We respect and value your privacy and acknowledge that we have an obligation at law to protect the personal information of others, including customers, employees, contractors and other individuals.
The following policy explains how and when personal information is collected, used, stored, and disclosed by us in accordance with the Privacy Act 1988 and under the Australian Privacy Principles (APP). Please refer to the Office of the Australian Information Commissioner website (www.oaic.gov.au/privacy/australian-privacy-principles) for additional details on how the APP operates.
The Privacy Act defines ‘Personal information’ as information or an opinion about an identifiable individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in material form or not.
How we collect your information (APP 1)
The main purposes for which we collect personal information are:
- for recruitment and employment (including expressions of interest in working for us);
- for administration and management purposes, including Government compliance;
- to reply to contact made by customers;
- for marketing, media and public relation purposes.
We collect personal information directly from each individual. We only collect personal information where you have consented, or you would reasonably expect us to collect personal information in that way.
Anonymity and pseudonymity (APP 2)
We will allow customers to communicate and transact with us anonymously or by using a pseudonym, wherever it is reasonable and practical.
Information collected (APP 3)
The type of information collected for employment or administrative purposes would typically include your name, date of birth, gender, contact details, email, job title and interests. Where relevant, we many ask for other information such as bank account details, tax file numbers, other financial information, driver’s licence details or details of directorships.
This is not an exhaustive list, however, unless disclosed to you prior or as required under employment conditions, we will not usually collect sensitive information (e.g. race or ethnic origins, religious beliefs, physical or mental health or sexual orientation).
For contact and marketing purposes, information retained would be in accordance with the requirements of the account or electronic app. This would likely include name and email.
Unsolicited personal information (APP 4)
If we receive personal information about you from a source other than yourself, or it is information provided by you that we did not request, we undertake to determine within a reasonable period if we could have requested such personal information under APP 3.
If we determine that we could have collected the information under APP 3, we may then use and treat that information as if we had collected the information in that manner.
If we determine that we could not have collected the information under APP 3, we will destroy or de-identify that information within a reasonable period.
Notification of the collection of information (APP 5)
When we collect information about you, we will make it clear to you, either at or before the time, or as soon as practicable afterwards, why we are collecting such information.
How we use the information (APP 6)
We will only use personal information to respond to lawful requests, to answer your enquiry, for direct marketing purposes where your information has been provided for that specific purpose, or in relation to your employment/services as an employee, director, or contractor.
The information is held only for as long as it is required to fulfil the purposes for which it was collected or as required by law.
Direct marketing (APP 7)
We will only use personal information we hold for the purpose of direct marketing if you provided this information for this specific purpose. Our direct marketing platforms include an option to opt out of receiving communications; if not actioned, direct marketing communications will continue to be utilised.
Personal information held by us will not be disclosed to third parties except with your express permission (e.g. to a supplier as a result of competition, media and public relation events).
Cross border disclosure (APP 8)
We may deal with international parties. Therefore, your information may be disclosed to overseas recipients where required by law (domestic or international).
We will take steps to maintain the security of the information and will endeavour to see that its use is consistent with this policy and our obligations under the Privacy Act. If we have to disclose your personal information, we will endeavour to advise you of the disclosure.
Email and website management
Whilst we takes steps to provide a secure internet environment, you should be aware that there are inherent risks associated with the transmission of information via the internet.
Email addresses are collected in accordance with this policy. We will record your email address when a message is sent to us. The email address will be used for the purpose for which it has been provided.
In some cases, those third-party providers may not be subject to the Privacy Act. We will not be taken to endorse or accept responsibility for any privacy issues arising as a consequence of accessing that web-link.
We use electronic cookies and we may track your Internet use on our IT network.
Use of Government related identifiers (APP 9)
We do not use Government related identifiers. We will not use or disclose a Government related identifier unless the use or disclosure of the identifier is reasonably necessary for us to fulfil any obligations we may have to a Government agency or an Australian State/Territory. It may also be required or authorised in accordance with Australian laws, Courts or Tribunals.
Quality of information (APP 10)
We will take all steps reasonable in the circumstances to ensure that personal information we collect from you is accurate, up to date and complete. Where we collect information directly from you, we rely on you to supply accurate information and we may not consider further steps are required.
Security of information (APP 11)
The Privacy Act 1988 has specific provisions that prohibit any employee of ours from collecting, using or disclosing anyone’s personal information except in performing their duties and in specific situations permitted by law. Your personal information is disclosed in accordance with the law or with your written permission.
We take all reasonable steps to ensure the integrity and security of administrative files, physical and electronic, in our possession to protect against loss, unauthorised access, misuse, disclosure or modifications and to ensure that only authorised employees have access to such material.
In the event of a data breach involving personal information, we are obliged to advise any individual where that breach is likely to result in serious harm. This is known as an ‘eligible data breach’.
This notification will include recommendations about the steps that should be taken by the impacted individuals in response to this breach. We will also notify the Australian Information Commissioner of the eligible data breach.
Access to personal information (APP 12)
We will allow you access to any personal information we may hold on to your file unless there are lawful reasons to refuse you access. Personal information can only be provided to a third party upon your written permission or if authorised by law.
In certain circumstances we may refuse access if we reasonably believe that doing so would pose a health or safety risk to any individual, have an unreasonable impact on the privacy of others, or that we consider the request to be frivolous or vexatious.
We will not release information if it relates to existing or anticipated legal proceedings between us and yourself if:
- it would be protected by legal professional privilege;
- any potential negotiations between us and yourself would be prejudiced; or
- doing so is illegal or in breach of any Court order.
If we suspect that you are involved in an unlawful activity or serious misconduct in relation to our purpose and giving you access to the information would prejudice our position, we will not release the information to you.
We will not release information if by doing so, would reveal information that is commercially sensitive to us.
Correction of personal information (APP 13)
If you believe that personal information collected by us about you is inaccurate, incomplete or not up-to-date, please contact us and we will take reasonable steps to correct it in accordance with the requirements of The Privacy Act 1988.
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