The Network treats the handling of your personal information very seriously. To that end, the Network has systems and procedures in place to protect your privacy in relation to the handling of your personal information.
The Network abides by the Australian Privacy Principles (“APPs”), which provide a scheme in relation to the collection, disclosure, use and storage of personal information. The Network’s objective is to handle information responsibly and provide you with some control over the way information about you is handled.
1. Collection of Personal Information
Personal information is information or opinion about an 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 a material form). The nature of personal information collected by the Network generally comprises an individual’s name, address, phone number, fax, e-mail address, birth date and gender, as well as interests and information about your transactions with us and with some of our business partners.
The primary purpose for collecting such information is to arrange, conduct and promote the Network’s activities and provide you with requested products and services.
The Network may collect personal information from you in a number of ways. These include, but are not limited to situations in which you set up an account with a company within the Network (for example a membership), request to receive products or services from the Network, provide products or services to the Network, enter a competition or voting forum, utilise the Network’s services, complete a survey or questionnaire, or when you communicate with the Network by telephone, fax, writing, email, or any other electronic means.
Whilst the Network will attempt to ensure all transfer of data to a third party and use by a third party is secure, the Network cannot be held responsible for the theft of data by a third party, or the consequences resulting from the loss of data where that loss is associated with the technical malfunction, tampering by a third party, viruses, computer bugs, or any action or event beyond the reasonable control of the Network.
The Network does not collect personal information unless it is reasonably necessary for the Network to perform one or more of its functions and activities or supply one or more of its services. On occasion, some of this personal information may be sensitive and the Network will only collect it with your consent or when required or authorised to by law.
The Network or its agents will generally collect personal information from you directly. For example, the Network may collect personal information when you complete a survey, become a member, attend a function or event, enter a competition, make a purchase, or enter an agreement.
There may be other occasions when the Network needs to source personal information from third parties such as credit agencies and recruitment agencies. If we do this, we will use reasonable efforts to notify you afterwards.
You may choose to deal with the Network anonymously or under a pseudonym where lawful and practicable (i.e. provided we are still able to provide the relevant service or do business with you without that information). For example, it might not be practical to deal with you anonymously if we need to process a payment, deliver goods or services or send personalised communications to you.
2. Use & Disclosure of Personal Information
Personal information provided to the Network may be shared with related companies within the Network. The Network takes all reasonably practical steps to keep such information strictly confidential.
The Network may use and disclose your personal information for the purpose for which it was initially collected, namely to arrange, conduct and promote the Network’s activities and provide you with requested products and services (and renewals thereof), as well as all purposes necessary and incidental to the provision of goods or services by the Network or by anyone on behalf of the Network.
In addition, the Network may use and disclose your personal information for purposes related to the initial purpose of collection if that other purpose would be within your reasonable expectations. Related purposes include analysing your personal information for the purpose of identifying and referring you to products and services and/or activities that may be of benefit or interest to you, improving our services, conducting research, contacting you, internal auditing and administration, adding your name to a guest list or invitation list, or assisting the Network to carry out auditing, administration, or product/service enhancement. Without limiting the foregoing, your personal information may be used to create an anonymous link to additional third party data (for example the data of our business partners) for the purpose of tailoring information you may be more interested in, and that link may be placed in cookies for the purpose of the Network and its business partners sending you targeted advertising when you use websites or other services over the internet, including those supplied to you by the Network as well as by third parties unaffiliated with the Network.
Additionally, in the event of a re-organization, merger or sale, the Network may transfer any and all personal information we have collected from you to the relevant third party. The Network may also be required to disclose your personal information without your consent if the disclosure is:
- required or authorised by law;
- required in order to investigate an unlawful activity;
- required by an enforcement body for investigative activities; or
- necessary to prevent a serious and imminent threat to a person’s life, health or safety, or to public health or safety.
Like most organisations, the Network performs some of its functions under licence and also contracts out some functions and relies on third party suppliers to conduct specialised activities such as website management, mail out services, call centre services, data analysis and processing services, supply of equipment and travel and hospitality services.
Whilst personal information may be provided to these licensors and suppliers in order to enable them to perform the agreed tasks, the Network will make every effort to ensure that the supplier handles the personal information in accordance with the Australian Privacy Principles and confidentiality principles. The Network will require all such suppliers to provide privacy undertakings and enter confidentiality agreements.
3. Direct marketing
From time to time the Network may use your personal information to identify programs, products and services that may be of interest to you. The Network may use your personal information to send you information regarding the Network’s programs, products and services, and those available through the Network’s business partners.
From time to time, the Network may also provide your personal information to carefully selected third parties for the purpose of them providing you with information regarding products and services specific to your needs, and to help the Network conduct product enhancement activities.
If you do not wish to receive direct marketing information from the Network or third parties (as applicable) as outlined in this section, please let the Network know by using the unsubscribe function in the communication you receive, or alternatively by contacting email@example.com The Network will take immediate steps to ensure that you do not receive any such direct marketing information in future.
4. Personal Information Quality
The Network’s objective is to ensure that all personal information collected by the Network is accurate, complete and up-to-date. To assist the Network in achieving its objective, please contact the Privacy Officer if any of your details change. Further, if you believe that the information the Network holds is not accurate, complete or up-to-date, please contact the Privacy Officer, Pam Herron on firstname.lastname@example.org in order to have the information corrected.
5. Personal Information Security
The Network is committed to keeping your personal information secure, and we will take reasonable precautions to protect your personal information from unauthorised access, loss, release, misuse or alteration.
Your personal information may be stored in hard copy documents, but is generally stored electronically on the Network’s software or systems.
The Network maintains physical security over its paper and electronic data stores, such as locks and security systems. The Network also uses computer and network security technologies such as firewalls, intrusion prevention software, antivirus software, external email filtering and passwords to control and restrict access to authorised staff for approved purposes and to secure personal information from unauthorised access, modification, disclosure, misuse and loss.
Whilst the Network takes all reasonable steps to secure your personal information from loss, misuse and unauthorised access, you acknowledge that all activities in which you intentionally or unintentionally supply information to the Network carries an inherent risk of loss of, misuse of, or unauthorised access to such information. The Network cannot be held responsible for such actions where the security of the personal information is not within the control of the Network, or where the Network cannot reasonably prevent such incident.
Additionally, you acknowledge that the collection and use of your personal information by third parties may be subject to separate privacy policies and/or the laws of other jurisdictions.
6. Access To Personal Information
You may request access to the personal information the Network holds about you.
The procedure for gaining access is as follows:
a) All requests for access to your personal information must be made in writing and addressed to the Privacy Officer.
b) You must provide as much detail as possible regarding the business entity, department or person to whom you believe your personal information has been provided, and when. This will allow the Network to process your request faster.
c) The Network will acknowledge your request within 30 days, and access will usually be granted within 30 days, or if it is more complicated, 60 days. The Network will inform you if this timeframe is not achievable.
d) You will be asked to verify your identity.
e) A fee may apply to such access in the event that a request for access is onerous or time consuming. Such a fee will cover staff costs involved in locating and collating information, and reproduction costs.
f) Depending on the circumstances, you may be forwarded the information by mail or email, or you may be required to personally inspect your records at the appropriate place.
g) You will be given the opportunity to correct any personal information that is no longer accurate.
In some circumstances, the Network may not be in a position to provide access. Such circumstances include the following:
- access would create a serious threat to safety;
- providing access will have an unreasonable impact upon the privacy of other individuals;
- denying access is required or authorised by law;
- the request is frivolous or vexatious;
- legal proceedings are underway or anticipated, and the information would not be accessible through the process of discovery in the proceedings;
- negotiations may be prejudiced by such access;
- providing access is likely to prejudice law enforcement;
- providing access is likely to prejudice action being taken or to be taken with respect to suspected unlawful activity or serious misconduct relating to the Network’s functions or activities; or
- access would reveal a commercially sensitive decision making process.
If the Network denies access to your personal information, it will provide you with reasons in writing.
7. Changes To This Policy
The Network may, without notice, change this Policy from time to time for any reason and will update the Policy accordingly. We ask that you visit our website periodically in order to remain up to date with such changes.
If you believe that your privacy has been infringed or a breach of the APPs has occurred, you are entitled to complain. All complaints should initially be in writing and directed to the Privacy Officer. The Network will respond to your complaint as soon as possible, within 14 working days, to let you know who is responsible for managing your query. The Network will try to resolve the complaint within 30 working days. When this is not possible the Network will contact you to provide an estimate of how long it will take to handle the complaint.
If you believe the Network has not adequately dealt with your complaint, you may complain to the Privacy Commissioner whose contact details are as follows:
Officer of the Australian Information Commissioner (OAIC) Phone: 1300 363 992 Email: email@example.com GPO Box 5218 Sydney NSW 2001
9. Privacy Officer’s Contact Details
Please address all written correspondence to the Privacy Officer:
Pam Herron, c/- Beaufort Street Network P.O. Box 698, Mt Lawley 6929