AFS & Associates Pty Ltd (ABN 51 061 795 337) and Andrew Frewin Stewart (ABN 65 684 604 390) collectively (‘AFS’) understands that privacy is important to you. Protecting your personal information is important to us.

This policy explains how AFS and its related entities handle personal information and comply with the requirements of the Privacy Act 1988 (‘Privacy Act’). The policy deals with AFS’s collection and handling of personal information that is covered by the Privacy Act. It does not cover personal information that is not covered by the Privacy Act.

What does personal information mean?

Personal information is any information about you that identifies you or by which your identity can be reasonably determined.

Collection of personal information

AFS collects and holds personal information from clients, customers, employees, contractors and other people. AFS collects and holds this information when it is necessary for business purposes.

Personal information which AFS collects includes but is not limited to name, address, job title, tax file numbers, financial institution details, phone numbers, email addresses and shareholding balances. In the course of providing tax, audit, accounting, business services, share registry and related services to our clients, we may collect and hold more detailed personal information, including financial information.

This information is generally provided to us either directly by our clients and other individuals such as job applicants, or through a listed or unlisted organisation (‘Issuer’) in relation to a share registry service we provide or a securities exchange or security broker. Personal information is obtained when we first deal with you. We may collect personal during a phone call or in-person meeting or via an application or other form completed by you. We also collect personal information during subsequent face to face meetings, email messages, telephone conversations and from third parties. For instance, if you telephone us we may keep a record of that contact.

How we use your personal information

AFS only uses your personal information for the purpose for which it was collected and to offer and provide related services that are connected to that purpose.  This includes, for example, providing Issuers with registry and registry-related services, or notifying you about other Issuer or AFS services.

The purposes for which we collect, hold, use and disclose personal information include:

  • to provide our services to you
  • to respond to your requests
  • to maintain contact with you
  • to keep clients and other contacts informed of the services we offer and industry developments and seminars that may be of interest to you
  • to administer your security holding
  • for general management and reporting purposes, such as invoicing and account management
  • for recruiting purposes
  • for purposes relating to the employment of our personnel and providing internal services to our employees
  • for other purposes related to our business, such as auditing, business planning, billing, record keeping, compliance with legislation, and for the purpose of potential legal proceedings.

We may collect, hold or use information about individuals to market our services, including by email.  When you become our client, you consent to receiving marketing email.  However, you may opt out of marketing services at any time by writing to the Marketing and Communications Manager, AFS & Associates Pty Ltd, PO Box 454 Bendigo, 3552 or emailing us at  Please allow 28 days for us to process your request. If we contact you by email, you may send a return email to notify us that you do not want to receive further marketing information from us via email. We will process that request as soon as practicable.

Consequences of not being able to collect your personal information

If we are not able to collect your personal information, we will not be able to provide you with a full range of services. For instance, we will not be able to provide an Issuer or securities exchange with accurate and complete information about you. If you are a job applicant and we cannot collect personal information about you, we will not be able to consider your job application.

Due to the nature of the services AFS provides, and its business structure and size, it is impractical for us to deal with you anonymously.

Security of personal information

AFS only collects information in a way that is lawful, fair and is not unreasonably intrusive.

We will endeavour to take reasonable precautions to ensure the security of your personal information, whether electronically or in hard copy, from such risks as loss or unauthorised access, destruction, misuse, modification or disclosure. We retain your personal information electronically or in hard copy files on-site. When your hard copy documents are no longer needed we either arrange for them to be destroyed securely or returned to you.

AFS aims to achieve industry best practice in the security of personal information which it holds. Wherever possible, we destroy or de-identify personal information once there is no longer a legal or business need for us to retain it. Sometimes, however, it is impossible to irrevocably destroy or de-identify information completely, because such information is intermingled with data which we are legally obliged to retain. An example of this is when we archive an electronic file but the information in the files remains on the hard drive of a computer which we use to store other files. It is not possible to completely sanitise the computer’s hard drive in such circumstances. Nevertheless, we use all reasonable endeavours to ensure that such data is not readily accessible or identifiable.

Will we provide your personal information to anyone else?

AFS does not disclose personal information to other people or organisations unless:

  • use or disclosure is permitted by this policy
  • we believe it is necessary to provide you with a product or service which you have requested (or as an employee is necessary in managing you in your role at AFS)
  • you give consent
  • such disclosure is required by law, regulation, rule or professional standard. For example, under Chapter 2C of the Corporations Act 2001 (Cth), certain information about you as a security holder (including your name, address and details of securities you hold) must be included in the public register of the entity in which you hold securities, and this information will therefore be disclosed to anyone who requests to inspect it
  • we engage a third party to help us deliver our products and service to you.

AFS uses service providers to help us maximise the quality and efficiency of our services and business operations, and personal information may sometimes be disclosed to those contractors or service providers. For example, personal information may be disclosed to IT service providers, off-site security storage facilities, debt collection agencies, print or mail services. We require our service providers to adhere to our privacy policy and not to keep this information or use it for any unauthorised purposes.

We do not sell to or trade personal information with third parties.

What is a Government identifier?

A Government identifier is a Commonwealth Government or Commonwealth Government agency designated identification number such as your Tax File Number (TFN).

Although at times AFS may request or hold details regarding certain Government assigned identification numbers we do not use such information as identifiers of our own.

We only use Government identifiers for purposes required by law, such as when we supply your TFN to the Australian Taxation Office.

Does your personal information leave Australia?

We utilise a hosted desktop for our applications, with all data residing in Australia. Data backups are encrypted and kept in a secure third party storage facility in Australia.

We may utilise cloud computing service providers. We may provide these third parties with access to your data to the extent this is required to perform the services.

Your data will be stored in servers physically located in Australia (unless otherwise specified) and in accordance with the security practices of the third party service provider and our Privacy Policy.

To the best of our knowledge, all third party servers are located in Australia, with the following exceptions:

  • The service provider AFS uses for online surveys is based overseas, and as a result your survey responses may be stored overseas. This is explained further whenever you receive an online survey. It is not possible for AFS to state precisely where the survey results are held as the service provider does not provide this information to AFS.
  • We may be required to request bank confirmations as part of our external audit services. Some banks only supply confirmations via a platform where date is hosted in the USA or Republic of Ireland.

Sensitive information

Some types of personal information are particularly sensitive and have special protection under the Privacy Act. Sensitive information is information about your:

  • racial or ethnic origin; or
  • political opinions; or
  • membership of a political association; or
  • religious beliefs or affiliations; or
  • philosophical beliefs; or
  • membership of a professional or trade association; or
  • membership of a trade union; or
  • sexual preferences or practices; or
  • criminal record; or
  • health information.

AFS only collects, uses or discloses this information about you when it is necessary and as allowed by law.


AFS may also collect personal information from you via its websites, such as

We use cookies on our online services to monitor your use of the Website, to measure usage sessions accurately and to provide you a more effective service. Cookies are also used to improve the functionality of the Website. If you prefer not to enable us to use cookies most browsers have a facility that will allow you to disable cookies altogether, please refer to your browser’s help menu to find out how to do this. Doing so may affect your browsing experience and certain functions of the Website may not work.

When you scan a QR Code, the third party that we engage to provide our QR Codes may collect certain information from your mobile device (such as your mobile device identifier and IP address). This information is used only for the purpose of providing anonymised statistical reports to us about users of our website and services.

A link to a third party’s website should not be construed as an endorsement by either AFS or that third party of the other or its products and services. AFS makes no representations or warranties regarding how user data is stored or used on third-party servers. We recommend that you review the privacy policy of each third-party site linked from our site to determine the security of your personal data.

Social media

You may wish to participate in social media platforms hosted by AFS or on which AFS participates. The aim of these social media platforms is to inform you of AFS news and events and allow you to share content. AFS is not responsible if you share personal information on social media platforms that is subsequently used, misused or otherwise appropriated by another user.

Our website includes links to social media platforms. These platforms are maintained on separate servers by individuals and organisations over which AFS has no control. For instance, AFS uses plugins (also known as buttons) of social media such as Facebook, Twitter and LinkedIn. When you visit our website, these plugins are deactivated by default, i.e. without your intervention they will not send any data about you to social media networks. The plugins are activated by clicking on them. We have no influence on the scope of data that is collected by social networks through their plugins. The privacy policies of the social networks provide information on the purpose and extent of the data that they collect, how this data is processed and used, the rights available to you and the settings that you can use to protect your privacy.

How we handle email

We will retain any email message that you send us if we have a legal requirement to do so.  Emails sent to or from us are routinely monitored for quality control, systems administration and legal compliance purposes.

Access and correction of your personal information

AFS will take reasonable steps to keep any personal information up to date. Under the Privacy Act you may access information that we hold about you. There are some exceptions to this which are detailed in the Act.

When you request access to personal information, we will require you to provide some form of identification (such as a driver licence or passport) 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 your personal information has been archived, we may charge a fee for retrieval of your file.

You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. In most cases, access to your personal information is available to you at no charge by contacting AFS on the following:

Phone:                 03 5443 0344

In writing:           The Privacy Officer, AFS & Associates Pty Ltd, PO Box 454, Bendigo, Victoria, 3552.


If you are a security holder and your security holding is sponsored by a broker, you will need to contact your broker direct who will in turn arrange for access to or correction of the information, as the case may be.

Requests for access to personal information will be handled as quickly as possible and we will endeavour to process any request for access within 30 days of having received the request.

If you have any questions or comments about this privacy policy, or you wish to lodge a complaint about the way we have handled personal information about you, please contact AFS’s Privacy Officer at the address listed above. Any complaint should be in writing. AFS will consider the complaint and endeavour to respond to it within 14 days. If you believe that AFS has breached the Australian Privacy Principles, you may also wish to contact the Office of the Australian Information Commissioner. The Commissioner’s details are:

Phone: 1300 363 992

Fax: 02 9284 9666

Post: GPO Box 5218 Sydney NSW 2001.


We reserve the right to modify this Privacy Policy at any time by publishing an updated version of this Privacy Policy on our Website and taking any further action as required by law, after which, your continued use of the Website or your provision of any further personal information will indicate your acknowledgement to the modified terms of this Privacy Policy.

This Privacy Policy was last updated in February 2022. All material copyright © 2021 AFS & Associates Pty Ltd.


This website and the articles on our website are not a substitute for independent professional advice. We do not warrant the accuracy, completeness or adequacy of the information or material on this website. All information is subject to change without notice. We and each party providing material displayed on this website disclaim liability to all persons or organisations in relation to any action(s) taken on the basis of currency or accuracy of the information or material, or any loss or damage suffered in connection with that information or material. You should make your own enquiries before entering into any transaction on the basis of the information or material on this website. Please ensure you contact us to discuss your particular circumstances and how the information provided applies to your situation.

Quality of information – always check the information

Before relying on the information on this website, users should carefully evaluate its accuracy, currency, completeness and relevance for their purposes, and should obtain professional advice relevant to their particular circumstances. We and associated parties can not guarantee nor assume any legal liability or responsibility for the accuracy, currency or completeness of the information or material.

Links to external websites

This website may contain links to other websites which are external to our website. It is the responsibility of the user to make their own decisions about the accuracy, currency, reliability and correctness of information contained in linked external websites.

Linkage to external websites should not be taken to be an endorsement or a recommendation of any third party products or services offered by virtue of any information, material or content linked from or to this website. Users of links provided by this website are responsible for being aware of which organisation is represented or providing the information or material on the website they visit.
Views or recommendations provided in linked websites do not necessarily reflect our views or recommendations, nor the views or recommendations of associated parties.

Security of our website?

Users of our website should be aware that the World Wide Web is an insecure public network that gives rise to a potential risk that a user’s transactions are being viewed, intercepted or modified by third parties or that files which the user downloads may contain computer viruses or other defects.

We and associated parties accept no liability for any interference with or damage to a user’s computer system, software or data occurring in connection with this website. Users are encouraged to take appropriate and adequate precautions to ensure that whatever is selected from this website is free of viruses or other contamination that may interfere with or damage the user’s computer system, software or data.


Notice of new or updated information or material available via our website may be emailed to our newsletter subscribers and clients.


This message may contain privileged and confidential information intended only for the use of the addressee named above.

If you are not the intended recipient of this message you are hereby notified that any use, dissemination, distribution or reproduction of this message is prohibited. If you have received this message in error please notify the sender immediately by return email and delete this email, any attachments and destroy any copies.

Any views expressed in this message are those of the individual sender and may not necessarily reflect the views of AFS.

We do not warrant that any attached files are free from computer viruses or other defects and we recommend that you scan this email and any attachment for viruses before opening.

The user assumes all responsibility for any loss or damage resulting directly or indirectly from the use of this email or the attached files.


Please be aware that there is a significant risk posed by cyber fraud, specifically affecting email accounts and bank account details.

Please note that our bank account details will not change during the course of a transaction and we will not notify you of any changes to our bank details via email.

Always independently confirm bank account details and transfer instructions with us in person or via a telephone call to a trusted and verified phone number.

In the event of any loss of funds which is not due to the negligence of AFS, we will not be liable for any loss or damages that may be suffered directly or indirectly as a result of any money which belongs to you not being received by you in which we shall be released from all and any claims, loss or liability incurred..

©AFS & Associates Chartered Accountants 2021 | Privacy Policy & Disclaimer | Liability limited by a scheme approved under Professional Standards Legislation.