Privacy Policy

Simon Houston — Registered Migration Agent MARN 1802791 Last updated: 30 October 2026 1. About this Privacy Policy I take the privacy and confidentiality of personal information seriously. As a Registered Migration Agent, I routinely receive personal and sometimes sensitive information about clients, visa applicants, sponsors, nominators, family members, employers and other people involved in migration matters. This Privacy Policy explains how I collect, hold, use, disclose and protect personal information in connection with my migration practice and this website. I handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles where they apply. Whether or not every activity of the practice is subject to the Australian Privacy Principles, I seek to handle personal information consistently with those principles and with my professional obligations as a Registered Migration Agent. I am also subject to the Migration Agents Code of Conduct, including professional obligations concerning confidentiality, security of client documents and retention of client files. Where another privacy regime, including the General Data Protection Regulation (GDPR), applies to a particular individual or processing activity, I will comply with that regime to the extent applicable. 2. Personal information I may collect The information I collect depends on the nature of your enquiry or migration matter. It may include: ● your name, date of birth, gender and contact details; ● residential and postal addresses; ● passport and identity-document information; ● citizenship and nationality information; ● visa history, immigration status and visa conditions; ● information about previous visa applications, refusals, cancellations or review proceedings; ● family, relationship and household information; ● employment, occupation and business information; ● educational qualifications and employment history; ● skills assessment information; ● financial information relevant to a migration matter; ● information concerning sponsors, nominators and supporting organisations; ● travel history; ● government-related identifiers and reference numbers; ● photographs, identity documents and signatures; ● correspondence and communications with me; ● documents and information provided through my client portal or assessment forms; and ● information reasonably necessary to assess or provide immigration assistance. Migration matters may also require the collection of sensitive information, including information relating to health, medical history, disability, criminal or character matters, racial or ethnic origin, religious beliefs, relationships or other matters relevant to Australian migration law. I collect sensitive information only where it is reasonably necessary for the matter and where collection is permitted by law or appropriate consent has been provided. 3. Anonymous and pseudonymous enquiries Where practicable, you may make a general enquiry without identifying yourself or by using a pseudonym. However, the nature of immigration assistance generally requires me to establish the identity of the people involved and obtain accurate personal information before I can provide professional services or act in a migration matter. 4. How I collect personal information I generally collect personal information directly from you. Information may be collected through: ● telephone conversations; ● email; ● Zoom or other video consultations; ● WhatsApp, Telegram or other messaging services where used; ● my website; ● Migration Manager assessment questionnaires and client portal; ● Systeme.io enquiry, booking or payment funnels; ● documents and information you provide; ● service agreements and engagement documents; ● meetings and correspondence; ● visa, sponsorship, nomination, citizenship or other application preparation; and ● communications during the course of an ongoing matter. With appropriate authority, I may also receive information from other people or organisations involved in a matter, including: ● family members; ● partners or spouses; ● employers; ● sponsors and nominators; ● accountants or other professional advisers; ● educational institutions; ● skills assessing authorities; ● government agencies; ● police authorities; ● medical providers; ● translators or interpreters; and ● other persons you authorise to communicate with me. In appropriate circumstances I may also obtain information from publicly available sources or official government systems. 5. Why I collect and use personal information I may collect, hold, use and disclose personal information for purposes including: ● responding to an enquiry; ● assessing your circumstances and migration objectives; ● determining what migration pathways may be available; ● identifying legal, evidentiary or practical risks; ● providing immigration assistance; ● preparing and lodging applications, submissions and supporting evidence; ● communicating with the Department of Home Affairs and other relevant authorities; ● assisting with skills assessments, State or Territory nominations, sponsorships, nominations and related processes; ● conducting VEVO checks where appropriate; ● managing client relationships and professional files; ● providing invoices, receiving payments and maintaining accounting records; ● arranging consultations and appointments; ● complying with professional, regulatory and legal obligations; ● maintaining the security and administration of the practice; ● improving the operation of my website and services; and ● communicating with you about services or updates where permitted. I will not use personal information for an unrelated purpose unless you would reasonably expect that use, you have consented to it, or the use is otherwise authorised or required by law. 6. Disclosure of personal information Depending on the matter, it may be necessary to disclose personal information to third parties. These may include: ● the Department of Home Affairs; ● the Administrative Review Tribunal; ● State or Territory government agencies; ● skills assessing authorities; ● Regional Certifying Bodies or other regional authorities; ● Australian or overseas police authorities; ● medical or health assessment providers; ● educational institutions; ● employers; ● sponsors or nominators; ● translators and interpreters; ● accountants or other professional advisers; ● payment processors; ● technology, communication and cloud-service providers; and ● other organisations or persons involved in providing services connected with your matter. Where a matter involves more than one client, applicant, sponsor, nominator or other interested person, the handling and disclosure of information may also be affected by the terms of the Service Agreement, any conflict-of-interest arrangements and the authority provided by the relevant individuals. I do not sell client personal information. I do not disclose personal information merely because another person asks for it. Disclosure must be authorised, reasonably necessary for the relevant purpose, permitted by the professional engagement, or required or authorised by law. 7. Confidentiality Confidentiality is fundamental to the migration agent–client relationship. Information relating to clients, former clients and their affairs is handled in accordance with my professional obligations as a Registered Migration Agent. Information may nevertheless be disclosed where: ● you have provided appropriate written authority or consent; ● disclosure is necessary for the services you have instructed me to provide; ● disclosure is required by Australian law; or ● another lawful basis for disclosure applies. 8. Electronic storage and third-party service providers I use professional technology systems to operate the migration practice, communicate with clients, manage documents and securely store information. These currently include services such as: ● Migration Manager, including its client portal and assessment systems; ● Microsoft 365 and OneDrive; ● Dropbox; ● Adobe Acrobat Sign and related Adobe services; ● Durable, which hosts this website; ● Systeme.io, which may be used for marketing, enquiries, booking, payment and client-acquisition funnels; ● Zoom, which may be used for consultations and meetings; ● WhatsApp and Telegram, where those communication channels are used; and ● other professional technology, payment, booking, communication or cloud services used from time to time. Migration Manager states that customer data submitted to its services is stored in encrypted form in a Microsoft Azure data centre located in Australia. Third-party service providers operate their own technical infrastructure and are subject to their own privacy policies, terms and security arrangements. I take reasonable steps when selecting and using service providers to ensure personal information is handled appropriately and access is limited to what is reasonably necessary for the relevant purpose. Where you choose to communicate with me through services such as WhatsApp or Telegram, information transmitted through those platforms is also subject to the relevant provider's privacy and security arrangements. 9. Overseas processing and disclosure Some technology providers may store or process information outside Australia or permit personnel or service providers located overseas to access information. Depending on the services used, overseas processing may occur in jurisdictions including: ● Ireland and other parts of the European Union; ● the United States; ● India; and ● other jurisdictions in which relevant technology providers or their service providers operate. For example, Systeme.io currently states that its servers are hosted through Amazon Web Services in Ireland. Some other technology, communication and cloud providers operate international infrastructure. The location of technology infrastructure and service providers may change from time to time. Where Australian privacy law requires particular steps before disclosure to an overseas recipient, I will take those steps. 10. Website information, cookies and analytics When you visit this website, technical information may be collected automatically. This may include: ● your IP address; ● browser type; ● device type; ● operating system; ● pages visited; ● referring website; ● approximate location derived from technical information; ● date and time of access; and ● interactions with website pages or buttons. This information may be used for website security, performance, analytics and improvement. The website may use cookies and similar technologies. 11. Meta Pixel and advertising technologies I may use advertising and analytics technologies, including the Meta Pixel or Meta Dataset, to understand how people interact with this website and to measure the effectiveness of advertising campaigns. These technologies may collect information about website visits, page views and interactions with website buttons. I do not intentionally send the contents of Migration Manager assessment questionnaires, uploaded migration documents, detailed visa information, health or character information, or other sensitive information to advertising platforms. Where third-party tracking technology is used for targeted advertising, appropriate notice and controls will be provided. I seek to configure tracking technology in a way that minimises the personal information disclosed to advertising platforms and limits collection to information reasonably necessary for the relevant advertising or analytics purpose. You may also be able to manage advertising and tracking preferences through your browser or the relevant third-party platform. 12. Direct marketing I may occasionally communicate with current, former or prospective clients about migration services, developments or information that may be relevant to them where this is permitted by law. You may ask at any time not to receive marketing communications. Marketing emails will provide a straightforward method of unsubscribing where required. I will not use sensitive information obtained from a migration matter for targeted direct marketing without appropriate consent. 13. Testimonials, photographs and marketing material I may publish client testimonials, photographs or information describing the type of migration matter in which I provided assistance only where I have obtained appropriate permission from the person concerned. Permission to use a testimonial, photograph or information about a migration matter for marketing purposes is separate from the provision of migration assistance and may be declined without affecting the professional services provided. The extent of information published will be limited to the scope for which appropriate permission has been obtained. 14. Artificial intelligence and automated tools I may use artificial intelligence, machine-learning tools or other automated technologies to assist with tasks such as: ● document review; ● research; ● drafting; ● data analysis; ● first-pass translations; ● note-taking; and ● administrative support. AI tools are used as an aid to professional work. I do not rely solely on AI-generated output to provide migration advice or make professional decisions about a client's migration matter. Where AI tools are used in relation to client work, I take reasonable steps to limit the personal information provided where practicable and review relevant output before it is used in professional advice, correspondence or representations. Some AI service providers may process information outside Australia. Further provisions concerning the use of AI may also appear in my Terms and Conditions or Service Agreement. 15. Security of personal information I take reasonable steps to protect personal information against: ● misuse; ● interference; ● loss; ● unauthorised access; ● unauthorised modification; and ● unauthorised disclosure. Security measures may include: ● secure cloud-based systems; ● encrypted client-management and document-storage platforms; ● password protection; ● multi-factor authentication where available; ● controlled access to client information; ● secure client portals; ● device and network security controls; and ● malware, ransomware, phishing and other threat-protection measures. N o internet transmission, cloud platform or electronic storage system can be guaranteed to be completely secure. I use commercially available cybersecurity tools and security practices to reduce the risk of unauthorised access, malicious software and other digital threats. If an eligible data breach occurs, I will assess and respond to the breach and make notifications where required by applicable law. 16. Retention of information Client files are retained in accordance with the Migration Agents Code of Conduct. A migration agent is required to take reasonable steps to retain the relevant client file for 7 years after the last action on the file, subject to the provisions of the Code concerning transfer of files. Other personal information is retained only for as long as reasonably necessary for the purpose for which it was collected, or as required for legal, professional, accounting or regulatory purposes. When information is no longer required, I may securely destroy or de-identify it where appropriate and permitted by law. 17. Access to and correction of personal information You may request access to personal information I hold about you. You may also ask me to correct information that you believe is inaccurate, incomplete, out of date, irrelevant or misleading. I may need to verify your identity before providing access or making a correction. There may be circumstances in which access cannot lawfully be provided. If that occurs, I will explain the position where required. Requests should be made by email to: office@simonhouston.com.au 18. Privacy complaints If you have a concern about the way I have handled your personal information, please contact me first so that I can investigate the matter. Privacy complaints may be sent to: Simon Houston Registered Migration Agent MARN 1802791 office@simonhouston.com.au Please provide enough information for me to understand the nature of the concern. I will seek to acknowledge and deal with a privacy complaint within a reasonable period. Where the Privacy Act applies and you are not satisfied with the response, you may have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC). A concern involving my professional obligations as a Registered Migration Agent may also be subject to the regulatory framework administered by the Office of the Migration Agents Registration Authority (OMARA). 19. Links to other websites and services This website may contain links to external websites and services, including government websites, Migration Manager forms, Systeme.io pages, payment providers and other third-party platforms. Those services operate under their own privacy policies and terms. I am not responsible for the privacy practices of an external website or service merely because this website contains a link to it. 20. Changes to this Privacy Policy I may update this Privacy Policy when: ● my business practices change; ● technology providers change; ● new website or marketing technologies are introduced; or ● applicable legal or professional requirements change. The current version will be published on this website and the “Last updated” date will be revised. 21. Contact For questions about this Privacy Policy, requests for access or correction, or privacy complaints, contact: Simon Houston Registered Migration Agent MARN 1802791 office@simonhouston.com.au