or any similar legislation)

 Accident Compensation Fund (ACC)

 our professional advisers, for example, law firms, as necessary to establish, exercise or defend our legal rights and

obtain advice in connection with the running of our business;

 third party contractors, subcontractors, and/or their subsidiaries and affiliates (for example independent contractors

and consultants, travel service providers, mail houses, off-site security storage providers, information technology

providers, event managers, credit managers, debt collecting agencies, providers of identity management, website

hosting and management, data analysis, data backup, security and cloud storage services);

 others when explicitly requested by you;

 other when required to deliver publications or reference materials requested by you;

If the law allows or requires us to do so, we may share your personal data with:

 the police and law enforcement agencies

 courts and tribunals

 any other relevant office or agency or similar

We may need to share your personal data with the third parties identified above in order to comply with our legal

obligations, including our legal obligations to you. If you ask us not to share your personal data with such third parties,

we may need to cease to act.

5. Retention of personal data

When acting as a data controller and in accordance with recognised good practice within the tax and accountancy

sector, we will retain all of our records relating to you as follows:

 Where tax returns have been prepared, it is our policy to retain information for seven years from the end of the tax

year to which the information relates.

 Where ad hoc advisory work has been undertaken, it is our policy to retain information for seven years from the

date the business relationship ceased.

 Where we have an ongoing client relationship, data that is needed for more than one year’s tax compliance (e.g.

capital investments and fixed assets) is retained throughout the period of the relationship, but will be deleted seven

years after the end of the business relationship unless you as our client ask us to retain it for a longer period.

Our contractual terms provide for the destruction of documents after seven years and therefore agreement to the

contractual terms is taken as agreement to the retention of records for this period, and to their destruction

thereafter.

You are responsible for retaining information that we send to you (including details of capital investments and fixed

assets and claims and elections submitted), and this will be supplied in the form agreed between us. Documents

and records relevant to your tax affairs are required by law to be retained by you as follows:

 seven years from the end of the accounting period.

Where we act as a data processor as defined in Privacy Act 2020, we will delete or return all personal data to the

data controller as agreed with the controller at the termination of the agreement.

6. Access to information

We will provide access to personal information upon request by an individual, except in the limited circumstances

in which it is permitted for us to withhold this information.

When you make a request to access personal information, we will require you to provide some form of identification

(such as driver’s licence or passport and IRD number) so we can verify that you are the person to whom the

information relates. In some cases we may also request an administrative fee to cover the cost of access.

If at any time you want to know what personal information we hold about you, you may contact us by emailing us

at privacy@strategico.nz

7. Residents in the European Economic Area

If you are a resident in the European Economic Area, you have a right to request access to your personal data that

we hold. Such requests are known as ‘subject access requests’ (SARs).

Please provide all SARs in writing marked for the attention of Francoise Le Marrec.

To help us provide the information you want and deal with your request more quickly, you should include enough

details to enable us to verify your identity and locate the relevant information. For example, you should tell us:

 your date of birth

 previous or other name(s) you have used

 your previous addresses in the past five years

 personal reference number(s) that we may have given you, for example your IRD number

 what type of information you want to know.

If you do not have an IRD number, you must send a copy of:

 the back page of your passport or a copy of your driving licence and

 a recent utility bill.

We are required to comply with a SAR promptly and in any event within one month of receipt. There are, however,

some circumstances in which the law allows us to refuse to provide access to personal data in response to a SAR

(eg if you have previously made a similar request and there has been little or no change to the data since we

complied with the original request).

We will not charge you for dealing with a SAR.

You can ask someone else to request information on your behalf – for example, a friend, relative or solicitor. We

must have your authority to respond to a SAR made on your behalf. You can provide such authority by signing a

letter that states that you authorise the person concerned to write to us for information about you and/or receive

our reply.

Where you are a data controller and we act for you as a data processor (eg by processing payroll), we will assist

you with SARs on the same basis as is set out above.

7.1 Putting things right (the right to rectification)

You have a right to obtain the rectification of any inaccurate personal data concerning you that we hold. You also

have a right to have any incomplete personal data that we hold about you completed. Should you become aware

that any personal data that we hold about you is inaccurate and/or incomplete, please inform us immediately so

we can correct and/or complete it.

7.2 Deleting your records (the right to erasure)

In certain circumstances, you have a right to have the personal data that we hold about you erased. If you would

like your personal data to be erased, please inform us immediately and we will consider your request. In certain

circumstances, we have the right to refuse to comply with a request for erasure. If applicable, we will supply you

with the reasons for refusing your request.

7.3 The right to restrict processing and the right to object

In certain circumstances, you have the right to ‘block’ or suppress the processing of personal data or to object to

the processing of that information. Please inform us immediately if you want us to cease to process your information

or you object to processing so that we can consider what action, if any, is appropriate.

7.4 Obtaining and reusing personal data (the right to data portability)

You have the right to obtain personal information we hold about you, in a structured, electronic format, and to

transmit such data to another data controller, where this is (a) personal information which you have provided to us,

and (b) if we are processing that data on the basis of your consent or to perform a contract with you.

7.5 Withdrawal of consent

Where you have consented to our processing of your personal data, you have the right to withdraw that consent

at any time. Please inform us immediately if you wish to withdraw your consent.

Please note:

 the withdrawal of consent does not affect the lawfulness of earlier processing

 if you withdraw your consent, we may not be able to continue to provide services to you

 even if you withdraw your consent, it may remain lawful for us to process your data on another legal basis (eg

because we have a legal obligation to continue to process your data).

8. Complaints

If you have requested details of the information we hold about you and you are not happy with our response, or

you think we have not complied with the Privacy Act 2020 in some other way, you can complain to us. Please send

any complaints to privacy@strategico.nz

If you are not happy with our response, you may make a complaint to the Office of the Privacy Commissioner

(https://www.privacy.org.nz/about-us/contact/).

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