At Highbury Partnership Pty Ltd (ABN 14 162 169 502) (Highbury), together with our related bodies corporate, we are committed to protecting your privacy in accordance the Privacy Act 1988 (Cth) (Privacy Act). This Privacy Policy sets out our policy on the collection, handling, storing, using, and disclosing of personal information. It also deals with how you can complain about a breach of the privacy laws, access the personal information we hold about you and have that information corrected (where necessary). We are subject to the Privacy Act and a range of other laws which protect your privacy, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act). Highbury provides certain professional services that are “designated services” under the AML/CTF Act, which means we are a “reporting entity” for the purposes of that Act and have additional obligations regarding the collection, verification, use, disclosure and retention of personal information as described in this Policy. This Privacy Policy is not intended to limit our obligations or permitted handling of personal information under any laws. For example, we may rely on exemptions under those laws including the exemption in relation to employee records under the Privacy Act.
Collecting And Holding Personal Information
We collect personal information about you in certain circumstances, such as where you contact us or where you become a client or customer of Highbury. The types of personal information we collect may include your name, contact details, organisation, title, interests, information in forms you submit and enquiry/complaint details. Where we provide you with a professional service that is a “designated service” under the AML/CTF Act, we are also required to collect and verify “know your customer” (KYC) information, which may include your full name, date of birth, residential address, occupation, source of funds and wealth, identification documents (such as a passport or driver’s licence) and, where you are acting on behalf of an entity, information about that entity’s beneficial owners, related individuals and any person acting on your behalf and their authority to act. We also collect personal information about your dealings with us, including any telephone, email or online communications. We may monitor and record your communications with us (including email and telephone) and operate video and audio surveillance devices in our premises for purposes including security, dispute resolution and training. We collect personal information from you directly and from other sources including our related companies, information service providers, identity verification service providers, public information (including government and credit reporting databases) and the parties with which we exchange information as described below.
Using Your Personal Information
We use your personal information to help us to provide, administer, develop, improve and personalise our products and services, verify your identity and personal information, maintain and update our records, conduct product and market research, communicate and manage our relationship with you, process payments and refunds, protect our lawful interests and deal with your enquiries and concerns.
We may also use your personal information in connection with acquisitions or potential acquisitions of our business, suspected fraud, misconduct and unlawful activity and reasonable information requests from courts, government agencies and lawyers. Where we provide a designated service to you under the AML/CTF Act, we also use your personal information to comply with our obligations under that Act, including to verify your identity and, where relevant, the identity of any beneficial owners, to conduct initial and ongoing customer due diligence, to assess and manage money laundering and terrorism financing risk, to monitor transactions and to identify, investigate and report suspicious matters and other information to the Australian Transaction Reports and Analysis Centre (AUSTRAC) as required or authorised by law.
We may provide marketing communications to you by telephone, electronic messages (e.g. email), online (including websites and mobile apps) and other means on an ongoing basis, unless you opt out or we are subject to legal restrictions. Should you wish to opt out of receiving marketing communications, we will always give you the option of electing not to receive these communications and you can unsubscribe at any time by notifying us that you wish to do so.
We may be limited in our ability to do these things without your personal information. For example, we may not be able to deal with your enquiries or communicate with you. You can contact us without using your name or by using a pseudonym. However, we may need your name or contact details to respond to you.
Web And Mobile Data
We may use technology such as cookies, beacons, tags, scripts and tracking pixels to collect, store and use anonymous data about how you use our website/mobile technology. This includes your server address, the date and time of your visit, the pages and links accessed, the type of browser used and other information about your browsing activities. This data is used to increase functionality and can also enable us to display information and content that is tailored to our understanding of your interests. This information alone cannot be used to discover your identity.
Automated Decision-Making
Highbury does not use a computer program to make, or to do a thing that is substantially and directly related to making, a decision that could reasonably be expected to significantly affect your rights or interests (for example, a decision affecting your rights under a contract, or your access to a service), using your personal information.
Where we use an electronic identity verification service to assist us in verifying your identity for KYC and AML/CTF compliance purposes, this involves the automated matching of your identification information against reliable and independent data sources. This electronic verification is used only to verify your identity — it is not used to make any decision about whether to provide services to you. Any decision about whether to provide services to you is made by Highbury personnel.
Additional Information For Particular Situations
Job applicants
If you apply for a position with us, we may also collect information about your experience, character, qualifications, identification information and screening checks (including reference, background, directorship, health, financial probity, identity, eligibility to work, vocational suitability and criminal record checks). We collect, use and disclose your personal information to assess your application, conduct screening checks and consider and contact you about other positions. We may exchange your personal information with recruiters, screening check providers, academic institutions, health service providers, professional and trade associations, law enforcement agencies, referees and your current and previous employers. Without your personal information we may not be able to consider you for positions with us.
Staff and contractors
We may collect information related to your current or former employment or engagement including information about your recruitment, training, terms and conditions, emergency contact details, performance, conduct, use of our IT resources, union or professional/trade association membership, drug/alcohol tests, payroll matters, leave, disciplining, resignation, termination and taxation, banking and superannuation affairs. We are required or authorised to collect your personal information under various laws including the Fair Work Act, Superannuation Guarantee (Administration) Act and Taxation Administration Act.
We collect, use and disclose your personal information for purposes relating to your employment or engagement with us including staff management, training, disciplining, payroll, superannuation, health and safety, insurance (including workers compensation) and administration. We may exchange your personal information with your representatives (including unions) and our service providers including providers of training, payroll, superannuation, banking, staff benefits, surveillance and training services. Without your personal information we may not be able to effectively manage your employment or engagement. We may also collect, use and disclose your personal information as described in the ‘Job applicants’ section above.
Storing And Securing Personal Information
We hold personal information in physical and electronic form at our premises and with the assistance of service providers. We take reasonable steps to protect your Personal Information from unauthorised access, interference, disclosure, or destruction. We use secure encryption and follow industry best practices to safeguard your Personal Information. We store most information about you in computer systems, phones and databases (including cloud service providers) operated by either us or our related bodies corporate. Some information about you is recorded in paper files that we store securely. We are also required to take reasonable steps to destroy or de-identify personal information when no longer needed for any permitted purpose. Information we hold is kept for as long as reasonably necessary for the purpose for which it was collected or to comply with any applicable legal reporting or document retention requirements. For example, where we have collected personal information for the purposes of the AML/CTF Act, we are required to retain that information, and records of our related customer due diligence and risk assessments, for at least 7 years after the end of our business relationship with you or the completion of the relevant transaction.
If you are considering sending us any other personal information through our website or other electronic means, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email, standard HTTP). We are subject to legal requirements to protect the security of personal information once it comes into our possession.
Disclosing Information
Note that we do not sell, trade or rent your personal information to others. We may provide your information to others if we are required to do so by law or under some other unusual circumstances which the Privacy Act permits. We may disclose your personal information with our related bodies corporate, your representatives, the organisation you represent and our service providers that assist us with technology, website, delivery, legal, accounting, business consulting, auditing, customer contact, banking, payment, data processing, data analysis, information broking, research, investigation or archival services. Where we provide a designated service to you under the AML/CTF Act, we may also disclose your personal information to AUSTRAC and other government and regulatory bodies, identity verification service providers, and other reporting entities, as required or authorised under the AML/CTF Act.
We will not disclose your information to overseas recipients.
Access, Updating And Feedback
If you have any queries or concerns about privacy or wish to access or correct any personal information we may hold about you at any time, please contact our Privacy Officer at info@highburypartnership.com or by calling +61 2 8188 1151. We may need to verify your identity.
In the case of access and correction requests, please provide as much detail as you can about the particular information you seek, in order to help us correct, amend or delete this information. Note that we do not charge you for providing access to your personal information. We will provide our reasons if we deny any request for access to or correction of personal information. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.
We take your privacy concerns seriously. Where you express any concerns that we have interfered with your privacy, compliance with the Privacy Act, Australian Privacy Principles, or this Policy, we will respond as soon as reasonably practicable to let you know who will be handling your matter and when you can expect a further response.
For information about privacy generally, or if your concerns are not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.
Your Consent
By asking us to assist with your investment needs, you consent to the collection and use of the information provided for the purposes previously described.
Updating This Policy
This Privacy Policy was prepared on 18 September 2026. We may update it at any time. The new version of this Policy will be published at highburypartnership.com/privacy-policy.
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