Privacy

Who this policy covers

This policy explains how Way Group Pty Ltd, ABN 79 689 468 184, trading as Way Group Migration Services, handles personal information. In this policy "we", "us" and "our" mean that entity.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

Migration advice is provided by Fernanda Maia, Registered Migration Agent, MARN 2418447, who is also bound by the Migration Agents Code of Conduct.

What we collect

Through this website we collect:

Your name, email address, phone number and the content of your message, when you send us an enquiry.

Your email address, when you subscribe to our newsletter or download a free resource such as the Partner Visa checklist.

Your name, email address, and the information you provide in the booking form and the Pre-Consultation Information Form, when you book a consultation. This can include your visa status, your immigration history and other details about your circumstances.

Technical information about your visit, such as your IP address, browser, device type and the pages you viewed.

If you go on to become a client, we collect considerably more, including identity documents, qualifications, employment history, health and character information, and relationship evidence. That collection happens through our client process, not through this website, and it is governed by your service agreement as well as by this policy.

Sensitive information

Some of what a migration matter requires is sensitive information under the Privacy Act, including health information and information about criminal history. We collect it only where it is reasonably necessary for your matter, and only with your consent, which is normally given in your service agreement. Please do not send sensitive information through the website enquiry form. Wait until we have opened a file for you.

Why we collect it

We use personal information to answer your enquiry, to arrange and hold your consultation, to assess your eligibility, to prepare and lodge applications on your behalf, to deal with the Department of Home Affairs, the Administrative Review Tribunal and other bodies, to issue invoices and collect payment, to meet our record-keeping obligations as a registered migration agent, and to send you the newsletter if you have asked for it.

We do not sell personal information, and we do not share it with anyone for their own marketing.

Who we disclose it to

We disclose personal information to:

The Department of Home Affairs and other Australian government agencies, where that is what your matter requires.

Skills assessing authorities, state and territory nominating bodies, English language test providers and translators, where your matter requires it.

Our service providers, who host this website, run our customer relationship system, send our email, process payments and store our files.

Anyone else you have asked us to deal with, such as your employer or your sponsor.

We also disclose personal information where the law requires it.

Our service providers, and where your information is stored

We use the following providers, and some of them store information outside Australia:

Duda, which hosts this website, in the United States.

HubSpot, which runs our customer relationship system, our booking system and the forms embedded on this website, in the United States and the European Union. When you fill in a form on this site, or book a consultation, the information goes to HubSpot as well as to us.

Google, which provides the analytics on this website, in the United States and other countries.

Stripe, which processes card payments, in the United States and Australia.

Australian Privacy Principle 8 requires us to tell you that these are overseas disclosures, and to take reasonable steps to make sure overseas recipients handle your information consistently with the Australian Privacy Principles. We do that by using established providers that publish their own privacy commitments and contract on those terms. You should understand that once information is held overseas, Australian law may not be enforceable against that provider in the same way, and we cannot control what a foreign government may lawfully require of them.

Cookies and analytics

This website uses cookies. Some are necessary for the site to work. Others are set by our analytics and by the HubSpot forms and booking tool, and they help us understand how people find and use the site.

You can block or delete cookies in your browser settings. If you do, parts of the site, including the booking tool, may not work properly.

We do not use the information from analytics to identify individual visitors.

Direct marketing

If you subscribe to our newsletter we will send you occasional emails. Every one of them has an unsubscribe link, and unsubscribing takes effect promptly. We will not add you to the newsletter simply because you sent us an enquiry, or because you became a client.

How we keep it

We store client files and enquiry records in our customer relationship system and in cloud storage, protected by access controls and multi-factor authentication. Access is limited to the people in our team who need it for your matter.

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

How long we keep it

We keep your client file for seven years after the last action on your matter. That period is set by regulation 56 of the Migration (Migration Agents Code of Conduct) Regulations 2021, which also sets out what the file has to contain: your application, your service agreement, our written and oral communications about your matter, invoices and receipts, and the personal documents you gave us.

Financial records are kept for five years, as Australian tax law requires.

Enquiries that do not become matters are kept for a shorter period and then deleted.

Accessing and correcting your information

You can ask us for a copy of the personal information we hold about you, and you can ask us to correct it if it is wrong. Email contact@waygroup.com.au and we will respond within a reasonable period.

We will normally give you access. Where we refuse, we will tell you why in writing, and we will tell you how to complain about that decision.

There are limited situations where we cannot give access, for example where doing so would reveal personal information about someone else.

Complaints

If you think we have mishandled your personal information, email contact@waygroup.com.au with the details. We will acknowledge your complaint and respond in writing.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au, or by phone on 1300 363 992.

Complaints about the conduct of a registered migration agent are handled separately, by the Office of the Migration Agents Registration Authority at mara.gov.au.