“Personal data” means information or an opinion, whether true or not and whether recordedin a material form or not, about an individual who is identified or reasonably identifiable.
In the course of providing our products and services we may collect and hold information that is reasonably necessary for the performance of our functions and activities.This information may include, but is not necessarily limited to;
We may collect Sensitive Information about you, with your consent. Sensitive information is a subset of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, health, political opinions, religion, trade union or other professional associates or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. The types of sensitive information we collect include:
Provided that you consent, your sensitive information may only be used and disclosed for purposes you have consented to or which are directly related to the primary purpose for which the sensitive information was collected, including (but not restricted to):
We may also collect, hold, use and disclose sensitive information to contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent and if otherwise required or authorised by law.
This is dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you.
Where possible we standardise the collection of personal information by using specifically designed forms (e.g. our application form). However, given the nature of our operations we often also receive personal information by email, through our website, online forms, letters, notes, in face-to-face meetings and through financial transactions.
We may also collect personal information from third parties or independent sources (including from publicly available sources such as LinkedIn, Twitter, email etc.), however, we will only do so where it is not reasonable and practical to collect the information from you directly.
We only use personal information that is reasonably necessary for one of more of our functions or activities (the primary purpose) or for related secondary purpose that would be reasonably expected by you, or to which you have consented.
Our uses of personal information include, but are not limited to:
We do not routinely disclose personal information to other organisations unless one or more of the following apply:
Personal information: We may disclose personal information (excluding sensitive information) to:
Sensitive information: We may disclose sensitive information to:
We may use GoogleAnalytics from time to time to collect and process data. You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’sAds Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device. To find out how Google uses data when you use third party websites or applications, please see here, or any other URL Google may use from time to time.
While we store personal information in Australia, where we disclose your personation information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia, including, but not limited to, New Zealand and Singapore. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.
In certain limited circumstances, your personal information may be shared with the ATO, and / or ASIC which will then exchange this information with similar overseas regulatory bodies as a result of Australia’s participation in the CommonReporting Standard and Foreign Account Tax Compliance Act.
We will provide access to personal information upon request by an individual, except in the limited circumstances in which it is permitted for us to withhold this information (for instance, where granting access would infringe another personal privacy).
You may request access to the personal information we hold about you, or request that we change the personal information, by contacting us in the manner outlined below.
You may also contact us if any of the details you have provided change or if you believe that the information we have about you is not accurate, complete or up to date.
When you make a request to access personal information, we will require you to provide some form of identification (e.g. driver’s licence or passport) so that we can verify that you are the person to whom the information relates.
If we do not agree to provide you with access or to correct your personal information you will be notified accordingly. Where appropriate we will provide you with the reasons for our decision and you may seek a review of our decision. If the rejection relates to a request to change your personal information you may make a statement about the requested change and we will attach this to your record.
You may also request that we restrict the use of your personal information for direct marketing purposes by contacting us using the contact details below. Alternatively, to unsubscribe from our email database or opt-out of communication including marketing communication) you may use the opt-out facilities provided in the communication or email us using the contact details below.
Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
If you wish to make a complaint about a breach by us to the Australian Privacy Principles, you may do so by providing your written complaint by email, letter or personal delivery to any one of our contact details as noted below. Where possible, the complaint should include enough information to help us resolve it.
We will respond to your complaint in writing within a reasonable time (usually no longer than 30 days) and we may seek further information from you in order to provide a full and complete response.
If you are not satisfied with our response to a complaint, you may lodge a complaint with the Office of the Australian Information Commissioner.
We do not charge for receiving a request for access to personal information or for complying with a correction request.
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Under the GDPR individuals located in the EU and the UK have extra rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual).
You may request details of the personal information that we hold about you and how we are process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation.
Purposes and legal bases for processing
We collect and process personal information about you only where we have legal bases for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground, we are relying on to process your personal information where more than one ground has been set out in the table below.
If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer doing business with us. Further information about your rights is available below.
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Cookies are text files placed in your computer's browser to store your preferences, provide a better user experience, and track patterns with regards to how users use our services and engage with us online. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our site and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide personal information, this information may be linked to the data stored in the cookie.
We use the following cookies:
You can find more information about the individual cookies we use, their category, and the purposes for which we use them in the table below:
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our online services.
Changes to our privacy and information handling practices