Australia Residents – For Contacts and Potential Clients or Suppliers


March 1, 2023

This ghSMART Privacy Policy (“privacy notice”, “privacy statement”, or “notice”) describes how G. H. Smart & Company, LLC and its subsidiaries (collectively “ghSMART”) collect, hold, use and disclose personal information and comply with applicable privacy laws including the Privacy Act 1988 (Cth) and the Australian Privacy Principles.


We have designated a privacy officer who is responsible for our compliance with this Notice.  You may contact our privacy ‎‎officer as described below.‎


It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or handling personal information about you, so that you are aware of how and why we are using such information.

Personal Information that we collect

The types of personal information we collect depends on our relationship and interactions with you. In general, the information we collect from you may include your identity and contact details, customer records (including education and employment information), and audiovisual data such as transcripts or recordings of interviews with you.

In limited instances we may collect government identifiers such as drivers’ licences, passport numbers, and information about your entitlement to social security or similar schemes.

We may collect these types of personal information directly from you, or in some instances from third parties including government entities.

Purposes of Collection, Use and Disclosure

We collect, hold, and use your personal information so that we can:

  • provide our products and services and manage existing customer relationships;
  • conduct our business operations;
  • engage with prospective clients and provide information about our products and services;
  • comply with our legal obligations under applicable laws and assist government and law enforcement agencies or regulators; and
  • engage in marketing activities including contacting you regarding our products and services.

In some circumstances, we may deidentify or aggregate your personal information so that it can no longer be associated with you, in which case we may continue to use such information without further notice to you.

You do not have to provide us with your personal information but we may not be able to provide you with our services if you do not provide the requested information.

Disclosure of Personal Information

We may transfer or disclose your personal information to our related companies.

We may disclose your personal information to a third party, for example our external service providers, for the performance of services for us or on our behalf.

We may also disclose your personal information, in accordance with applicable law, in ‎connection with ‎a corporate re-organization, a merger or amalgamation with another entity, or a sale of ‎all or a ‎substantial portion of our assets, provided that the disclosed information continues to be used ‎solely for ‎the purposes permitted by this notice by the entity acquiring the information.‎

Cross-border transfers of personal information

We may transfer the personal information we collect about you outside of Australia including to the United States, European Economic Area, United Kingdom and Canada where ghSMART has administrative services, subcontractors, service providers, client consultants and client leadership. You acknowledge that the governments, courts or law enforcement or regulatory agencies in those jurisdictions may be ‎able ‎to obtain disclosure of that personal information through the laws of the foreign jurisdiction‎.

We may also transfer your personal information as otherwise permitted or required by law.


We protect the personal information in our custody or control using reasonable physical, ‎‎organizational and electronic security arrangements.  We ‎regularly review our practices to ensure they align with reasonable industry practices appropriate to ‎‎the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, ‎‎alteration or disclosure.‎

However, no method of transmission over the Internet, or method of electronic storage, is completely ‎secure. As ‎such, despite our safeguards and protocols, we cannot fully guarantee the security of your ‎personal ‎information and you should always exercise caution when disclosing personal information ‎over the ‎Internet (including by email).‎

Access to and Correction of Personal Information

We will make a reasonable effort to ensure that personal information we are using or disclosing is ‎‎accurate and complete. You may request corrections to your personal information as described below.

How to Exercise Available Rights

You can request access or correction of the personal information we hold about you by contacting us using the details below. In some instances, we are not required to provide you with access to your personal information.

We will not charge you for requesting access to personal information, but you may need to cover our reasonable costs in facilitating access, for example significant time spent on collating information.

Requests for access or correction will be responded to within a reasonable time.


If you have a complaint about how we have handled a privacy issue, you can contact us using the details below. If you remain unsatisfied, you can contact the Office of the Australian Information Commissioner (

Contact details 

If you have any questions about this privacy notice or how we handle your personal information, please contact: or +61 3 7064 1951.

Mail address:

G. H. Smart & Company, LLC
203 North LaSalle Street
Suite 2100
Chicago, IL 60601
The United States of America

G. H. Smart & Company Pty Ltd
Level 29 Chifley Tower
2 Chifley Square
Sydney NSW 2000

Changes to this privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.