STANLEY VALE PARTNERSHIP - POLICY ON PRIVACY
This Privacy Policy sets out the approach which Stanley Vale Partnership will take in relation to the treatment of Personal Information. It includes information on how Stanley Vale Partnership collects, uses, discloses and keeps secure, individuals' Personal Information.
This policy has been drafted having regard to Stanley Vale Partnership's obligations under the Privacy Act 1988 (including the National Privacy Principles) (the Privacy Act). Nothing in this Policy changes Stanley Vale Partnership's existing obligations under the credit reporting requirements of the Privacy Act.
It should be noted that this Policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.
1. Collection
1.1 Stanley Vale Partnership will only collect Personal Information where the information is necessary for Stanley Vale Partnership to perform one or more of its functions or activities. In this context, "collect" means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 Stanley Vale Partnership collects Personal Information primarily to supply customers with the products and services ordered from it and its related companies. Stanley Vale Partnership may use Personal Information for secondary purposes including which include:
(i) billing and account management;
(ii) business planning and product development; and
(iii) to provide individuals with information about services
1.3 Stanley Vale Partnership will notify individuals (including, but not limited to, our customers) of the matters listed below before collecting any Personal Information:
i) the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
ii) other related Uses or Disclosures that we may make of the Personal Information (Secondary Purposes);
iii) our identity and how individuals can contact us, if this is not obvious;
iv) that individuals can access the Personal Information that Stanley Vale Partnership holds about them;
v) that individuals should contact us (even if they are not a customer) if wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;
vi) the organisations or types of organisations to whom we usually Disclose the Personal Information including Related Bodies Corporates and contractors;
vii) where applicable, any law that requires the Personal Information to be collected (for example, information that is required to be collected for the Integrated Public Number Database which is used by directory publishers);
viii) the consequences (if any) for the individual if all or part of the Personal Information is not provided to Stanley Vale Partnership.
1.4 Where it is not practicable for Stanley Vale Partnership to notify individuals of all of the Collection Information before the collection of Personal Information, Stanley Vale Partnership will ensure that individuals are notified of the Collection Information as soon as possible after the collection. Stanley Vale Partnership will provide "post collection notification" in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.
1.5 Stanley Vale Partnership will not collect Sensitive Information from individuals except with consent and only where it is necessary for Stanley Vale Partnership to collect such information for an activity or function.
1.7 Stanley Vale Partnership will not collect Personal Information secretly or in an underhanded way.
1.8 Stanley Vale Partnership will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.3.
2. Use
2.1 Stanley Vale Partnership will obtain an individual's consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual's Reasonable Expectations.
2.2 Stanley Vale Partnership Uses Personal Information primarily for the purposes listed in 1.2 above.
2.3 If Stanley Vale Partnership relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:
i) individuals are clearly notified of their right to Opt Out from further Direct Marketing;
ii) there is only one Use of the information before the Opt Out right is given and this Use applies across all Stanley Vale Partnership' Related Bodies Corporate (if the information is shared between those Related Bodies Corporate);
iii) the individual is given an Opt Out in all further instances of Direct Marketing if they have not previously chosen to Opt Out; and
iv) if the individual Opts Out of all Direct Marketing the Opt Out will be respected by Stanley Vale Partnership and all its Related Bodies Corporate.
2.4 Stanley Vale Partnership will not use Sensitive Information for Direct Marketing.
2.5 Stanley Vale Partnership may use Personal Information to avoid an imminent threat to a person's life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 Stanley Vale Partnership will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
2.7 Stanley Vale Partnership will not attempt to match de-identified or anonymous data collected through surveys or such online devices as "cookies", with information identifying an individual, without the consent of the relevant individual.
3. Quality of Information
3.1 Stanley Vale Partnership will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
3.2 Stanley Vale Partnership will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.
4. Information security
4.1 Stanley Vale Partnership requires employees and contractors to perform their duties in a manner that is consistent with Stanley Vale Partnership' legal responsibilities in relation to privacy.
4.2 Stanley Vale Partnership will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Stanley Vale Partnership who have a genuine "need to know" as well as "right to know".
4.3 Stanley Vale Partnership will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
5. Glossary
Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.
Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of Stanley Vale Partnership or a Related Body Corporate or those of an independent third party organisation.
Disclosure generally means the release of information outside Stanley Vale Partnership, including under a contract to carry out an "outsourced function".
Health Information means:
(a) information or an opinion about:
(i) the health or a disability (at any time) of an individual; or
(ii) an individual's expressed wishes about the future provision of health services to him or her; or
(iii) a health service provided or to be provided to an individual; that is also personal information; or
(b) other personal information collected to provide or in providing a health service; or
(c) other personal information about an individual collected in connection with the donation; or intended donation by the individual of his or her body parts or body substances. Opt Out means an individual's expressed request not to receive further Direct Marketing.
Stanley Vale Partnership means all or any companies in the Stanley Vale Partnership group.
Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.
Reasonable Expectation means a reasonable individual's expectation that their personal information might be Used or Disclosed for the particular purpose.
Related Body Corporate means that where a body corporate is:
·a holding company of another body corporate;
·a subsidiary of another body corporate; or
·a subsidiary of a holding company of another body corporate,
the first mentioned body corporate and the other body corporate are deemed to be related to each other.
Sensitive Information means:
(a) information or an opinion about an individual's:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual preferences or practices; or
(ix) criminal record;that is also personal information or
(b) Health Information about an individual.
Use means the handling of Personal Information within Stanley Vale Partnership.
Contacting Stanley Vale Partnership
If you require further information regarding Stanley Vale Partnership's Privacy Policy, you can contact Stanley Vale Partnership Customer Service on:info@stanleyvale.com.au
