1.2 We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. Our commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles (APPs). The APPs set out the way in which personal information must be treated.
1.4 This policy applies to any person for whom we currently hold, or may in the future collect, personal information.
1.5 This policy applies to personal information. In broad terms, ‘personal information’ is information or opinions relating to a particular individual who can be identified.
1.6 Information is not personal information where the information cannot be linked to an identifiable individual.
2. HOW DO WE MANAGE THE PERSONAL INFORMATION WE COLLECT?
2.1 We manage the personal information we collect in numerous ways, such as by:
- implementing security systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure;
- regularly providing staff with information bulletins on privacy issues;
- appropriately supervising staff who regularly handle personal information;
- implementing mechanisms to ensure any agents or contractors who deal with us comply with the APPs;
- implementing procedures for identifying and reporting privacy breaches and for receiving and responding to complaints;
- appointing a privacy officer within the business to monitor privacy compliance.
2.2 We will take reasonable steps to destroy or permanently de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.
2.3 It is not possible for you to use a pseudonym or remain anonymous when dealing with us, due to the limited nature of personal information we collect.
3. WHAT KINDS OF INFORMATION DO WE COLLECT AND HOLD?
3.1 We may collect and hold personal information about you, which may include:
- sensitive information (see below);
- contact information;
- date and place of birth;
- employment arrangements and history;
- educational qualifications;
- tax returns and tax file numbers;
- credit information;
- banking details;
- gender; and
- any other personal information required to supply our products to or employ you.
3.2 ‘Sensitive information’ is a subset of personal information and includes personal information that may have serious ramifications for the individual concerned if used inappropriately.
3.3 We may collect sensitive information if it is relevant in providing direct marketing to you or assessing your suitability for credit. The sensitive information we collect and hold about you may include whether you are a member of professional or trade associations.
3.4 We will not collect sensitive information without the individual’s consent to whom the information relates unless permitted under the Privacy Act.
4. HOW AND WHEN DO WE COLLECT PERSONAL INFORMATION?
4.1 Our usual approach to collecting personal information is to collect it directly from you.
4.2 We may also collect personal information in other ways, which may include:
- from paid search providers;
- through referrals from individuals or other entities;
- through marketing (including direct marketing) and business development events;
- from third party providers and suppliers;
- from list purchases;
- from other customers, suppliers, providers, or clients;
- when individuals respond to questions regarding products or services;
- through website cookies; and
- from competitions.
4.3 If you wish, you may elect not to accept cookies on your browser. This should not adversely affect your experience when visiting our website.
5.1 The use of cookie technology allows us to collect information such as browser type and geographical location as well as to identify and understand the navigation of visitors to the VanLife Customs web site.
- maximize the efficiency of a web site visit by delivering customised content and advertising;
- gauge the effectiveness of the site’s customised marketing materials; and
- investigate or take action regarding any unlawful activities.
6. HOW DO WE HOLD PERSONAL INFORMATION?
6.1 Our usual approach to holding personal information includes:
- physically at our premises (securely); and
- on a private cloud; or
- using a third party data storage provider.
6.2 We secure the personal information we hold in numerous ways, including:
- using security cards / access codes to access areas that contain personal information;
- using secure servers to store personal information;
- using unique usernames, passwords and other protections on systems that can access personal information.
6.3 We may disclose personal information to our third party technology providers such as our data storage providers and email filter providers.
7. WHY DO WE COLLECT, HOLD, USE OR DISCLOSE PERSONAL INFORMATION?
7.1 We take reasonable steps to use and disclose personal information for the primary purpose for which we collect it. The primary purpose for which information is collected is generally to provide our products to you or your business, assess any application for credit, or assess your suitability for employment.
7.2 Personal information may also be used or disclosed by us for secondary purposes which are within your reasonable expectations and which are related to the primary purpose of collection.
7.3 For example, we may collect and use your personal information for direct marketing purposes to improve the products and services provided by VanLife Customs to you or your business.
7.4 We may disclose personal information to other third parties or suppliers, if it is necessary in order for us to supply to your business, or to our accountant and advisors.
7.5 Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act.
8. WILL WE DISCLOSE PERSONAL INFORMATION OUTSIDE AUSTRALIA?
8.1 From time to time, we may disclose information to our overseas service provider located in the United States of America.
8.2 We are satisfied that the service provider is committed to privacy and confidentiality obligations that are at least equal to the Australian Privacy Principles.
8.3 Your personal information will not be disclosed to any overseas recipient unless we are satisfied that the receiving party provides commitments to privacy and confidentiality that are at least equal to the Australian Privacy Principles or the recipient is subject to privacy protection laws that offer at least the same level of protection as required under the Privacy Act in Australia.
9. HOW DO WE MANAGE YOUR CREDIT INFORMATION?
What kinds of credit information may we collect?
9.1 In the course of providing products to you and assessing your suitability for credit, we may collect and hold the following kinds of credit information:
- your identification information;
- information about any credit that has been provided to you;
- your repayment history;
- information about your overdue payments;
- if terms and conditions of your credit arrangements are varied;
- if any court proceedings are initiated against you in relation to your credit activities;
- information about any bankruptcy or debt agreements involving you;
- any publicly available information about your credit worthiness; and
- any information about you where you may have fraudulently or otherwise committed a serious credit infringement.
9.2 In some circumstances, we may collect credit information and personal information from credit reporting bodies (e.g. Veda). The kinds of information we collect may include any of those kinds of information outlined in sections 3.1 and 9.1 of this policy.
How and when do we collect credit information?
9.3 In most cases, we will only collect credit information about you if you disclose it to us and it is relevant in providing you with our products or improving our products and our provision of them to you.
9.4 Other sources we may collect credit information from include:
- credit reporting bodies; and
- your suppliers and creditors.
9.5 We do not collect and hold credit information from credit reporting bodies unless it is incidentally collected in providing our products to you.
How do we store and hold the credit information?
9.6 We store and hold credit information in the same manner as outlined in section 6 of this policy.
Why do we collect the credit information?
9.7 Our usual purpose for collecting, holding, using and disclosing credit information about you is to enable us to provide you with the products.
9.8 We may also collect the credit information:
- to process payments;
- to assess eligibility for credit;
- for direct marketing purposes;
- for other purposes incidental to our supply of products or services to you.
Overseas disclosure of the credit information
9.9 We will not disclose your credit information to entities without an Australian link unless you expressly request us to.
How can I access my credit information, correct errors or make a complaint?
9.10 You can access and correct your credit information, or complain about a breach of your privacy in the same manner as set out in section 10 of this policy.
10. HOW DO YOU MAKE COMPLAINTS AND ACCESS AND CORRECT YOUR PERSONAL INFORMATION OR CREDIT INFORMATION?
10.1 It is important that the information we hold about you is up-to-date. You should contact us if your personal information changes.
Access to information and correcting personal information.
10.2 You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.
10.3 We will grant you access to your personal information as soon as possible, subject to the request circumstances.
10.4 In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.
10.5 We may deny access to personal information if:
- the request is unreasonable;
- providing access would have an unreasonable impact on the privacy of another person;
- providing access would pose a serious and imminent threat to the life or health of any person;
- providing access would compromise our professional obligations; or
- there are other legal grounds to deny the request.
10.6 We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.
10.7 If the personal information we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, where it is appropriate to do so.
10.8 If you wish to complain about an alleged privacy breach, then you must follow the following process:
- The complaint must be firstly made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint.
- In the unlikely event the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.
Who to contact
10.9 A person may make a complaint or request to access or correct personal information about them held by us. Such a request must be made in writing to the Privacy Officer at the following address:
Postal Address: PO Box 747, Caloundra QLD 4551
Telephone number: 0412 586 911
Email address: firstname.lastname@example.org
11. CHANGES TO THE POLICY
This policy was last updated in February 2021. If you have any comments on the policy, please contact the privacy officer with the contact details in section 10 of this policy.