Privacy Policy.

This privacy policy covers both Gatehouse Legal Recruitment ACN 161 120 761 and Gatehouse Business Brokers Pty Ltd ACN 603 978 169 (collectively and each of them individually as the context requires, “Gatehouse” or “we“, “us” or “our“), we recognise the importance of your privacy and understand your concerns about the security of the personal information we may collect and hold about you, including via the website located at gatehouselegal.com.au (Website).

We are bound by the Australian Privacy Principles (APP) contained in the Privacy Act 1988 (Cth) (Privacy Act) (subject to exemptions that apply to us under that Act), the AML/CTF Law, our general law obligations of confidentiality to you and all other applicable guidelines and codes in Australia. The APPs detail how personal information may be collected, used, disclosed, stored and destroyed, and how an individual may gain access to or make complaints about the personal information held about them.

“Personal information” is defined in the Privacy Act. Broadly, it means information or an opinion about an identified individual, or about an individual who is reasonably identifiable, whether or not the opinion is true or not and whether or not the information is stored in material form or not. It includes sensitive information and health information.

“Health information” is information or an opinion about an individual’s health or disability, the health services provided or to be provided to them, their expressed wishes for the provision of future health services, personal information collected to provide a health service, personal information collected in connection with organ and body-part donation, and predictive genetic information.

“Sensitive information” is a special category of personal information. It is information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, health information about an individual or genetic information about an individual that is not otherwise health information.

This policy details how Gatehouse manages personal information about you. For that reason, please read the following details carefully.

We may, from time to time, review and update this policy, including taking into account of new or amended laws, new technology and/or changes to our operations and practices. All personal information held by us will be governed by the most recently updated policy. Accordingly, please also regularly check our privacy policy so that you are aware of these updates and changes. If you have any questions, please contact us.

What kinds of information will we collect and hold?

The personal information we collect and hold will depend on whether you are a client (including an employee, officer, shareholder, contractor, agent or related party of a client), consultant, vendor or service provider (including contractor or sub-contractor), employee, volunteer, job applicant or a person making an enquiry. It may also depend on which service we provide, and/or what goods or services you provide to us.

The personal information that we may collect and hold from you or about you include, but is not limited to:

your name, gender, address, phone, fax and mobile numbers, email address, date of birth, qualifications, education, business, accreditations and your work experience; and
the opinions of others about your work performance (whether true or not), your career objectives, the name and contact details of individuals listed as referees within your application for employment, references, aptitude test results; and
any other information obtained by us in connection with the provision of our services.

We may also collect and hold personal information as required by the AML/CTF Law to comply with the AML/CTF obligations (including, conducting customer identification and verification, ongoing customer due diligence and transaction monitoring).

Insofar as our services to you constitute or include a “designated service”, as defined in the AML/CTF Law (e.g. assisting in a sale or purchase of a business opportunity), this may include, but is not limited to, (a) information relating to your ownership or control; (b) the identity of you, the person on whose behalf you are representing , and their respective authorised representatives, beneficial owners and controllers; and (c) where relevant, information relating to the source of wealth and the origin of funds for a transaction.

When you browse our website or contact us electronically, we may record: geographical tagging, cookies, and statistical data.

We may collect sensitive information from you or about you where there is a legal requirement to do so, or where we are otherwise required or permitted by law. In all other situations, we will specifically seek your consent.

If you provide that information that we do not solicit, we will, within a reasonable period after receiving the information, determine whether or not we could have collected the information under the APP. If we determine that we could not have collected such information under APP and the information is not a Commonwealth Government identifier, then we will as soon as practicable either destroy the information or otherwise ensure it is de-identified, provided that it is lawful to do so. Otherwise, we will hold, use and disclose such information in accordance with this policy.

How do we collect and hold that 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 you or about you from:

correspondences that you submit to us, whether in writing or by email, facsimile or post;
communications, telephone calls, meetings or interviews with us;
questionnaires and feedback surveys that you complete;
the application, form or application you complete and submit to us;
your activity on our Website and social media platforms;
other material provided to us or to our consultants or other persons connected to your interest in your application for employment; and
information about you that is available on the internet or that is otherwise published.

Where you have provided us with your referees, we may also collect personal information about you from them, but only if you give us express permission to do so.

We may also collect personal information from third parties about you, including (but not limited to): courts, law enforcement agencies and other government entities; our clients; other legal representatives and third parties involved in the matters in which we are involved; your (current or former) employers or advisors; suppliers, vendors, contractors and sub-contractors; third party recruitment providers, including screen and reference check service providers; electronic identity verification services, document verification services and other commercially available databases. These third parties may, and are likely to, have their own privacy policies that apply to your Personal Information. You should review the privacy policies of any third party before disclosing personal information to any third party. We do not accept any responsibility for information submitted by you to third parties.

Where you have provided us with the personal information of another person (e.g. referees), you confirm that every person whose personal information has been provided to us by you has been notified of this and has agreed to the collection, process, disclosure and use of their personal information as set out in this Privacy Policy and any of our terms and conditions. You also confirm that you will inform such persons that they may have rights of access to, and correction of, their personal information.

In addition, in connection with your use of the Website, we may also collect cookies from your computer or mobile, which enables us to tell when you use the Website and also to help customise your Website experience.

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.

The purpose for which we collect, hold, use and disclose personal information

We collect, hold, use and disclose your personal information in order to provide services we offer or you have contracted us to provide or otherwise to comply with its legal obligations.

We collect, hold, use and disclose Personal Information from you or about you primarily for the following purposes (where applicable):

to conduct our business;
to provide our services , including, without limitation, assisting you or any other person in the identification, planning, negotiation or execution of employment or business opportunities, to identify your career objectives and to apply for specific jobs, and/or to act for or on behalf of you or any other person in a transaction;
to assist employers to find prospective employees or a person to plan, negotiate or execute a transaction.;
to consider the suitability of prospective employees, contractors and/or buyers;
to enable you to submit your CV generally, to apply for specific jobs or to subscribe to our services;
to assess an application for employment made by you or on your behalf;
to answer your queries;
to provide you with any training;
to assist you with your interviews with potential employers;
to promote, facilitate and manage the provision of any other services we provide to you;
for our administrative and accounting functions, fraud checks, marketing and promotions, newsletter communications, website traffic analysis;
to maintain our business relationship, where you are a user of our Website, a client or candidate;
to receive, hold and control (including disburse) or manage a person’s money, accounts or other property as part of assisting the person in the planning or execution of a transaction, or otherwise acting for or on behalf of a person in a transaction, in the course of carrying on our business;
to comply with our legal and regulatory obligations (including our obligations under the AML/CTF Law). These include, but are not limited to, conducting customer due diligence, and verifying the identity of our clients and counterparties; and/or
for any other purposes disclosed at the time of collection.

Where we use your Personal Information for marketing and promotional communications, you can opt out at any time by notifying us.

If you are a candidate, we will disclose your personal information to specific employer(s) or third parties that you have consented to us disclosing your information.

We will also disclose your information to third party contractors that we retain to assist us providing services to you, including Information Technology and database design contractors, our internet service provider and our professional advisers (such as our accountants or lawyers).

In connection with our AML/CTF compliance obligations, we may also disclose personal information to: AUSTRAC, in compliance with our reporting obligations under the AML/CTF Law; law enforcement or intelligence agencies, where required or authorised by law; electronic identity verification and screening service providers for the purpose of conducting customer due diligence; and our AML/CTF compliance advisers.

We will not disclose personal information about you for any other purposes, except that we may disclose or use your personal information where:

we are under a legal duty to do so, including circumstances where we are under a lawful duty of care to disclose information; or
such disclosure is authorised or permitted by the APP, law or you.

What is the main consequence for you if you do not provide your information to us?

If you do not provide your personal information to us we may be unable to:

assist you in your efforts to find an employment and/or business opportunity for you or place you in work;
assist you in your efforts to find a suitable acquisition and/or merger target;
provide you with the necessary training or appraisal;
answer your enquiry; and/or
provide or continue to provide any other services that you or your organisation have contracted us to provide.

Destruction and De-identification

We will retain your personal information whilst it is required for any of our business functions, or for any other lawful purpose.

Notwithstanding the above, where personal information has been collected in connection with our AML/CTF compliance obligations, we are required by law to retain that information for a minimum period of 7 years after the end of our relationship with you, or 7 years after the relevant transaction was completed, whichever is later. This obligation overrides any request by you for earlier deletion or de-identification of such records.

We use secure methods to destroy or to permanently de-identify your personal information when it is no longer needed:

Paper records are commonly sent for secure destruction.
Electronic records are deleted from all locations, to the best of our ability, or encrypted and/or placed beyond use.

Overseas disclosure

We may disclose your personal information to our contractors, service providers and third party suppliers located overseas (including, without limitation, any organisations engaged by you or us to assist in exploring an opportunity overseas) for one or more of the purposes listed above.

These overseas recipients include our contracted service providers located in the Philippines.

We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

How do we keep personal information accurate and up to date?

We rely on the Personal Information we hold about you in providing you with our services or otherwise conducting our business. Therefore, it is important that the information we hold about you is accurate, complete and up-to-date. This means that from time to time we may ask you to tell us if there are any changes to your Personal Information. To assist us to keep our records up-to-date, please advise your consultant immediately when your personal details change. We generally update your personal information over the telephone, by email or in post.

How are you able to access to your personal information

We have procedures in place for dealing with and responding to requests for access to the personal information held about you.

In most cases, we expect that we will be able to comply with your request. However, we may refuse to provide access to, or to correct, personal information where doing so would: prejudice the prevention, detection, investigation or prosecution of a criminal offence or a breach of a law imposing a penalty or sanction; reveal the existence or content of a suspicious matter report made to AUSTRAC; be contrary to the ‘tipping off’ provisions of the AML/CTF Act; or otherwise be unlawful. If we refuse access on these grounds, or if for any other reason, we do not agree to provide you access to information as requested, we will give you written reasons why (to the extent we are permitted and not prohibited by law to do so). For further information, please contact us privacyofficer@gatehouselegal.com.au.

Enquiries & complaints

We have procedures in place for handling and dealing with complaints and concerns about our practices in relation to the Privacy Act and the APPs. These procedures are set out in our Privacy Complaints Handling Process annexed hereto. We will respond to your complaint in accordance with our Privacy Complaints Process and the relevant provisions of the APPs. For further information, please contact our Privacy Officer.

Contact

Privacy Officer
privacyofficer@gatehouselegal.com.au

July 2026

Privacy Complaints Process

This Privacy Complaints Process covers both Gatehouse Legal Recruitment ACN 161 120 761 and Gatehouse Business Brokers Pty Ltd ACN 603 978 169 collectively (“Gatehouse” or “we”, “us” or “our”).

Definitions

AML/CTF Law means the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and associated Rules (to the extent applicable to our services).

Complaint: an expression of dissatisfaction with the quality of an action taken, decision made, or service provided by us or our contractors that may interfere with the privacy of an individual.

Complainant: The person making the Complaint. This can include anyone whose personal information Gatehouse has collected, stored, used or disclosed.

Privacy Officer: The person assigned by Gatehouse to maintain Gatehouse’s Privacy Policy and privacy practices, as well as review any Complaints received. The Privacy Officer investigates, assesses and records any complaints. The Privacy officer also monitors and tracks Complaints, making recommendations for improvements to the Privacy Policy or privacy practices.

Purpose

The Privacy Complaints Process aims to establish an open and transparent Complaint handling process. It sets out our approach to resolving Complaints, and clarify the roles and responsibilities of Gatehouse staff in Complaint handling.

Process

There are five phases to the privacy complaints process:

Receipt of Complaint;
Assessment of Complaint;
Actions taken to resolve the Complaint;
Recording of outcome and monitoring; and
System improvements, where appropriate.

Receipt of a complaint

A Complaint may be made to the Privacy Officer in one of the following two ways:

In person or via mail:
Privacy Officer
Gatehouse Legal Recruitment
Level 1, 530 Little Collins Street, Melbourne, Victoria 3000

Email:
privacyofficer@gatehouselegal.com.au

In the Complaint, the Complainant should:

include sufficient contact details to enable us to identify them;
clearly and succinctly state the nature of their Complaint;
include sufficient information for the Privacy Officer to understand the Complaint;
provide details of the circumstances giving rise to the Complaint, such as what happened, when they became aware of it, and who was involved;
outline the impact the event has had on them; and
include details of what they would like to see happen to resolve their Complaint.

Importantly, we can only accept Complaints from the individual involved, or their authorised representative. If the Complaint is acting on behalf of another person, they must provide satisfactory evidence of their authority to do so.

The Privacy Officer will aim to acknowledge the Complaint within 5 working days of receiving it.

In order to properly and efficiently respond to a Complaint,the Privacy Officer may also seek further information from the Complainant (if necessary).

Complaint Investigation

The Privacy Officer will investigate the Complaint. This may involve obtaining further information from the Complainant, speaking with the relevant staff members, reviewing relevant documents or files, and obtaining technical or legal advice.

How long it takes for the Privacy Officer to investigate your Complaint and respond to you will ultimately depend on the nature and complexity of the issues involved. However, it is anticipated that in most cases, the duration of the investigation will not exceed 30 days of the Complaint and all subsequently requested information being received. If the investigation is likely to take longer than 30 days, the Privacy Officer will notify the Complainant.

Resolving a complaint

The Privacy Officer will make an assessment of the Complaint following an investigation and make a decision, including any appropriate remedy.

The Privacy Officer will write to the Complainant to inform them of the outcome of the investigation.

Remedies may include an explanation, an apology, a correction, system improvements, or a combination of these.

If a Complaint is dissatisfied with the outcome of a Complaint or the responses provided, they may wish to contact the Office of the Australian Information Commissioner (OAIC). More information about the OAIC and how to lodge a Complaint can be found on the OAIC website.

Recording and monitoring

All Complaints are to be recorded in the Privacy Complaints Register. This includes all Complaints received in writing, and those received verbally but documented by a Gatehouse representative.

Any action taken pursuant to receipt of a complaint, and its resolution, are also to be recorded. The Privacy Officer will monitor privacy complaints and determine if system or process improvements are required.

System improvements

A Complaint may alert Gatehouse to a system or process failure that requires correction to ensure that people’s personal information and privacy is protected. When considering improvements the Privacy Officer will act to prevent recurrence of any breaches and will promote continuous improvement of Gatehouse’s privacy practices.

Any improvement considerations will include policy and process reviews, practice reviews, and training.

Policy last updated July 2026.

Contact

Privacy Officer
privacyofficer@gatehouselegal.com.au