Dolman Bateman Chartered Accountants
Privacy Policy
Version 2.0. Effective 10th September 2026.

1. About this policy

Dolman Bateman & Co Pty Ltd (ACN 052 851 019, ABN 88 052 851 019), trading as Dolman Bateman Chartered Accountants and DB Forensic ("we", "us", "our"), respects your privacy and is committed to protecting the personal information we hold about you.

This policy explains what personal information we collect, why we collect it, how we hold and protect it, who we disclose it to, and how you can access it, correct it or complain about the way we have handled it.

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We also comply with the Privacy (Tax File Number) Rule 2015 and the confidentiality obligations imposed on us by the Tax Agent Services Act 2009 and by APES 110 Code of Ethics for Professional Accountants.

This policy is available free of charge on our website. We will provide it in an alternative format on request.

2. Anonymity and pseudonymity

You may deal with us anonymously or under a pseudonym for general enquiries. We cannot provide taxation, accounting, forensic or advisory services anonymously, because we are required by law to identify our clients and to lodge documents in your correct legal name.

3. The personal information we collect

The information we collect depends on the services we provide to you. It may include:

Identity and contact information Name, previous names, residential and postal address, email address, telephone numbers, date of birth, place of birth, and copies of identification documents such as a passport, driver licence or Medicare card.

Government identifiers Tax file numbers, Australian Business Numbers, Australian Company Numbers, superannuation fund numbers and ATO client identifiers.

Financial and taxation information Income, employment and payroll records, business and trading records, bank account details, investment and superannuation holdings, loan and liability details, asset registers, cryptocurrency transaction records, capital gains records, and prior year tax returns and assessments.

Engagement information Information you provide in engagement letters, questionnaires, onboarding forms, checklists and supporting documents, and our records of meetings, telephone calls and correspondence with you.

Information about third parties Where you provide it to us, information about your spouse, dependants, business partners, trustees, beneficiaries, directors, shareholders and employees.

Forensic accounting engagements Where we are engaged in a family law, commercial litigation, personal injury or insurance matter, we may receive extensive personal and financial information about you and about other parties to the proceedings, including information produced under subpoena or court order.

Recruitment information Where you apply for a role with us, your resume, qualifications, work history, referee comments and the results of background checks.

Website information Information about your use of our websites, as described in section 6.

Sensitive information In limited circumstances we may collect sensitive information, which is a special category of personal information under the Privacy Act. Examples include health information relevant to a medical expenses or disability offset, an early release of superannuation application, a personal injury forensic engagement, or criminal record information relevant to an AML/CTF or forensic matter. We collect sensitive information only with your consent, or where the law requires or authorises us to do so.

4. How we collect personal information

We collect personal information directly from you wherever it is reasonable and practicable to do so. This includes information you give us in meetings, by telephone, by email, through our website forms, through our client portal, and through documents you upload or send to us.

We also collect personal information from third parties, including:

the Australian Taxation Office, through the Tax Agent Portal and pre-fill services
ASIC, AUSTRAC, the Australian Business Register and other government agencies and registries
your previous accountant or tax agent, on your authority
your bank, superannuation fund, share registry, broker or cryptocurrency exchange
your employer, bookkeeper or payroll provider
your solicitor or other professional adviser
accounting software you connect to us, such as Xero
electronic identity verification and sanctions screening providers
publicly available sources, including public registers, court records and social media, where relevant to a forensic or verification engagement

Where we collect your personal information from someone other than you, we take reasonable steps to make you aware of that collection, unless an exception under the Privacy Act applies.

5. Why we collect, hold, use and disclose personal information

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

provide accounting, taxation, business advisory, bookkeeping, virtual CFO, SMSF and forensic accounting services
prepare and lodge income tax returns, business activity statements, financial statements and other documents with the ATO, ASIC and other authorities
verify your identity and meet our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006
issue engagement letters, quotes, invoices and statements, and collect our fees
communicate with you about your affairs and about lodgement deadlines and legislative changes
respond to your enquiries and manage our relationship with you
meet our professional, legal and regulatory obligations, including those imposed by the Tax Practitioners Board, Chartered Accountants Australia and New Zealand, AUSTRAC and ASIC
obtain professional advice, respond to complaints and claims, and manage our professional indemnity insurance
conduct quality reviews, practice reviews and audits
assess job applications and manage our workforce
improve our services and operate our business

We will not use or disclose your personal information for a purpose other than the purpose for which it was collected, or a related purpose you would reasonably expect, unless you consent or the law requires or permits it.

6. Our websites, cookies and analytics

Our websites are built on the Wix platform. When you visit our websites we may collect your IP address, browser and device type, operating system, referring page, the pages you view, and the date and time of your visit.

Wix sets cookies that are necessary for our websites to function, and provides us with analytics about how visitors use our sites. We also use Google Tag Manager to manage the measurement and analytics tags on our websites. These tools may set cookies that collect information about your visit, including your approximate location, the pages you view and how long you spend on them. We use this information in aggregate to understand which pages are useful and to improve our websites. We do not use it to identify you personally.

You can set your browser to refuse cookies or to notify you when a cookie is set. Some parts of our websites may not function correctly if you do. You can also opt out of Google Analytics using the Google Analytics opt-out browser add-on.

Our websites may contain links to third party sites. We are not responsible for the privacy practices of those sites, and we encourage you to read their privacy policies.

7. Direct marketing

We may send you newsletters, tax updates, invitations and information about our services by email or post. We will always give you a simple way to opt out, and every marketing email we send includes an unsubscribe link. You can also opt out at any time by contacting our Privacy Officer.

Opting out of marketing does not stop us sending you communications we are required to send you about your engagement, your lodgements or your obligations.

We do not sell personal information, and we do not disclose personal information to other organisations for their own direct marketing purposes.

8. Who we disclose personal information to

We may disclose your personal information to:

the Australian Taxation Office, ASIC, AUSTRAC, the Tax Practitioners Board, state revenue offices and other regulators
courts, tribunals, and parties to litigation, where we are required to do so or where you have engaged us in connection with proceedings
your solicitor, barrister, financial adviser, mortgage broker, bookkeeper or other adviser, on your instructions
banks, superannuation funds and share registries
SMSF auditors, and auditors of entities we act for
our professional indemnity insurers, brokers, lawyers and debt recovery agents
our software, hosting, communications, storage, identity verification and IT support providers
our contractors and offshore service team, as described in section 9
Bear Loans, where you make a mortgage broking enquiry or book a meeting about mortgage broking through our website
a purchaser or prospective purchaser in connection with a sale or merger of our practice, subject to confidentiality
any person to whom you have authorised or directed us to disclose it
any person where disclosure is required or authorised by law

We require our service providers and contractors to protect your personal information, to use it only for the purpose for which we provided it, and to comply with obligations equivalent to the APPs.

9. Overseas disclosure and our offshore team

Some of the people who work on our clients' files are engaged by us as contractors based in the Philippines. They work under our direction, on our systems, under written contracts that impose confidentiality and privacy obligations equivalent to the Australian Privacy Principles, and under the supervision of our Australian Chartered Accountants.

Some of our software, hosting and cloud providers also store or process data outside Australia. The countries in which recipients of your personal information are likely to be located are the Philippines, the United States, the United Kingdom, the European Union, Singapore, New Zealand and Canada.

Before we disclose personal information overseas we take reasonable steps to ensure the recipient does not breach the Australian Privacy Principles, including through contractual obligations, access controls and restrictions on the downloading and local storage of client data.

If you would like to know where a particular service we use stores your information, please contact our Privacy Officer and we will tell you.

10. Tax file numbers and government identifiers

We are a tax file number recipient. We collect and use tax file numbers only for the purposes permitted by taxation, personal assistance and superannuation law.

We will not use a tax file number to identify you in our records, we will not disclose it except as permitted by law, and we will not require you to provide it where the law does not require it. We take reasonable steps to protect tax file number information from misuse, loss and unauthorised access, and to securely destroy it when we are no longer required to retain it.

We do not adopt a government related identifier, such as a Medicare number or driver licence number, as our own identifier for you.

11. Anti-money laundering and counter-terrorism financing

From 1 July 2026, accounting practices that provide designated services under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 are reporting entities regulated by AUSTRAC. Where we provide a designated service to you, we are required to:

collect and verify information about your identity, and about the identity of beneficial owners, directors, trustees and persons acting on your behalf
screen that information against sanctions lists and politically exposed person lists
monitor our relationship with you on an ongoing basis
keep records for at least seven years
report certain matters to AUSTRAC

We collect this information because the law requires it. If you do not provide it, we may be unable to act for you. Where we are required to report a matter to AUSTRAC, the law prohibits us from telling you that we have done so.

12. Automated decisions and our use of artificial intelligence

We use software, including tools with artificial intelligence and automation features, to assist us in preparing work, summarising documents, drafting correspondence and checking data. A qualified member of our team reviews the output of those tools before we act on it or provide it to you.

Where we use a computer program to make a decision, or to do something substantially and directly related to making a decision, that could reasonably be expected to significantly affect your rights or interests, we will tell you. At present, the categories of decision that may involve automated processing are:

automated identity verification, sanctions screening and politically exposed person screening as part of our client onboarding, which may affect whether we are able to accept you as a client

The kinds of personal information used in those processes are your identity and contact information, your government identifiers, and information about your work history and qualifications.

13. How we hold and protect personal information

We hold personal information in electronic form in our practice management, document management and accounting systems, and in physical form in secure premises.

We protect personal information using measures that include multi-factor authentication, device management and endpoint protection, encryption in transit and at rest, role based access controls, restricted physical access to our office, staff confidentiality undertakings, and staff training.

No system is completely secure. If we suffer a data breach that is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme.

14. How long we keep personal information

We retain personal information for as long as we need it for the purpose for which we collected it, and for as long as the law requires us to keep it.

In practice we retain client records for at least seven years after our engagement ends. Longer periods apply in some cases, including records relating to capital gains tax assets, self managed superannuation funds, deceased estates, forensic engagements and matters that are or may become the subject of a claim.

When we no longer need personal information and we are not required to retain it, we destroy it or

de-identify it securely.

15. Accessing and correcting your personal information

You may ask us for access to the personal information we hold about you, and you may ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading.

Please make your request in writing to our Privacy Officer using the contact details in section 17. We will need to verify your identity before we release information.

We will respond to your request within 30 days. We do not charge for making a request, but we may charge a reasonable fee for the cost of giving you access to a large volume of material.

There are limited circumstances in which we may refuse access or correction, including where the information relates to anticipated or existing legal proceedings, where giving access would unreasonably affect the privacy of another person, or where the law requires or authorises us to refuse. If we refuse, we will tell you in writing why, and how you may complain.

Documents we produce in a forensic engagement may be subject to legal professional privilege or the directions of a court, and access to them may be restricted for that reason.

16. Complaints

If you believe we have breached the Australian Privacy Principles or the Privacy (Tax File Number) Rule, please contact our Privacy Officer using the details in section 17. Please set out your concern in writing so that we can investigate it properly.

We will acknowledge your complaint within five business days and give you a written response within 30 days. If we need longer, we will tell you why and agree a timeframe with you.

17. Contact us

Privacy Officer Dolman Bateman Chartered Accountants 21 Hill Street, Roseville NSW 2069 Telephone: 02 9411 5422 Email: mail@dolmanbateman.com.au

18. Changes to this policy

We review this policy regularly and may update it from time to time. The current version is always available at www.dolmanbateman.com.au/privacy-policy. Material changes will be notified on our website.

Last reviewed: September 2026.

Dolman Bateman Chartered Accountants Privacy Policy Version 2.0. Effective 10th September 2026.