1.1 We provide packaging, strapping, wrapping and associated products for customers throughout Australia. We have offices in Brisbane, Sydney and Melbourne.
1.3 We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. Our commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles which set out the way in which personal information must be treated.
1.5 This policy applies to any person for whom we currently hold, or may in the future collect, personal information.
1.6 Generally, we only collect personal information from customers and from prospective employees.
1.7 This policy applies to personal information. In broad terms, ‘personal information’ is information or opinions relating to a particular individual who can be identified.
1.8 Information is not personal information where the information cannot be linked to an identifiable individual.
2. HOW DO WE MANAGE THE PERSONAL INFORMATION WE COLLECT?
2.1 We manage the personal information we collect in numerous ways, such as by:
(a) implementing procedures for identifying and managing privacy risks;
(b) implementing security systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure;
(c) providing staff with training on privacy issues;
(d) implementing procedures for identifying and reporting privacy breaches and for receiving and responding to complaints;
(e) appointing a privacy officer within the business to monitor privacy compliance; and
(f) allowing individuals the option of not identifying themselves, or using a pseudonym, when dealing with us in particular circumstances.
2.2 We will take reasonable steps to destroy or permanently de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.
2.3 In limited circumstances, it may be possible for you to use a pseudonym or remain anonymous when dealing with us (for example, when making a general enquiry with us). However, if you would like to order a product or service from us, we will need your personal information in most instances in order to supply you with the product or service.
3. WHAT KINDS OF INFORMATION DO WE COLLECT AND HOLD?
3.1 We may collect and hold personal information about you, which may include:
(a) contact information;
(b) financial information;
(c) date and place of birth;
(e) employment arrangements and history;
(f) tax file numbers;
(g) credit information;
(h) banking details; and
(i) any other personal information required to provide the product or service to you.
3.2 ‘Sensitive information’ is a subset of personal information and includes personal information that may have serious ramifications for the individual concerned if used inappropriately.
3.3 We generally do not collect sensitive information about individuals.
4. HOW AND WHEN DO WE COLLECT PERSONAL INFORMATION?
4.1 Our usual approach to collecting personal information is to collect it directly from you.
4.2 We may also collect personal information in other ways, which may include:
(a) through our website;
(b) from government bodies (such as the Australian Taxation Office and the Australian Securities and Investment Commission);
(c) through referrals from individuals or other entities;
(d) from trade references;
(e) from third party providers and suppliers; and
(f) from employers, colleagues, associates or relatives of yours (where necessary, we will make reasonable enquiries to verify the information).
5. HOW DO WE HOLD PERSONAL INFORMATION?
5.1 We generally hold personal information:
(a) physically, at our premises (securely); and
(i) on secure online servers; and
(ii) by a third party data backup provider.
5.2 We secure the personal information we hold in numerous ways, including:
(a) using security systems to access areas that contain personal information;
(b) using secure servers to store personal information;
(c) using unique usernames, passwords and other protections on systems that can access personal information; and
(d) regularly destroying documents that are no longer needed subject to legal obligations for record keeping.
6. WHY DO WE COLLECT, HOLD, USE OR DISCLOSE PERSONAL INFORMATION?
6.1 We take reasonable steps to use and disclose personal information for the primary purpose for which we collect it. The primary purpose for which we collect your information is generally to provide you with our products or services. A full range of the products and services we offer can be found at www.pakall.com.au.
6.2 In the case of potential employees, the primary purpose the information is collected is to assess the individual’s suitability for employment.
6.3 Personal information may also be used or disclosed by us for secondary purposes which are within your reasonable expectations and which are related to the primary purpose of collection. For example, we may collect and use your personal information:
(a) to keep record of transactions to assist in future enquiries and enhance our customer relationship with you;
(b) for delivery purposes; and
(c) to assess your eligibility for credit.
6.4 We may disclose personal information to:
(a) government bodies (such as the Australian Taxation Office);
(b) business support service providers (for example our software suppliers, data backup provider, law and accounting firms or other consultants); and
(c) any other third party we deem necessary in connection with providing you with the products or services.
6.5 Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act.
7. WILL WE DISCLOSE PERSONAL INFORMATION OUTSIDE AUSTRALIA?
We do not disclose personal information outside of Australia.
8. HOW DO WE MANAGE YOUR CREDIT INFORMATION?
What kinds of credit information may we collect?
8.1 In the course of providing products or services to you, we may collect and hold the following kinds of credit information:
(a) your identification information;
(b) information about any credit that has been provided to you;
(c) your repayment history;
(d) information about your overdue payments;
(e) if terms and conditions of your credit arrangements are varied;
(f) if any court proceedings have been initiated against you in relation to your credit activities;
(g) information about any bankruptcy or debt agreements involving you;
(h) any publicly available information about your credit worthiness; and
(i) any information about you where you may have fraudulently or otherwise committed a serious credit infringement.
8.2 We may also collect personal information which may affect your credit worthiness from other credit providers (such as your trade referees), who have collected that information from a credit reporting body. The kinds of personal information we collect may include any of those kinds of personal information outlined in section 3.1 of this policy.
How and when do we collect credit information?
8.3 In most cases, we will only collect credit information about you if you disclose it to us.
8.4 Other sources we may collect credit information from include:
(a) other credit providers (e.g. your trade referees);
(b) other individuals and entities via referrals; and
(c) government bodies.
How do we store and hold the credit information?
8.5 We store and hold credit information in the same manner as outlined in section 5 of this policy.
Why do we collect the credit information?
8.6 Our usual purpose for collecting, holding, using and disclosing credit information about you is to enable us to provide you with the requested product or service.
8.7 We may also collect the credit information:
(a) to process payments;
(b) to assess eligibility for credit; and
(c) for any other purpose that we consider necessary to best provide you with the relevant service or product.
Overseas disclosure of the credit information
8.8 We will not disclose your credit information to entities without an Australian link unless you expressly request or authorise us to.
How can I access my credit information, correct errors or make a complaint?
8.9 You can access and correct your credit information, or complain if you believe there has been a breach of your privacy in the same manner as set out in section 9 of this policy.
9. HOW DO YOU MAKE COMPLAINTS AND ACCESS AND CORRECT YOUR PERSONAL INFORMATION OR CREDIT INFORMATION?
9.1 It is important that the information we hold about you is up-to-date. You should contact us if your personal information changes.
Access to information and correcting personal information
9.1 You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.
9.2 Subject to section 9.4, we will grant you access to your personal information as soon as possible.
9.3 In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.
9.4 We may deny access to personal information if:
(a) the request is unreasonable;
(b) providing access would have an unreasonable impact on the privacy of another person;
(c) providing access would pose a serious and imminent threat to the life or health of any person; or
(d) there are other legal grounds to deny the request.
9.5 We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.
9.6 If the personal information we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, where it is appropriate to do so.
9.7 If you wish to complain about an alleged privacy breach, you must follow the following process:
(a) The complaint must be firstly made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint.
(b) In the unlikely event the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.
Who to contact
9.8 A person may make a complaint or request to access or correct personal information about them held by us. Such a request must be made in writing to the following address:
Privacy Officer: Sheree Paynter
Postal Address: PO Box 391, Acacia Ridge, QLD, 4110
Telephone number: 07 3711 4444
Email address: firstname.lastname@example.org
10. CHANGES TO THE POLICY
10.2 This policy is effective April 2015. If you have any comments on the policy, please contact the privacy officer with the contact details in section 9 of this policy.