South Pacific Realty (“SPR”, “We”, “Us”) is committed to respecting your right to privacy and protecting your personal information.
We are bound by the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles set out in the Act.
We will ensure that all officers, employees and subcontractors are aware of and understand SPR’s obligations as well as their own obligations under the Act. We will achieve this through the provision of training and through maintaining and implementing internal policies and procedures to prevent personal information from being collected, used, disclosed, retained, accessed or disposed of improperly.
This Policy applies to all your dealings with us, whether in person, or via telephone, email, correspondence or our website.
The purpose of this Policy is to:
- Give you a better and more complete understanding of the kinds of personal information we collect and hold;
- Clearly and concisely communicate how and when we collect, disclose, use, store and otherwise handle personal information;
- Inform you about the purposes for which we collect, hold, use and disclose personal information;
- Provide you with information about how you may access your personal information, and seek correction of your personal information;
- Provide you with information about how you may make a complaint, and how we will deal with any such complaint;
- Advise you of the circumstances in which we are likely to disclose personal information to overseas recipients; and
- Enhance the transparency of our operations.
For the purpose of this Policy, the following terms will have the following meanings, as attributed to them by section 6 of the Act:
Health information means:
- Information or an opinion about:
- The health or disability (at any time) of an individual; or
- An individual’s expressed wishes about the future provision of health services to him or her; or
- A health service provided, or to be provided, to an individual;
that is also personal information; or
- Other personal information collected to provide, or in providing, a health service; or
- Other personal information about an individual collected in connection with the donation, or intended donation, by the individual of his or her body parts, organs or body substances; or
- Genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual.
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
Sensitive information means:
- Information or an opinion about an individual’s:
- Racial or ethnic origin; or
- Political opinions; or
- Membership of a political association; or
- Religious beliefs or affiliations; or
- Philosophical beliefs; or
- Membership of a professional or trade association; or
- Membership of a trade union; or
- Sexual orientation or practices; or
- Criminal record
that is also personal information; or
- Health information about an individual; or
- Genetic information about an individual that is not otherwise health information; or
- Biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
- Biometric templates.
Collection of Personal Information
Whenever you deal with SPR, we will collect personal information in order to provide or prospectively provide, services and products to you. Such services and products include:
- professional development and nationally recognised training services;
- complaint resolution services;
- recruitment services;
- payroll services to members;
- membership services;
- advisory services;
- updates about events, products and services which may be of interest to you
- other products and services you may wish to purchase.
We do not collect personal information unless it is reasonably necessary for, or directly related to, one or more of the services we provide or functions we carry out.
The types of personal information we generally collect includes but is not limited to:
- Date of birth.
- Residential address.
- Business address.
- Postal address.
- Email address.
- Home telephone number.
- Work telephone number.
- Mobile telephone number.
- Names of your employees.
- Your occupation and business address.
- Financial information including names of banks or financial institutions.
- Bankruptcy information and credit reporting information.
- Bank account information and credit card details
- Insurance related information including (but not limited to) professional indemnity insurance details.
We will not ordinarily ask you to provide sensitive information however, we are required to collect certain information and data on behalf of the Federal Government for statistical purposes in relation to training course enrolments. This information includes information relating to:
- language and cultural diversity
- schooling and previous qualifications achieved
- employment status
- study reasons
Apart from the above, we will only collect sensitive information in circumstances where:
- It is reasonably necessary for one or more of the services we provide or functions we carry out; and
- You consent to the collection of the information; or
- We are required or authorised by law to collect the sensitive information.
We will, if it is reasonable or practicable to do so, collect your personal information directly from you. This may happen when you fill out a form or when you give us personal information in person, or via telephone, email, correspondence or our website.
Sometimes we will collect personal information from a third party or a publicly available source. For example, we may need to collect personal information from a credit reporting agency.
If we receive personal information that we did not solicit, we will determine as soon as reasonably practicable whether we could have lawfully collected that information as part of our functions or activities. If we are not satisfied that we could have lawfully collected the information, then we will (if it is lawful and reasonable) destroy the information or ensure that it is de-identified.
You may choose to deal with us anonymously or under a pseudonym where lawful and practical. Where anonymity or use of a pseudonym will render us unable to provide the relevant service or do business, we may request that you identify yourself.
Use and Disclosure of Personal Information
Personal information collected by SPR will ordinarily be used for the following purposes:
- Processing your application for membership services
- Processing training enrolment forms
- Assisting you to resolve a complaint.
- Providing a relevant service or product as requested or ordered.
- Member relationship management.
- Marketing of products and services to you.
- Promoting your SPR membership to the community.
In order to achieve the purposes described above, we may disclose your personal information to the persons/organisations described below:
- Our mediators and Tribunal representatives if you utilise our complaint resolution processes.
- Your legal advisor(s) and other relevant third parties involved in or relevant to a complaint referred to Us for investigation and resolution.
- Your financial institution.
- Persons or organisations involved in providing, managing or administering products or services, including independent contractors engaged by us as trainers or to provide us with a required service or product.
- Organisations involved in maintaining, reviewing and developing our business systems, procedures and infrastructure including maintaining or upgrading our computer systems.
- Persons or organisations involved in commercial negotiations with our business.
- Organisations involved in payments systems including financial institutions, merchants and payment organisations.
- Organisations involving in managing and hosting our online training services.
We will only use and disclose personal information for the primary purpose for which it was initially collected, or for purposes which are directly related to one of our functions or activities.
We will not disclose your personal information to government agencies, private sector organisations or any third parties unless one of the following applies:
- You have consented.
- You would reasonably expect, or you have been told, that information of that kind is usually passed to those individuals, bodies or agencies.
- It is otherwise required or authorised by law.
- It is reasonably necessary for enforcement related activities conducted by, or on behalf of, an enforcement body (eg. Police).
Personal information provided to SPR may be shared with its related companies. We will take all reasonable and practical measures to keep such information strictly confidential.
SPR may transfer your personal information to overseas countries including but not limited to the United States of America and Canada in order to perform one or more of our functions or activities. In these circumstances, we will take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to the information.
Like many other businesses in Australia, SPR may rely on third party suppliers or contractors to provide specialised services such as web hosting, cloud computing technology and data storage services. If personal information is provided to these suppliers and contractors in order to enable them to perform the agreed tasks, we will make every effort to ensure that the supplier or contractor handles the personal information in accordance with the Act and the Australian Privacy Principles. We will also require all suppliers and contractors to provide privacy undertakings and enter into confidentiality agreements.
There may be limited circumstances in which it is necessary for us to collect a government related identifier such as your tax file number or Centrelink reference number. We will not use or disclose your government related identifiers unless we are required or authorized to do so by law or by a court or tribunal order, or in order to fulfill our obligations to a State or Territory authority.
Marketing our products and services
SPR may use or disclose your personal information to let you know about products and services in which you may be interested. You can contact us at any time if you no longer wish us to market our products and services to you (see the Contacting Us section for more information).
We may disclose your personal information to sponsors and supporters of the SPR and other third parties in order to facilitate direct marketing by those parties. You may contact us at any time to request that we refrain from providing your personal information to such parties (see the Contacting Us section for more information).
Non personally identifiable information
We sometimes collect data that, in and itself, does not directly identify you. We may collect, use, disclose and transfer this non personally identifiable information for any purpose. For example, we or our partners may collect information about your visits to our website, the links and advertisements that you click on and the URL that referred you to our website. We and/or such third parties with whom we may contract may use this information to serve you or like-minded customers with advertisements relating to other products, programs or services.
Hashed personal information
We may also share hashed portions of your Personal information with certain strategic partners to make our business more responsive to your interests and/or those of like-minded consumers. For example, we may aggregate your email address together with the email addresses of others who use our website or our services, and transmit the hashed data to Facebook for the purpose of creating “Custom Audiences” (where targeted ads are sent to people on Facebook who have already used our services or been to our website) and “Lookalike Audiences” (where targeted ads are sent to people on Facebook who have similar characteristics to people on our Custom Audience list). Please let us know if you wish to opt-out of this use.
We use third party analytics tools to help us measure traffic and usage trends and online behavior. These tools collection information sent by your computer or mobile device or our website, including the web pages that you visit, add-ons, and other information that assist us in improving the website. We collect and use this analytics information with analytics information from other users so that it cannot reasonably be used to identify any particular individual user.
An example of the use of a cookie is through Google AdWords Remarketing. Google Adwords Remarketing will display relevant ads tailored to you based on what parts of the website you have viewed by placing cookies on your computer. Google AdWords Remarketing then allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you.
Web Beacons and Pixel Tags
In addition to cookies, we also collect analytics information through the use of tracking pixels, also known as web beacons. A tracking pixel is a transparent graphic image that is placed on a web page and, in combination with a cookie, allows for the collection of information regarding the use of the website that contains the tracking pixel. We use tracking pixels to tell when an advertisement has been clicked on or otherwise interacted with, and use that information to judge which advertisement is more appealing to users. In some cases, we use third party service providers to help us collect and analyse this information.
Accuracy of Personal Information
SPR will take reasonable steps to ensure that all personal information it collects, uses or discloses is accurate, complete and up-to-date.
If you believe your personal information is not accurate, complete or up-to-date, please contact us (see the Contacting Us section for more information).
Your personal information may be stored in hard copy documents or electronically. SPR is committed to keeping your personal information secure and safe. Some of the ways we do this are:
- Requiring employees and contractors to enter into confidentiality agreements.
- Secure hard copy document storage (i.e. storing hard copy documents in locked filing cabinets).
- Security measures for access to our computer systems.
- Providing a discreet environment for confidential discussions.
- Access control for our buildings.
- Security measures for our websites (see the Your Privacy on the Internet section for more information).
- Anti-spam, anti-virus and anti-malware software
- Secure server room with access limited to authorised personnel
We will review and update our security measures from time to time.
In addition, we will review the personal information and sensitive information held by us from time to time, ensuring that information which is no longer needed for a purpose for which it was initially collected is destroyed or de-identified.
Your Privacy on the Internet
SPR takes care to ensure that the information you provide to us via our website is protected. For example, our website has electronic security systems in place, including the use of firewalls and data encryption in relation to shopping cart functions.
You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to ascertain their privacy standards, policies and procedures.
Access to Personal Information
You may request access to personal information that SPR holds about you (see the Contacting Us section for more information).
We will acknowledge your request within 14 business days of the request being made. Access will usually be granted within 14 business days of our acknowledgment or, if the request involves complex considerations or voluminous photocopying or scanning, we will contact you to provide an alternative timeframe based on the circumstances and anticipated work involved.
You will need to verify your identity before access to your personal information is granted.
While we cannot and do not charge an “application fee” for you applying to access your personal information, we may charge a fee for actually giving you access to your personal information in your preferred format (where reasonable and possible), which will cover our costs involved in locating and collating information as well as reproduction costs.
Once your request has been processed by SPR, you may be forwarded the information by mail or email or you may personally inspect it at the location where the information is held or another appropriate place. Whenever possible, we will endeavor to make the information available to you in the manner requested by you unless it is unreasonable for us to do so (eg. if you have asked for the information to be emailed to you, we will endeavor to email the information to you. If the file size would be too large, we may send you the information by hard copy instead of email).
If you are aware that we hold personal information about you that is no longer accurate, complete or up-to-date, please contact us (see the Contacting Us section for more information).
If you request access to your personal information, or if you request that we correct your personal information, we will allow access or make the correction unless we consider that there is a sound reason to withhold the information, or not make the correction.
Under the Act, we may refuse to grant access to personal information if:
- We believe that granting access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety.
- Granting access would have an unreasonable impact upon the privacy of other individuals.
- Denial of access is required or authorised by law or by a Court or Tribunal order.
- Giving access would be unlawful.
- The request for access is frivolous or vexatious.
- Legal proceedings are underway or anticipated and the information would not be accessible by way of the discovery process in those proceedings.
- Giving access would reveal our intentions in relation to negotiations between us and you in such a way as to prejudice those negotiations.
- Giving access is likely to prejudice enforcement related activities conducted by, or on behalf of, an enforcement body.
- Giving access is likely to prejudice action being taken or to be taken with respect to suspected unlawful activity or serious misconduct relating to our functions or activities.
- Giving access would reveal information in connection with a commercially sensitive decision making process.
If we do not agree to make a correction to your personal information, you may provide a statement about the requested corrections, and we will ensure that the statement is apparent to any users of the relevant personal information.
If we do not agree to provide access to your personal information or to correct your personal information, we will provide written reasons for the refusal and the mechanisms available to complain about the refusal (see the Complaints section for more information).
You may contact us by mail, email or telephone as follows:
PO Box 300
RUNAWAY BAY. QLD. 4216
0408 450 180
If you consider that there has been a breach of the Australian Privacy Principles, you are entitled to complain to SPR (see the Contacting Us section for more information).
We will acknowledge receipt of a complaint within 2 business days.
We will investigate the complaint and attempt to resolve it within 20 business days after the complaint was received. Where it is anticipated that this timeframe is not achievable, we will contact you to provide an estimate of how long it will take to investigate and respond to the complaint.
If you consider that we have not adequately dealt with a complaint, you may complain to the Office of the Australian Information Commissioner on the below details:
Officer of the Australian Information Commissioner (OAIC)
GPO Box 5218
SYDNEY NSW 2001
1300 363 992
This policy is to be reviewed as follows:
- Annually as a minimum.
- Following an information security incident.
- Following significant changes to our systems.
- Following changes to the relevant State and Commonwealth legislation
Reviews are to examine the appropriateness of the policy taking into consideration corporate, system and compliance requirement changes since the last review was undertaken.
SPR reserves the right to change this Policy at any time and any amended Policy is effective upon posting to our website. The SPR will make every effort to communicate any significant changes to you via email or via our SPR updates. Your continued membership of SPR and use of our services will be deemed acceptance of any amended Policy.