Privacy Policy
1. Introduction
From 12 March 2014, the Australian Privacy Principles (APP’s) replaced the National Privacy Principles and Information Privacy Principles. These new principles apply to private sector organisations who deal with information relating to individuals. This legislation is designed to protect personal information about individuals and sets in place a framework and guidelines about how to deal with this information. APP 1.3 requires an APP entity to have a clearly expressed and up-to-date APP privacy policy describing how it manages personal information.
An APP privacy policy is a key tool for meeting APP 1’s requirements.
Golden Electronics is dedicated to providing robust privacy policies and procedures for its staff and clients. This includes ensuring that it conforms with all required APP’s including the provision of a clearly expressed and readily available Privacy Policy. This is completed by the provision of this Privacy Policy Manual.
To assist with this compliance, Golden Electronics ensures that all of its staff members adhere to these policies and procedures. Any breaches of these policies and procedures must be reported to the relevant staff members manager or supervisor immediately so that any appropriate measures can be taken to mitigate any issues surrounding an identified breach.
Every staff member of Golden Electronics who handles personal information is required to have an understanding of the Australian Privacy Principles (APP’s) and the objectives of the Privacy Act generally. Where a more detailed knowledge of Golden Electronics’s rights and responsibilities is required, the Privacy Officer will be able to provide assistance.
All staff are encouraged to discuss privacy issues with the nominated Privacy Officer.
Review
Formal review of this privacy policy shall be undertaken on a 6 monthly basis with the details of this review recorded by the Privacy Officer.
2. Australian Privacy Principles (APP’s)
The Privacy Act 1988 and the Credit Reporting Privacy Code 2014 places obligations and responsibilities on employers and employees to ensure that information collected from individuals is collected, retained and used in line with the APP’s. Golden Electronics shall abide by the following APP’s at all times:
APP No.
Part 1 – Consideration of personal information privacy
APP 1
Open and transparent management of personal information
APP 2
Anonymity and pseudonymity
Part 2 – Collection of personal information
APP 3
Collection of solicited personal information
APP 4
Dealing with unsolicited personal information
APP 5
Notification of the collection of personal information
Part 3 – Dealing with personal information
APP 6
Use or disclosure of personal information
APP 7
Direct marketing
APP 8
Cross-border disclosure of personal information
APP 9
Adoption, use or disclosure of government related identifiers
Part 4 – Integrity of personal information
APP 10
Quality of personal information
APP 11
Security of personal information
Part 5 – Access to, and correction of, personal information
APP 12
Access to personal information
APP 13
Correction of personal information Further information regarding the APP’s can be obtained from the office of the Australian Information Commissioner at www.oaic.gov.au.
A copy of the APP’s as produced by the Office of the Australian Information Commissioner is attached as Appendix A.
3. Types Of Personal Information That Is Collected & Held
Golden Electronics collects personal information for a variety of reasons. This personal information will be collected in the normal course of business and will relate to Goods and/or Services that are provided by Golden Electronics to consumers. This information collected will be done so in the course of business where the consumer is a client of Golden Electronics or when the consumer acts as a guarantor for another person or company that is a customer of Golden Electronics. Golden Electronics will not collect information that is not relevant or sensitive in nature unless it is required in the normal course of business.
The personal information that is collected may include, but will not be limited to the following;
1/ Full name
2/ Address
3/ Date of birth
4/ Credit references if applicable
5/ Publically available information which relate to the consumers activities in Australia
6/ Any information recorded in the National Personal Insolvency Index
7/ The consumer acknowledges that provided the correct Privacy Act disclosures have been made that Golden Electronics may conduct a credit report on the consumer for the purposes of evaluating the credit worthiness of the consumer.
8/ Driver’s license details
9/ Medical insurance details (if applicable)
10/ Electronic contact details including email, Facebook and Twitter details
11/ Next of kin and other contact information where applicable
Golden Electronics ensures that all personal information is held in a secure manner. Where applicable and to the best of Golden Electronics’s knowledge all computers or servers have the required security protections in place to safeguard and protect any personal information that is held by Golden Electronics.
Golden Electronics also regularly conducts internal risk management reviews to ensure that its infrastructure (to the best of its knowledge) is secure and any identifiable risks have been mitigated as much as they can be in the normal course of business.
4. Procedures (How Golden Electronics Handles Privacy Issues)
Golden Electronics will collect personal information in the normal course of business. This personal information may be collected (but is not limited to) by any of the following methods;
1/ Credit applications forms
2/ Work authorisation forms, quote forms or any other business documentation
3/ Publically available databases that hold information 4/ Websites that detail information such as Sensis, Facebook, Google etc
5/ By verbally asking you for information as part of normal business practices
As a consumer dealing with Golden Electronics you hereby agree and consent to the collection, use and disclosure of your personal information. In the event that you do not wish to agree or consent to any of the above use, collection and disclosure, then Golden Electronics warrants that any request by you to withdraw your consent or agreement shall be deemed as confirmation by you to cease any and/or all collection use and disclosure of your personal information. Request (by telephone and/or by email) can be made by you to Golden Electronics.
Golden Electronics will ensure that any Information that is to be obtained from you is done so using Golden Electronics’s prescribed forms which;
Authorise Golden Electronics:
1/ To collect personal information; and
2/ Inform the individual what personal information is being collected; and
3/ Inform the individual why (the purpose) the personal information is being collected; and
4/ Inform the individual why & when personal information will be disclosed to 3rd parties.
It is the responsibility of Golden Electronics to ensure that any personal information obtained is as accurate and up to date as possible and information is only collected by lawful means.
5. Purposes For Which Information Is Collected, Held, Used And Disclosed
Personal Information can only be used to:
1/ Access a credit reporter’s database for the following purposes:
a) To assess your application for a credit account; or
b) To assess your ongoing credit facility; or
c) To notify a credit reporter of a default by you; or
d) To update your details listed on a credit reporter’s database; or
2/ Check trade references noted on the prescribed form for the following purposes:
a) To assess your application for a credit account; or b) To assess your ongoing credit facility; or c) To notify a default.
3/ Forward information to a 3rd party for the purposes of debt collection.
4/ Market Golden Electronics’s products and services.
5/ Any other day to day business purposes such as complying with ATO requirements, managing accounting returns or legal matters.
Relationship with Credit Reporter – In the event that notification of a default has been reported to a Credit Reporter and your credit file has been updated (including any changes to the balance outstanding or contact details), then the Credit Reporter shall be notified as soon as practical of any such changes.
Golden Electronics will only gather information for its particular purpose (primary purpose). Golden Electronics will not disclose this information for any other purpose unless this has been agreed to by both parties.
6. How An Individual May Access Personal Information Held, And How They May Seek Correction Of Such Information
You shall have the right to request from Golden Electronics a copy of all the information about you that is retained by Golden Electronics. You also have the right to request (by telephone and/or by e-mail) that Golden Electronics correct any information that is incorrect, outdated or inaccurate.
Any requests to receive your personal information or to correct personal information should be directed to the following contact details;
The Privacy Officer
Golden Electronics
282a Murray Street
Hobart TAS 7000 golden.office@goldenelectronics.com.au
(03) 6231 1277
Golden Electronics will destroy personal information upon your request (by telephone and/or by e-mail) or when the personal information is no longer required. The exception to this is if the personal information is required in order to fulfil the purpose of Golden Electronics or is required to be maintained and/or stored in accordance with the law
7. How An Individual May Complain About A Breach Of The APP, And How The Complaint Will Be Dealt With
You can make a complaint to Golden Electronics’s internal dispute resolution team (‘IDR’) regarding an interference with and/or misuse of your personal information by contacting Golden Electronics via telephone or e-mail.
Any complaints should be directed to the following contact details in the first instance;
The Privacy Officer
Golden Electronics
282a Murray Street
Hobart TAS 7000 golden.office@goldenelectronics.com.au
(03) 6231 1277
In your communication you should detail to Golden Electronics the nature of your complaint and how you would like Golden Electronics to rectify your complaint.
We will respond to that complaint within 7 days of receipt and will take all reasonable steps to make a decision as to the complaint within 30 days of receipt of the complaint.
We will disclose information in relation to the complaint to any relevant credit provider and or CRB that holds the personal information the subject of the complaint.
In the event that you are not satisfied with the resolution provided, then you can make a complaint to the Information Commissioner on the OAIC website at www.oaic.gov.au
8. Will Personal Information Be Disclosed To Overseas Recipients
Golden Electronics does not disclose information about the consumer to third party overseas recipients unless specifically agreed to by both parties in writing. Golden Electronics will notify you if circumstances change regarding overseas disclosure and will comply with the Act in all respects
Unless otherwise agreed, Golden Electronics agrees not to disclose any personal information about the Buyer for the purpose of direct marketing. You have the right to request (by telephone and/or by e-mail) that Golden Electronics does not disclose any personal information about you for the purpose of direct marketing
9. Availability Of This Privacy Policy Manual
This Privacy Policy manual is available to all customers of Golden Electronics. It will be made available (where applicable) on Golden Electronics’s website.
This manual will also be available upon request at Golden Electronics’s business premises and is available to be sent to you if required.
If you require a copy of this Privacy Policy please make a request utilising the following contact information in the first instance;
The Privacy Officer
Golden Electronics
282a Murray Street
Hobart TAS 7000 golden.office@goldenelectronics.com.au
(03) 6231 1277
10. Privacy Officer (Responsibilities)
Golden Electronics has appointed an internal Privacy Officer to manage its privacy matters. The name of this officer is available by making contact with Golden Electronics.
The privacy officers duties include (but are not limited to) the following; The Privacy Officer needs to be familiar with the APP’s. Educational material is available from the office of the Privacy Commissioner which explains what Golden Electronics needs to know in order to comply with the Privacy Act.
If a person complains to the Privacy Commissioner that Golden Electronics has breached their privacy, the Information Commissioner may contact the Privacy Officer to discuss the complaint, and to see whether there is any means of settling the matter. The Privacy Officer shall provide whatever assistance is necessary. The Privacy Officer may be asked to provide background information or identify the staff members who can do so.
Complaints
In the event that a complaint about privacy issues is received the Privacy Officer will:
1/ Take ownership of the complaint and ensure that it is dealt with in a timely manner.
2/ Acknowledge receipt of the complaint within 24 hours and advise the complainant of their rights.
3/ Fully investigate the complaint.
4/ Respond, with findings, to the complainant within 30 days of receipt.
5/ Keep a record of all complaints received for ongoing review of policies and procedures.
In the event that a complaint about privacy issues is received via a credit reporter the Privacy Officer will:
1/ Take ownership of the complaint and ensure that it is dealt with in a timely manner.
2/ Acknowledge receipt of the complaint to the credit reporter within 24 hours.
3/ Fully investigate the complaint.
4/ Respond, with findings, to the credit reporter within 7 days of receipt. Golden Electronics – Privacy Policy Manual Page 11 Copyright – EC Credit Control 1989 – 2014
5/ Keep a record of all complaints received for ongoing review of policies and procedures