Your Privacy Is Important
Wentworth Advantage Pty Limited ABN 67 099 678 332 trading as Wentworth Advantage (we, our, us and similar) respects other people’s privacy. All our staff are required to read this policy and understand their responsibilities when dealing with personal information. This policy is designed to comply with Australian law.
In this policy:
Act means the Australian Privacy Act 1988 (Cth)
NPPs means the National Privacy Principles in the Australian Act;
personal information means any information or an opinion whether true or not, from which an individual’s identity is apparent, or can reasonably be ascertained;
sensitive information refers to information about a person’s racial or ethnic origin, political opinions or associations, religious beliefs or affiliations, philosophical beliefs, trade and professional memberships, sexual preferences or practices, criminal record or health information; and
website means our Internet site accessible from http://www.myadvantage.com.au
Our Privacy Principles
Wentworth Advantage has resolved to comply with the NPPs, and has adopted internal policies and procedures to ensure that your personal information is dealt with in accordance with the Act. You can see the full text of the NPPs and the Act online at www.privacy.gov.au.
We collect personal information about individuals including names, addresses, phone numbers and other contact details, and employer or other affiliation with our clients. We may also collect other personal information about you or others.
We collect personal information so we are able to:
• identify our clients and potential clients, and their authorised representatives;
• inform our clients and potential clients, and their authorised representatives, of marketing initiatives we think may be of interest to them;
• provide goods, services or other benefits to be offered to clients;
• conduct our business and manage our staff and other resources in a professional and efficient manner;
• develop and implement initiatives to improve our products and services.
If we are not provided with all the personal information we request, we may be unable to do business with you or others.
Where possible we will collect personal information directly from the individual concerned. However, an individual’s representatives may hold personal information (eg, employer, financial or bank account details or a credit reference) that we may need to access for particular dealings, such as creating and managing user accounts, or other purposes. Where we are at liberty to do so, we will use our best endeavours to seek an individual’s consent before obtaining their personal information from third parties.
We may collect personal information when:
• we are contacted about our products and services, in person, over the telephone or over the internet;
• we negotiate and enter into business transactions;
• we provide products and services;
• we receive an application for employment; or
• we respond to an inquiry, where we consider personal details are required or appropriate to fulfil the query.
Personal information will usually be recorded or up-dated in our records, each time we have contact with or from the individual concerned. Any additional purpose for the collection (not included in this policy) will be identified when we collect personal information, or as soon as practicable afterwards.
We generally do not need to collect “sensitive information” (as defined in the Australian Act) about individuals, however we will collect such information from applicants for employment with us. Where we are at liberty to do so, and it is practicable to do so, we will seek the consent of the individual concerned before collecting their sensitive information and inform them of the purpose at the same time.
We may use personal information:
• to identify individuals and protect them from unauthorised access to their personal information, accounts or services in our control;
• to improve our services to you or others;
• to inform you or others of our marketing initiatives and product offerings;
• conduct our business and manage our staff and other resources in a professional and efficient manner;
• to derive or aggregate anonymous information from which individuals cannot be identified;
• to prevent or lessen a threat to a person’s life or health;
• where disclosure is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim;
• for the purpose for which it was collected, or for a related purpose (or a directly related purpose in the case of sensitive information) that the individual concerned would reasonably expect from us, or to transfer our database or part to a purchaser or licensee of our business or a part; and
• for other purposes permitted, required or authorised by or under law.
We may use third party mailing/fax/email providers to help us to distribute promotional, marketing and advertising materials; third party couriers and freight handlers to help us deliver goods to our clients.
Except where otherwise indicated, we will not disclose personal information to a third party unless:
• the disclosure is for a primary purpose for which the information was collected;
• the individual concerned has consented to the disclosure;
• the third party is our agent or contractor, in which case we will require them to disclose and to use the personal information only for the purpose for which it was disclosed;
• there are reasonable grounds to believe that disclosure is necessary to prevent or lessen a threat to your life or health or that of another person;
• the disclosure is to a related body corporate of Wentworth Advantage or its subsidiaries;
• the disclosure is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim; or
• the disclosure is permitted, required or authorised by or under law.
Wentworth Advantage handles information received from visitors to our website as follows.
To ensure we are meeting the needs and wants of our website users, and to develop our online services, we collect information by using cookies.
Cookies are unique identification numbers like tags that are placed on the browser of our website users. The cookies do not in themselves necessarily identify users personally, but are linked back to a database record about the user/session. No personal information is stored within the cookie without your authorisation that this is to occur (for example, accessing an authorised user account through our website is your authorisation for us to link your user/session with personal information we collect about you).
• the address of a user’s server;
• a user’s top level domain (such as .com. or .au);
• the date and time of a user’s visit;
• the pages a user accessed and downloaded;
• the search engine a user used;
• what type of browser was used.
When a user visits our site a cookie may be placed on their machine. Where a user has visited us before the cookie may be read each time they re-visit the site.
In the case of users who are authorised by a client of Wentworth Advantage to receive our online services, we link your use of our online services back to personal information about you held in our records. We do this so we can record your use of our services and report back to our client who authorised you to use our services.
We do not use this technology to access any other personal information of a user in our records, except for users who are authorised by a client of Wentworth Advantage to receive our online services, and a user cannot be personally identified from a cookie.
Wentworth Advantage may use your IP address to assist in the diagnosis of problems with our server and to administer and monitor the use of our site. Except for users who are authorised by a client of Wentworth Advantage to receive our online services, this provides broad demographic information only and statistical input for onward development of the site.
Wentworth Advantage offers the following interactions at our website:
• Access to Technical Resources
• Access to HR Express subscription
• Request forms to ask for more information on our products and services
• Request forms for ‘HR Matters’ subscription
• Download of multimedia presentation and other marketing collateral on our products and services
Contact information resulting from use of the above services is collected for the purpose of sending information to the requestor. In addition, we may follow up to check that the information has been received and / or that the requestor has not encountered problems with any of the documentation or software received or downloaded. Further, the contact information may be used by Wentworth Advantage only, to make the requestor aware of new or updated information on Wentworth Advantage’s products and services. Such mailings offer an opt-out response mechanism enabling removal from our e-mail lists.
Wentworth Advantage reserves the right to use any ideas, concepts or know-how that are sent to us via our website, for any purpose whatsoever.
We may use personal information to advise the individual concerned of new services and marketing initiatives that we think may be of interest to them. This may include special product offerings, sale brochures, catalogues and general information about Wentworth Advantage.
Those who prefer not to receive information about our products or services can contact our Privacy Officer to be removed from the relevant circulation list. Contact details for our Privacy Officer appears at the end of this policy.
We never disclose personal information to a party outside Wentworth Advantage for the purposes of allowing them to direct market their products or service on an individual, unless that individual has expressly consented to that kind of disclosure.
We may require written confirmation of a request to be removed from our circulation list.
Correction of Records
We ask that you tell us of any changes to the personal information we hold about you.
We can be notified at any time to update personal information or to be told that the personal information we hold about you is inaccurate or incomplete. We will then take reasonable steps to correct the information in the manner requested. If we consider that the personal information we retain does not require amendment, then we will note your request to correct your personal information on our files.
The protection of personal information is a priority for us. We are committed to maintaining:
• safeguards to protect personal information against unauthorised use, disclosure, access, alteration, destruction and accidental loss. All personal information we hold is dealt with in accordance with the NPPs;
• industry standards for the security and protection of information. Personal information is stored securely and access is restricted to authorised personnel only. Our computer systems require access passwords, and these are kept secure by our personnel; and
• internal policies on management of personal information, and staff training to ensure compliance with these policies. All our staff are required to read this policy and understand their responsibilities in relation to personal information.
Access to Personal Information
We will generally allow an individual access to any personal information that we hold about them on request - subject to any Restrictions on Access. We will try to give the individual concerned access in a form and manner that suits their needs.
Contact our Privacy Officer if you wish to request access to your personal information in our records. Contact details for our Privacy Officer appear at the end of this policy.
Restrictions on Access
You may not be allowed access to personal information we hold where access would reveal evaluative information generated by us in connection with a commercially sensitive decision-making process. Instead, we may give you an explanation for the decision, rather than direct access to the information.
If we have given you such an explanation and you believe that direct access to the evaluative information is necessary to provide a reasonable explanation of the reasons for the decision, we will, at your request, review the decision. Personnel other than the original decision-maker will conduct the review.
Wherever direct access by you is impractical or inappropriate, we should consider together whether the use of a mutually agreed intermediary would allow sufficient access to meet both our needs and concerns.
Other instances where it may not be appropriate to provide you with access to the personal information we hold, include where:
• providing access would pose a serious and imminent threat to the life or health of any individual;
• providing access would have an unreasonable impact upon the privacy of others;
• the request for access is frivolous or vexatious;
• the information relates to an anticipated or existing legal dispute and disclosure would compromise our position or the position of others.
Charges for Access
An individual will incur no charges for lodging a request to access personal information. However, we may levy a reasonable charge for providing the access. We will provide an estimate of any charge on request, or if it appears to us that the work will be onerous or otherwise warrants a charge.
Overseas Transfer and Data Storage
Wentworth Advantage stores personal information within Australia and to keep our prices low we may use specialist third parties to provide secure storage facilities.
We may transfer personal information overseas, for example:
• for the purposes of data storage;
• to give effect to a request to open a new client account; or
• to amend existing accounts.
Except as otherwise indicated in this policy, we will not otherwise transfer your personal information outside Australia unless:
• we reasonably believe that the recipient of the information is subject to legal obligations that uphold principles for the protection and fair handling of personal information that are substantially similar to the principles contained inthe NPPs or IPPs (as the case may be) and this policy;
• we are given consent by the individual concerned to do so, expressly or by implication;
• we are contractually required to do so; or
• the transfer is for the benefit of the individual concerned and it is not practicable for us to obtain their consent and if they were able to grant consent, they would be likely to give it. In this instance we will advise the individual concerned to whom their information has been disclosed as soon as practicable.
Changes to our Policy
We may update or change this policy when and as we consider appropriate. When we do so, we will publish the current policy on our website.
We are committed to constantly improving our procedures so that personal information is treated appropriately.
If you feel that we have failed to deal with your personal information in accordance with the NPPs, or this policy, please speak to us so that we have an opportunity to resolve the issue to your satisfaction.
The person to contact is our Privacy Officer, whose contact details appear at the end of this policy.
Our Privacy Officer will manage the following process for us to:
• listen to your concerns and grievances regarding our handling of personal information;
• discuss with you the ways in which we can remedy the situation; and
• put in place an action plan to resolve your complaint and improve our information handling procedures if appropriate.
If this process does not result in an outcome that is satisfactory to you, you may contact the Privacy Commissioner’s Office. Where appropriate, we will work together with the relevant Privacy Commissioner’s Office to resolve the issues between us. Further information about privacy and your rights in Australia can be obtained at the Australian Privacy Commissioner’s website at www.privacy.gov.au. The contact details for the Australian Privacy Commissioner’s Office are as follows:
Street address: Level 8, Piccadilly Tower, 133 Castlereagh Street Sydney NSW 2000.
Telephone 1300 363 992 (for the cost of a local call anywhere in Australia)
TTY 1800 620 241
Post GPO Box 5218, Sydney NSW 1042
Facsimile +61 2 9284 9666
If you wish to access any personal information that we hold about you, have a query about this policy, or would like to meet with our Privacy Officer to pursue any question, comment or concern, please contact our Privacy Officer in Australia as follows:
firstname.lastname@example.org +61 2 8448 3200
Suite 7, Level 3, North Tower
1 – 5 Railway St
Chatswood NSW 2067
Privacy Officer + 61 2 8448 3299