We are bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Act). The APPs came into effect on 12 March 2014, when they replaced the National Privacy Principles, which applied previously under the Act. We have adopted internal policies and procedures to ensure that personal information that we collect, store, use and disclose is dealt with in accordance with the APPs. You can see the full text of the APPs online at http://www.oaic.gov.au/privacy/privacy-act/australian-privacy-principles.
We may need to collect personal information about you and others including names, addresses, phone numbers and other contact details as well as details regarding shareholdings, employment history, bank account details, credit card information and tax file numbers.
We may need to collect personal information so we can:
If we are not provided with all the personal information we request, we may be unable to provide you with credit or do business with you or others.
Unless it is unreasonable or impractical, we will collect personal information directly from the individual concerned. However, an individual’s representatives may hold personal information (eg, financial or bank account details or a credit reference) that we may need to access for particular dealings, legal proceedings or other purposes. Where we are at liberty to do so, we will use our best endeavours to seek an individual’s consent before obtaining their personal information from third parties.
Personal information may be collected by us:
The personal information of our clients and business contacts or their representatives will usually be recorded in hard copy files designated for the purpose for which the personal information was collected and/or updated on our computer database.
Any additional purpose for which the information is collected (not included in this policy) will be identified when we collect the personal information, or as soon as practicable afterwards.
We may need to collect sensitive information about you or others. Where we are required to and it is practicable to do so, we will seek your consent before collecting your sensitive information and inform you of the purpose of the collection at that time. Your consent to collection of your sensitive information may be implied in limited circumstances.
We will use personal information:
Except where indicated above, we will not disclose personal information to a third party unless:
To ensure we are meeting the needs and requirements of our website users, and to develop our online services, we may collect aggregated information by using cookies.
Cookies are unique identification numbers like tags that are placed on the browser of our website users. The cookies do not in themselves identify users personally, but are linked back to a database record about them.
When a user visits our site a cookie may be placed on their machine. Where a user has visited us before, the cookie may be read each time they re-visit the site.
We do not use this technology to access any other personal information of a user in our records and a user cannot be personally identified from a cookie.
If a user chooses not to have their browser accept cookies from our site, they are still able to view the text on their screens.
We may use personal information to advise the individual concerned of new services and marketing initiatives that we think may be of interest to them. Those who prefer not to receive information about our services or seminars can contact us and request to be removed from the relevant circulation list. Contact details appear at the end of this policy. We will not disclose personal information to a third party to enable that party to direct market their products or services to an individual, unless that individual has expressly consented to that disclosure. We may require written confirmation of a request to be removed from our circulation list, for example where legislation requires us to provide particular communications to the individual concerned.
We ask that you tell us of any changes to the personal information we hold about you. You may notify us (contact details appear at the end of this policy) at any time to request that your personal information is amended or updated. We will then take reasonable steps to correct the information in the manner requested.
If we consider that the personal information we retain does not require amendment, we will annotate the request on our files.
The protection of personal information is a priority for us.
We are committed to maintaining:
We will destroy or de-identify any personal information that we hold which is no longer needed for any purpose permitted by the APPs unless we are required by law to retain such personal information.
We will generally allow an individual access to any personal information that we hold about them on request – subject to any restrictions on access. We will try to give the individual concerned access in a form and manner that suits their needs. To request such access please contact us. Contact details appear at the end of this policy.
We are entitled to restrict access to personal information in accordance with the APPs.
You may not be allowed access to personal information we hold where access would reveal evaluative information generated by us in connection with a commercially sensitive decision-making process. Instead, we may give you an explanation for the decision, rather than direct access to the information.
If we have given you such an explanation and you believe that direct access to the evaluative information is necessary to provide a reasonable explanation of the reasons for the decision, we will, at your request, review the decision. Personnel other than the original decision-maker will conduct the review.
Wherever direct access by you is impractical or inappropriate, we should consider together whether the use of a mutually agreed intermediary would allow sufficient access to meet both our needs and concerns.
Other instances where it may not be appropriate to provide you with access to the personal information we hold, include where:
An individual will not incur charges for lodging a request to access personal information. However, we may levy a reasonable charge for providing access to that information. We will provide an estimate of any charge on request, or if it appears to us that the work will be onerous or otherwise warrants a charge.
We typically do not transfer personal information to any entity outside Australia. However, in the event that we do disclose information to an overseas’ recipient, we will take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to the disclosed personal information unless:
We are committed to constantly improving our procedures so that personal information is treated appropriately.
If you feel that we have failed to deal with your personal information in accordance with the APPs or this policy, please speak to us so that we have an opportunity to resolve the issue to your satisfaction.
Further information about privacy and your rights can be obtained at the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.
If you wish to access any personal information that we hold about you, or have a query about this policy, please contact Jason Signmakers:
1 McDowell St Welshpool 6101
P: +61 8 6253 7112