3. Policy and Procedure

What Information do we Hold and Collect?

We collect Personal Information, including Sensitive Information. Examples of the types of Personal Information we collect include names, postal addresses, other contact details such as email address, financial details such as a credit card number, transaction history and products and service preferences.

How do we Collect Your Personal Information?

We collect personal information in several ways and how we collect personal information from you will depend on how you use our services.

For example, we may collect personal information about you when you deal with us over the telephone, enter into an agreement with us or send us correspondence (whether by letter, fax or email), visit our web site, have contact with us in person or via any other mode of communication.

Where possible, we will collect this information directly from you. However, there may be times where we collect personal information from a third party that you have authorised to provide the information, or from a client or third party where it is unreasonable or impracticable to collect the information directly from you.

From time to time, we may receive personal information that we have not requested (unsolicited personal information). If we receive unsolicited personal information, then we will determine if we could have collected the information under privacy laws if we had solicited the information. If we determine that we could have collected the information under privacy laws, then we will keep the information and will comply with our legal requirements in relation to the information.  If we determine that we could not have collected the personal information under privacy laws, then we will destroy or de-identify it as soon as practicable (subject to it being lawful and reasonable for us to do so).

Where practicable and legal we will allow persons to remain anonymous or to use a pseudonym, when dealing with us, however we will generally need your name and contact information to be able to respond to questions and requests and to provide you with our services.

We do not collect Sensitive Information without your consent, except in the limited circumstances permitted by the APPs.

How do We Use and Disclose Your Personal Information?

We only use and disclose personal information for the purpose which we collected it (the primary purpose) unless:

• you have given us permission to use or disclose the information for another purpose;
• you would reasonably expect us to use or disclose the information for another purpose and:
  • if the information is sensitive information, the purpose is directly related to the primary purpose; or
  • if the information is not sensitive information, the purpose is related to the primary purpose;
• the use or disclosure is required or permitted under Australian law or by a court or tribunal order; or
• we reasonably believe that the use or disclosure is reasonably necessary:
  • to lessen or prevent a serious threat to the life, health or safety of any individual or to public health or safety;
  • to take appropriate action in relation to suspected unlawful activity or serious misconduct;
  • for any other legal purpose.

Generally, a primary purpose for us using and disclosing personal information would include:

• the purpose of dealing with your request, enquiry, contractual dealing or otherwise providing you with services;
• contacting clients, business contacts and individuals associated with providing services or business dealings with us;
• marketing our services, including through subscription services;
• assessing job applicants; and
• providing information to service providers who assist us in operating our business. These organisations are required to comply with the principles of this policy.

Assessing and Correcting Personal Information

We take all reasonable steps to ensure that the personal information that we collect, hold, use and disclose is up to date, complete and relevant.

You may request access to personal information we hold about you by contacting the Privacy Officer using the details listed at the end of this policy. You may also use these details to request corrections be made to that information.

We will generally provide you with access to any personal information we hold about you on request. In limited circumstances, however, access may be refused if required or permitted by law. If we do not provide you with access, we will explain the reasons for our refusal in writing. We will not unreasonably refuse requests to access personal information and we will respond to requests for access within a reasonable time.

We will not charge you for making an application to access your personal information but may charge a reasonable fee to cover the cost of giving access, such as photocopying costs. We will advise you if such a charge applies before your request is dealt with.

How Do We Secure Personal Information?

Your personal information is held on databases and physical files. We take appropriate measures to keep your personal information secure and prevent it from misuse, interference, loss, unauthorised access, modification or disclosure.

If we outsource services involving the use of personal information, we will take steps to ensure the protection of your personal information.

Website

In the course of using our website, you may provide us with personal information. We take all reasonable steps to ensure its security within our own system.

Sending Personal Information Overseas

We may disclose personal information to overseas recipients (including to recipients located in the Philippines). Before disclosing personal 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 information.

We will be accountable for the overseas recipient’s acts or practices in relation to the information that would breach the APPs. We will also only disclose personal information for the primary purpose for which it was collected.

Complaints

Any complaints or concerns relating to privacy should be directed to our Privacy Officer as follows:

Phone: 0409 972 543

Email: sandra.costanzo@symal.com.au

Mail: 208-210 Hall Street, Spotswood Vic 3015

If a person receives our response to a complaint and is unsatisfied, then they may refer their complaint to the Office of the Australian Information Commissioner as follows:

By telephone: 1300 363 992

By writing:       Director of Complaints, Office of Federal Privacy Commissioner,

GPO Box 5288, Sydney NSW 1042

Online:             www.oaic.gov.au