Privacy Policy

General Information

Last Updated 03/23/2026

Phillips & Cohen Associates (Australia) Pty Ltd is bound by the Privacy Act 1988 (Cth) (Privacy Act) as amended from time to time, including the Australian Privacy Principles (APPs). The APPs are designed to protect the privacy of individuals by regulating the way personal information is collected, used, disclosed, and managed. Personal information is information or an opinion relating to an identified, or reasonably identifiable, individual, whether the information is true or not and whether the information is recorded in a material form or not.

This Privacy Policy explains the types of personal information that we may collect and hold, how that information is used and with whom the information is shared. It also sets out how you can contact us if you have any queries or concerns about our collection, use or disclosure of personal information, or if you believe we have not complied with this Privacy Policy or the Privacy Act.

In this Privacy Policy references to:

  • “PCA”, “we”, “us” and “our” in this Privacy Policy refer to Phillips & Cohen Associates (Australia) Pty Ltd.
  •  “you” and “your” refer to each and every individual whose personal information we may handle from time to time.
  • Personal information are to that term as defined in the Privacy Act.
  • Right Party is to a person who is managing the final affairs of the deceased estate, which Phillips & Cohen are managing on behalf of a creditor.

Client is to the Creditor in which PCA is acting on behalf to support the process of remediation of debts of the deceased estate.

What personal information do we collect?

The types of personal information we may collect include, but are not limited to:

  • contact information (e.g., full name, title, email address, postal address, and telephone number);
  • your role (e.g. executor of an estate) and the nature of your relationship with the deceased person (e.g. beneficiaries); and
  • personal information about you contained in any documentation provided to us as part of our death notification services, such as typical information contain in a death certificate or Last Will & Testament of a deceased person

‘Sensitive information’ is defined in the Privacy Act and includes personal information about an individual’s health, racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or membership of a trade union, among other things.  We do not collect any sensitive information without your permission, except where otherwise required or authorised by law.

How do we collect personal information?

We collect personal information in several ways, including directly from you, for example, when you provide it to us or our agents, apply for employment with us, use our website or platforms, or otherwise engage with PCA. Confirmation that you are the person managing the final affairs of the deceased estate or that another individual is responsible for managing the final affairs of the deceased estate, is obtained directly with you.

Personal information may also be collected by way of emails, phone conversations (which may be recorded for quality control purposes in accordance with applicable laws), forms filled out by individuals (including via online forms), employment applications, face-to-face interviews and via virtual interviews.

We may also be provided your personal information by third parties, for example, our clients (including where you were listed as an alternative contact, or the person notifying of the death of an individual), and users of our death notification services and online platforms. We may also obtain your personal information from public notices such as Probate and Letters of Administration notices.

If you provide us with the personal information of another person, we assume that you have obtained their consent or are otherwise authorised to provide their information to us for the purposes described in this Privacy Policy. 

We do not collect or store information such as payment card details.  Third-party Payment Gateway providers are used for online payment card transactions made via the PCA website, or by phone.

When an estate’s funds become available payments by, cheque, online or by phone:

  • Right Party person will be directed to a payment gateway provider;
  • our office has camera surveillance to ensure that agents do not write or save credit card details, if payments are made over the phone the calls recording will be stopped. Where a Right Party may email payment card details, we have an automated scanner solution of emails that will stop the email coming through to us; and
  • we will receive certain information about payments made from the payment gateway provider (including payment card details in a hashed format and the name and IP address) to enable us to provide record to our clients that the debt has been remediated.

Purposes of collection, use and disclosure

PCA may collect, use and disclose your personal information for the purposes described in this Privacy Policy, for related purposes which would reasonably be expected by you, for purposes to which you have consented, and in other circumstances permitted by the Privacy Act or otherwise required or authorised by law.

Generally, PCA may collect, use and disclose your personal information for a range of purposes, including to:

  • provide our clients with updates on the process of estate finalisation;
  • respond to queries related to the deceased account held with our client;
  • consider employment applications;
  • provide guidance and support to the individuals managing the final affairs of a deceased estate;
  • support the remediation of debts on behalf of our clients including providing debt collection services on behalf of our clients;
  • provide death notification services, including to you, our clients and other third parties;
  • disclose death notification information to other third parties (including organisations that are not our clients) to help identify and facilitate the resolution of any accounts held by the deceased person;
  • allow third parties to communicate with you about your death notification;
  • respond to your queries or complaints in relation to our death notification services; and
  • provide you any updates from our clients, relating to the final affairs of an estate.

Disclosure of personal information to other parties

PCA may disclose your personal Information to third parties, including:

  • our Clients;
  • our clients and other third parties to whom we provide death notification services;
  • other third parties to the extent necessary to fulfill the relevant purposes set out in this Privacy Policy; and
  • people and organisations that help us with our business, such as IT support, and suppliers who provide services to us. We only do this where it’s needed for those services to be provided to us. When we do this, we take steps that require our service providers to protect your information.

Security and management of personal information

We will take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification, or disclosure. The ways we do this include:

  • limiting physical access to our premises.;
  • limiting access to the information we collect about you (for instance, only those of our personnel who need your information to carry out our business activities);
  • using a third party payment gateway for secure handling of your payment information;
  • requiring any third-party providers to have appropriate security systems and processes to keep personal information secure; and
  • putting in place physical, electronic, and procedural safeguards in line with industry standards.

We will take reasonable steps to destroy or permanently de-identify information that is not required for the purposes for which it was originally collected.

Accessing the personal information we hold about you

Under the APPs, you have the right to seek access to a copy of the personal information that we hold about you. The APPs provide some exceptions to your rights in this regard. To make a request to access this information, please contact us in writing at the address listed below to the attention of our Compliance Manager. We will require you to verify your identity and specify what personal information you require:

Postal Address: Suite 1, Level 7, 60 City Road, Southbank VIC 3006

Email: Privacy@phillips-cohen.com.au

Telephone: +61 3 9118 8309

Updating your personal information

We endeavour to ensure that the personal information we hold about you is accurate, complete, and up to date. Please contact us at the contact address set out below if you believe that the personal information we hold about you requires correction or is out-of-date.

Updates to this Privacy Policy

This Privacy Policy will be reviewed from time-to-time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The current version of this Privacy Policy is available at:  phillips-cohen.com.au

Privacy Officer

For the purpose of managing this Privacy Policy for Phillips & Cohen Associates Australia Pty Ltd, Chris Manders has been appointed to be the Privacy Officer and is responsible for the management and review of this Privacy Policy on an annual basis to take into effect changes and reviews as outlined under the Updates section of this Privacy Policy.
 

Complaints

If you are concerned about your privacy or how we’ve handled your personal information, you can make a complaint and we’ll try to fix it. If you’re not satisfied with how we handled your complaint, you can contact the Australian Privacy Commissioner, (www.oaic.gov.au) (which is the regulator responsible for privacy in Australia).
Step 1: let us know

  • If you would like to make a complaint, you should let us know by contacting us in writing to the attention of our Compliance Manager:

    Email: Privacy@phillips-cohen.com.au,

Postal Address: Suite 1, Level 7, 60 City Road, Southbank VIC 3006

Telephone: +61 3 9118 8309

Step 2: investigation of complaint

  • Your complaint will be investigated and a response will be provided to you in writing within a reasonable period.

Step 3: contact Australian Privacy Commissioner

  • We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Australian Privacy Commissioner who can be found at the Office of the Australian Information Commissioner as follows:  

Director of Privacy Case Management
Office of the Australian Information Commissioner (OAIC)
GPO Box 5288 
Sydney NSW 2001

www.oaic.gov.au

References

Phillips & Cohen Website

Privacy Act 1988 (Cth)

www.oaic.gov.au/privacy/guidance-and-advice/handling-privacy-complaints

Responsibilities

It is the responsibility of SVP, Human Resources, and the Human Resources Manager to oversee and implement all procedures, tasks and controls associated with this Privacy Policy.