The team at Communicat is committed to protecting your privacy and the personal information that we collect in the course of running our business.
This document explains the types of personal information that we may collect and hold, how that information is used and with whom the information may be shared. It also sets out how you can contact us if you have any queries or concerns regarding our policy and procedures.
This document explains:
- What information we collect;
- Why we collect it;
- Who we may disclose it to; and
- How you can contact us if you have any concerns or questions regarding the information that we hold.
2. What information we collect
We collect information such as organisation name, address, phone number, address, type of business, employee contact details, roles, notes of conversations, emails, correspondence, etc. In some cases we record conversations subject to gaining permission from the parties concerned.
3. Why we collect it
To improve our understanding of the requirements of our clients and prospective clients so that we can offer products and services which closely match the needs of our clients.
4. Who is affected by this policy?
This policy applies to all individuals except Communicat employees, who deal with our company. Employees are dealt with under separate policies specific to employment matters.
This policy affects clients of Communicat and persons with whom we participate in promotional activities and users of our websites, software and information systems.
For the purpose of convenience and brevity Communicat Business Solutions Pty Ltd is referred to in this document as “Communicat”.
Privacy Act means the Privacy Act 1988 (Commonwealth)
6. Why do we collect personal information?
We collect personal information about our customers, suppliers, contractors, job applicants and other contacts in order to understand and meet their needs, to conduct our business activities and to meet legal obligations.
7. What personal information do we collect?
The types of personal information we may collect include contact information (such as your name, address, email address, fax and telephone number), information about your employer, your communication preferences and any feedback that you provide to us about our products and services, our website, or other matters.
Communicat also collects statistical information about visitors to our website. Generally, this information cannot be used to identify particular individuals but in some circumstances it may include a visitor’s internet protocol address, which could be linked to the individual.
Personal information may be collected by way of online forms, emails, telephone conversations, online user-generated content, market research, face-to-face meetings and interviews. Where necessary and with your consent, we may also supplement the information we receive from you with information from third party sources, such as your employer.
8. What happens if you do not provide us with your personal information?
You are under no obligation to provide us with personal information requested by us, however if you choose not to provide certain personal information we may not be able to provide you with specific products and services that you require.
9. How might Communicat use and disclose your personal information?
Communicat may use and disclose your personal information for the primary purpose of collection or for reasonably expected secondary purposes which are related to the primary purpose, or for purposes to which you have consented, and in other circumstances authorised by the Privacy Act.
Generally, Communicat may use and disclose your personal information for a range of purposes, including:
- Providing you with our products or services that you have requested;
- Responding to your queries or feedback;
- Providing you with any communications or publications regarding which we think may be of interest to you, or which you have requested;
- Facilitating your participation in forums, social events and educational events; and
- Considering employment applications.
10. Disclosure of personal information to other parties
Communicat may disclose your personal information to our related companies and to third parties such as our professional advisers, our external service providers (such as distributors of communications and other publications developed by Communicat, and market research), your employer, Government, statutory or regulatory bodies. We take reasonable steps to ensure that these third parties are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
We may disclose your personal information for the purposes set out above.
We do not sell or license your personal information to third parties.
We may disclose your personal information if it is required or authorised by law, where disclosure is necessary to prevent a threat to life, health or safety, or where we are otherwise permitted by the Privacy Act.
11. Sensitive information is subject to greater restrictions
Communicat policy is that we do not collect “sensitive information”, such as information or opinions about an individual’s health, racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or membership of a trade union.
Communicat may use and disclose your sensitive information for the primary purpose of collection or for reasonably expected secondary purposes which are directly related to the primary purpose, or for purposes to which you have consented and in other circumstances authorised by the Privacy Act (e.g. where required or authorised by law to be disclosed, or where disclosure is necessary to prevent a threat to life, health or safety).
12. Security and management of personal information
Communicat will take reasonable steps to protect the personal information that we hold against misuse and loss and from unauthorised access, modification or disclosure. The methods we use to protect personal information include:
- Limiting physical access to our premises;
- Limiting access to the information we collect about you (for instance, only those of our personnel who need your information to carry out our business activities are allowed);
- Requiring any third party providers to have acceptable security measures to keep personal information secure; and
- Putting in place physical, electronic, and procedural safeguards in line with industry standards.
- If we no longer require your personal information and are not legally required to retain it, Communicat will take reasonable steps to destroy or permanently de-identify the personal information.
13. Links from our website to other websites
Our website may contain links to third party websites. We do not operate these websites and therefore we are not responsible for the collection or handling of personal information by the operators of these websites.
14. Accessing the information we hold about you
Under the APPs, you may be able to obtain a copy of the personal information that we hold about you. The APPs provide some exceptions to your rights in this regard. To make a request to access this information, please contact us in writing. We will require you to verify your identity and specify what information you require. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested.
15. Updating your personal information
We endeavour to ensure that the personal information that we hold about you is accurate, complete and up-to-date. Please contact Communicat at the contact address set out below if you believe that the information we hold about you requires correction or is out-of-date.
16. Sending information overseas
Personal information may be sent overseas in limited circumstances, including:
- Communicat employees travelling overseas; and
- External service providers that assist our organisation with market research and the distribution of our communications and other publications by Communicat.
- The countries in which recipients are likely to be located include New Zealand, Singapore, Malaysia, Philippines, USA, UK
17. Our processes ensure the security of private information
We take all reasonable precautions to protect your personal information from loss, misuse, unauthorised access, modification or disclosure.
We employ a number of means to protect your personal information:
- External and internal premises security
- Restricted access to personal information
- Maintaining a secure computer network to prevent unauthorised access
- Regular reviewing and testing of our software to ensure the level of security is maintained
- Taking reasonable steps to ensure third parties provide information security of a similar standard
- Removal of information that is no longer required.
- Communicat does not store private information in public or overseas data systems. All private data (including email) is stored on data systems that are physically located within Australia, using data systems that are under the direct management and control of Communicat.
18. Legal Jurisdiction
Communicat is bound by the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Commonwealth) (Privacy Act). The APPs are designed to protect the confidentiality of information and the privacy of individuals by regulating the methods by which personal information is collected, used, disclosed and managed.
Communicat is an Australian-owned organisation and is therefore subject to Australian Legal Jurisdiction. Any matter which arises in relation to privacy matters is subject to resolution within the legal system of the State of Victoria, Australia.
“Personal Information” refers to any information regarding an individual (for example address, phone number or date of birth).
“Sensitive Information” – refers to personal information concerning your:
- Racial or ethnic origin
- Political opinions
- Membership of a political association
- Religious beliefs or affiliations
- Philosophical beliefs
- Membership of professional, trade or other associations
20. Updates to this Policy
If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may bring a complaint internally through our complaints process or you may decide to make a formal complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au) (which is the regulator responsible for privacy in Australia).
We will deal with complaints as follows:
If you would like to make a complaint, you should let us know by contacting our Privacy Officer (see below for contact details).
Communicat Business Solutions Pty Ltd,
Level 1, 541 King Street,
Attention: The Privacy Officer
We will endeavour to respond to all complaints and correspondence promptly.
If you remain dissatisfied you can also contact the Office of the Australian Information Commissioner as follows:
Office of the Australian Information Commissioner (OAIC)
GPO Box 5218
Sydney NSW 2001
© Communicat Business Solutions Pty Ltd 2018. All rights reserved