1.1 From time to time Integrity Coach Lines (Aust) Pty Ltd ("the Company") is required to collect, hold, use and/or disclose personal information relating to individuals (including, but not limited to, its customers, contractors, suppliers and employees) in the performance of its business activities.
1.2 This document sets out the Company's policy in relation to the protection of personal information, as under the Privacy Act 1998 (Cth) the ("Act") and the Australian Privacy Principles ("APP").
1.3 The APPs regulate the handling of personal information.
2 What is personal information?
2.1 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.
3 Employee records
3.1 This policy does not apply to the collection, holding, use or disclosure of personal information that is an employee record.
3.2 An employee record is a record of personal information relating to the employment of an employee. Examples of personal information relating to the employment of the employee include, but are not limited to, health information and information about the engagement, training, disciplining, resignation, termination, terms and conditions of employment of the employee. Please see the Act for further examples of employee records.
4Kinds of information that the Company collects and holds
4.1 The Company collects personal information that is reasonably necessary for one or more of its functions or activities. We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:-
i.Internal record keeping;
ii.We may use the information to improve our products and services;
iii.We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting, using the email address which you have provided.
4.2 The type of information that the Company collects and holds may depend on your relationship with the Company. For example:
Candidate: if you are a candidate seeking employment with the Company, the Company may collect and hold information including your name, address, email address, contact telephone number, gender, age, employment history, references, resume, medical history, emergency contact, taxation details, qualifications and payment details.
Customer: if you are a customer of the Company, the Company may collect and hold information including your name, address, email address, contact telephone number, gender and age.
Supplier: if you are a supplier of the Company, the Company may collect and hold information including your name, address, email address, contact telephone number, business records, billing information, information about goods and services supplied by you.
Referee: if you are a referee of a candidate being considered for employment by the Company, the Company may collect and hold information including your name, contact details, current employment information and professional opinion of candidate.
Sensitive information: the Company will only collect sensitive information where you consent to the collection of the information and the information is reasonably necessary for one or more of the Company’s functions or activities. Sensitive information includes, but is not limited to, information or an opinion about racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, membership of a trade union, sexual preferences, criminal record, health information or genetic information.
5 How the Company collects and holds personal information
5.1 The Company must collect personal information only by lawful and fair means. The Company will collect personal information directly from you if it is reasonable or practicable to do so.
5.2 The Company may collect personal information in a number of ways. This may include information such as your name, address, phone number, email address and credit card details. It may also include your intended travel dates, place of departure and intended destination and other information relevant to customer feedback/surveys and/or offers. It may also collect personal information from the following without limitation:
through application forms;
by email or other written mechanisms;
over a telephone call;
in person;
through booking transactions;
through our website;
through surveillance camera;
by technology that is used to support communications between us;
a) through publically available information sources (which may include telephone directories, the internet and social media sites);
b) direct marketing database providers;
5.3 When the Company collects personal information about you through publicly available information sources, it will manage such information in accordance with the APPs.
5.4 At or before the time or, if it is not reasonably practicable, as soon as practicable after, the Company collects personal information, the Company must take such steps as are reasonable in the circumstances to either notify you or otherwise ensure that you are made aware of the following:
the identity and contact details of the Company;
that the Company has collected personal information from someone other than you or if you are unaware that such information has been collected;
that collection of personal information is required by Australian law, if it is;
the purpose for which the Company collects the personal information;
the consequences if the Company does not collect some or all of the personal information;
any other third party to which the Company may disclose the personal information;
the Company's privacy policy contains information about how you may access and seek correction of personal information held by the Company and how you may complain about a breach of the APPs; and
whether the Company is likely to disclose personal information to overseas recipients, and the countries in which those recipients are likely to be located.
5.5 Unsolicited personal information is personal information that the Company receives which it did not solicit. Unless the Company determines that it could have collected the personal information in line with the APPs or the information is contained within a Commonwealth record, it must destroy the information to ensure it is de-identified.
6 Purposes for which the Company collects, holds, uses and/or discloses personal information
6.1 The Company will collect personal information if it is reasonably necessary for one or more of its functions or activities.
6.2 The main purposes for which the Company may collect, hold, use and/or disclose personal information may include but are not limited to:
recruitment functions;
customer service management;
training and events;
surveys and general research; and
business relationship management.
6.3 The Company may also collect, hold, use and/or disclose personal information if you consent or if required or authorised under law.
6.4 Direct marketing:
6.4.1 The Company may use or disclose personal information (other than sensitive information) about you for the purpose of direct marketing (for example, advising you of new goods and/or services being offered by the Company).
6.4.2 The Company may use or disclose sensitive information about you for the purpose of direct marketing if you have consented to the use or disclosure of the information for that purpose.
6.4.3 You can opt out of receiving direct marketing communications from the Company by contacting the Privacy Officer in writing or if permissible accessing the Company’s website and unsubscribing appropriately.
7 Disclosure of Personal Information
7.1 We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. The Company may disclose your personal information for any of the purposes for which it is was collected such as to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen, and as indicated under clause 6 of this policy, or where it is under a legal duty to do so.
7.2 Disclosure will usually be internally and to related entities or to third parties such as contracted service suppliers.
7.3 Before the Company discloses personal information about you to a third party, the Company will take steps as are reasonable in the circumstances to ensure that the third party does not breach the APPs in relation to the information.
8 Access to personal information
8.1 If the Company holds personal information about you, you may request access to that information by putting the request in writing and sending it to the Privacy Officer. The Company will respond to any request within a reasonable period, and a small charge will apply for giving access to the personal information.
8.2 There are certain circumstances in which the Company may refuse to grant you access to the personal information. In such situations the Company will give you written notice that sets out:
the reasons for the refusal; and
the mechanisms available to you to make a complaint.
9 Correction of personal information
9.1 If the Company holds personal information that is inaccurate, out-of-date, incomplete, irrelevant or misleading, it must take steps as are reasonable to correct the information.
9.2 If the Company holds personal information that you believe is incorrect or incomplete please make a request for us to correct this in writing, or by email, addressed to the Privacy Officer, Integrity Coach Lines (Aust) Pty Ltd, PO Box 1131, Midland, Western Australia, 6936 and we will respond to your request promptly in order to correct the information.
9.3 There are certain circumstances in which the Company may refuse to correct the personal information. In such situations the Company will give you written notice that sets out:
the reasons for the refusal; and
the mechanisms available to you to make a complaint.
9.4 If the Company correct personal information that it has previously supplied to a third party and you request us to notify the third party of the correction, the Company will take such steps as are reasonable to give that notification unless impracticable or unlawful to do so.
10 Integrity and security of personal information
10.1 The Company are committed to ensuring that your information is secure and will take such steps (if any) as are reasonable in the circumstances to ensure that the personal information that it:
collects is accurate, up-to-date and complete; and
uses or discloses is, having regard to the purpose of the use or disclose, accurate, up-to-date and complete.
10.2 The Company will take steps as are reasonable in the circumstances to protect the personal information from misuse, interference, loss and form unauthorised access, modification or disclosure.
10.3 If the Company holds personal information, it no longer needs the information for any purpose for which the information may be used or disclosed, the information is not contained in any Commonwealth record and the Company is not required by law to retain the information, it will take such steps as are reasonable in the circumstances to destroy the information or to ensure it is de-identified.
11 Anonymity and Pseudonymity
11.1 You have the option of not identifying yourself, or using a pseudonym, when dealing with the Company in relation to a particular matter. This does not apply:
where the Company is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves; or
where it is impracticable for the Company to deal with individuals who have not identified themselves or who have used a pseudonym.
11.2 However, in some cases if you do not provide the Company with your personal information when requested, the Company may not be able to respond to your request or provide you with the goods or services that you are requesting.
12 Our Website - How we use cookies
12.1 A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual.
12.2 We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
12.3 Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
12.4 You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
13 Our Website - Links to other websites
13.1 Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
14 Complaints
14.1 You have a right to complain about the Company’s handling of your personal information if you believe the Company has breached the APPs.
14.2 If you wish to make such a complaint to the Company, you should first contact the Privacy Officer in writing. Your complaint will be dealt with in accordance with the Company’s complaints procedure and the Company will provide a response within a reasonable period.
14.3If you are unhappy with the Company’s response to your complaint, you may refer your complaint to the Office of the Australian Information Commissioner.
15 Privacy Officer contact details
15.1 The Company's Privacy Officer can be contacted in the following ways:
Telephone number: 1800226339
Email address: admin@integritycoachlines.com.au
Postal address: PO Box 1131, Midland DC, WA, 6939
16 Breach of this policy
16.1 Any employee who is found to have breached this policy may be subject to disciplinary action, up to and including termination of employment.