MY ACCOUNTS is committed to privacy protection and compliance with applicable privacy laws and standards, and will manage personal information in an open and transparent way. MY ACCOUNTS will fulfil its obligations under the Privacy Act of 1988 (including the Amendment (Enhancing Privacy Protection) Act 2012 (Cth)), by complying with the Australian Privacy Principles (APPs). These 13 principles detail how organisations should collect, update, use, keep secure or where necessary disclose and give access to personal information, as well as how complaints should be handled and how, in some circumstances, anonymity can be maintained.
This policy applies to all employees, contractors, customers and suppliers. It applies to the collection, updating, use, storage, disclosure and access to personal and sensitive information that can be recorded in any format including, but not limited to, information held in writing, online, digitally or by electronic means, including mobile phones and USB sticks.
Information collected and held by MY ACCOUNTS could include name, current and previous address, telephone number(s), driver licence number, bank account details, Tax File Number, date of birth, diversity status, and relevant sensitive (e.g. health) information, as well as details of your trading with us e.g. numbers, financial and business details (suppliers and customers) information.
MY ACCOUNTS will:
3.1.1.1 where reasonable and practicable to do so, collect personal information about an individual from that individual
3.1.1.2 ensure that individuals are aware that, in some circumstances, information may be provided anonymously or by using a pseudonym unless
(a) MY ACCOUNTS is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves or
(b) it is impracticable for MY ACCOUNTS to deal with individuals who have not identified themselves or who have used a pseudonym
3.1.1.3 not collect, update, use, store or disclose personal, health or business information to another party without written consent from an individual, business or MY ACCOUNTS
3.1.1.4 only collect personal information that is necessary for its functions or activities
3.1.1.5 only collect information by lawful and fair means, without unwarranted coercion and in a way that is not unreasonably intrusive
3.1.1.6 when, or as soon as practicable after, collecting personal information from an individual, MY ACCOUNTS will take reasonable steps to ensure that the individual is aware of:
a) MY ACCOUNTS’s identity and contact details
b) how to access the information
c) how to update the information
d) the purpose for which the information is collected
e) the types of entities to which MY ACCOUNTS usually discloses information of that kind, and, where relevant, the countries in which overseas recipients are likely to be located
f) any law that requires the particular information to be collected
g) the main consequences (if any) for the individual if all or part of the information is not provided
h) MY ACCOUNTS’s Privacy Policy which contains information about how the individual may access the personal information about the individual and seek the correction of such information, and
i) how to complain about a breach of the Australian Privacy Principles.
3.1.1.7 if personal information is collected from someone other than the individual, take reasonable steps to ensure that the individual is made aware of the matters listed above except to the extent that making the individual aware of the matters would pose a serious threat to the life or health of any individual
3.1.1.8 inform all managers and staff by way of the Privacy Policy that no personal information or business details are to be given to another party without the consent/and or guidance of the National Senior Executive Human Resources or Chief Executive Officer
3.1.1.9 inform the party/s concerned of the reason for collecting, using, storing or disclosing such information
3.1.1.10 inform the party/s concerned of the main consequences if all or part of the information is not provided.
MY ACCOUNTS collects personal information in a number of ways:
3.1.2.1 directly from you when you apply to us for employment as part of our recruitment
of employees process, or training services, on an application form
3.1.2.2 from freely available “public domain” information sources e.g. telephone directories
3.1.2.3 from our own records of how and when you use our various services
3.1.2.4 from third parties, such as previous employers or organisations you have dealt with in the past and volunteered by you as a reference for the purposes of employment or credit checks prior to the opening of an account with us.
3.1.3.1 If MY ACCOUNTS receives unsolicited personal information, we will, within a reasonable period after receiving the information, determine whether or not the information could have been collected by lawful and fair means.
3.1.3.2 If MY ACCOUNTS determines that we could not have collected the personal information, and the information is not contained in a Commonwealth record, MY ACCOUNTS will, as soon as practicable, but only if it is lawful and reasonable to do so, destroy the information or ensure the information is de-identified.
3.1.3.3 If MY ACCOUNTS determines that the information could have been collected by lawful and fair means, we will apply the Australian Privacy Principles in relation to the information as if we had collected the information under the Australian Privacy Principles.
MY ACCOUNTS will only use this information to:
3.2.1.1 provide the service(s) you have requested. This may be payment for work done, invoicing for work completed by one of our employees, or providing training services and reporting results
3.2.1.2 manage those services in order to provide the optimum level of service for your individual needs
3.2.1.3 conduct appropriate credit, police and/or “Working with Children” checks, and pre-employment checks e.g. reference checking or pre-employment medical advice
3.2.1.4 advise you of other services that we provide, that may be of interest to you.
3.2.2.1 MY ACCOUNTS will only disclose information about you to others on an as needs basis or where required by law.
These people or organisations may include,
a) your authorised representative or legal advisors
b) banks or credit providers for payroll purposes or credit related functions such as the provision of account facilities
c) government and statutory authorities, where required by law, for example the reporting of training results for a registered trainee; Australian Taxation Office; or nominated superannuation fund
d) MY ACCOUNTS’s Privacy Officer / National Senior Executive Human Resources who believes that use of the information is necessary to prevent or lessen a serious and imminent threat to the life or health of the individual concerned or another person.
3.2.2.2 MY ACCOUNTS will only use or disclose personal information for a purpose (the secondary purpose) other than the primary purpose of collection if:
a) the individual has consented to the use or disclosure of the information or
b) the individual would reasonably expect the information to be used or disclosed for the secondary purpose and
c) if the information is sensitive, it is directly related to the primary purpose or
d) if the information is not sensitive, it is related to the primary purpose or
e) the use or disclosure of the information is required or authorised by or under an Australian law or court/tribunal order or
f) a permitted general situation exists or
g) a permitted health situation exists or
h) MY ACCOUNTS reasonably believes that the use or disclosure is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
If MY ACCOUNTS uses or discloses personal information under the previous paragraph we will make a written note of the use or disclosure, and will take reasonable steps to ensure that the information in de-identified before disclosure.
These guidelines on use and disclosure of personal information do not apply for the purposes of direct marketing or the use of government related identifiers,
3.2.5.1 MY ACCOUNTS may use personal information (other than sensitive information) about an individual for the purposes of direct marketing if:
a) MY ACCOUNTS collected the information from the individual and the individual would reasonably expect MY ACCOUNTS to use the information for that purpose
or
b) MY ACCOUNTS collected the information from someone other than the individual and either
(i) the individual has consented to the use or disclosure of the information for that purpose or
(ii) it is impracticable to obtain that consent.
c) MY ACCOUNTS may use personal contact details for the purposes of direct marketing if:
(i) MY ACCOUNTS is a contracted service provider for a Commonwealth contract and
(ii) MY ACCOUNTS collected the information for the purpose of meeting (directly or indirectly) an obligation under the contract and
(iii) the use is necessary to meet (directly or indirectly) such an obligation.
And for any of the above situations, MY ACCOUNTS will provide a simple means by which the individual may easily request not to receive direct marketing communications from MY ACCOUNTS and will make all reasonable efforts to ensure no further direct marketing is sent to those contact details.
3.2.5.2 MY ACCOUNTS will not disclose personal or sensitive information to any other party through direct marketing.
3.2.5.3 MY ACCOUNTS will make all reasonable efforts to remove the individual's contact and personal details if the individual communicates this request through the response point to the origin of the direct marketing or through any other MY ACCOUNTS corporate communication media.
3.2.5.4 If MY ACCOUNTS uses personal information about an individual for the purpose of direct marketing by MY ACCOUNTS or to facilitate direct marketing by other organisations the individual may:
a) irequest not to receive direct marketing communications from MY ACCOUNTS
b)request MY ACCOUNTS not to use or disclose the information for the purpose of direct marketing by other organisations
e) request MY ACCOUNTS to provide its source regarding this information.
3.2.5.5 If and when an individual makes a request under the above sub-clause 3.2.5.4,
a) MY ACCOUNTS will not charge the individual for the making of, or to give effect to, the request to remove their details from future direct marketing and
b) if the request is not to receive direct marketing communications from MY ACCOUNTS for its own direct marketing or for the facilitating direct marketing by other organisations, MY ACCOUNTS must give effect to the request within a reasonable period after the request is made and
c) if the request is that MY ACCOUNTS provide its source of information, MY ACCOUNTS will, within a reasonable period after the request is made, notify the individual of its source unless it is impracticable or unreasonable to do so.
3.2.5.6 This principle does not apply to the extent that any of the following apply:
a) the Do Not Call Register Act 2006
b) the Spam Act 2003
c) any other Act of the Commonwealth, or a Norfolk Island enactment, prescribed by the regulations.
Google Adwords advertising
MY ACCOUNTS uses the following features of Google Adwords for the purpose of promoting its services
remarketing
interest categories
similar audiences
interest-based advertising
demographic and location targeting.
In conducting the above activity with Google Adwords MY ACCOUNTS will not
collect personally identifiable information (PII) including, but not limited to, email addresses, telephone numbers, and credit card numbers use or associate personally identifiable information with remarketing lists, cookies, data feeds, or other anonymous identifiers use or associate targeting information, such as demographics or location, with any personally identifiable information collected from the ad or its landing page share any personally identifiable information with Google through our remarketing tag or any product data feeds which might be associated with our Google Adwords ads send Google precise location information without obtaining people's consent. MY ACCOUNTS will abide by the policy for sensitive categories outlined below.
When creating a remarketing list, we will not use any sensitive information about our site or app visitors, whether collected directly or associated with a visitor, based on the visitor's profile or behavior on our site or app Ad content will not imply knowledge of personally identifiable or sensitive information.
MY ACCOUNTS will:
3.3.6 if the individual and MY ACCOUNTS disagree about whether the information is inaccurate, incomplete, out of date, irrelevant or misleading, and the individual asks MY ACCOUNTS to associate with the information a statement that the information is inaccurate, incomplete, out of date, irrelevant or misleading, MY ACCOUNTS will take such steps as are reasonable in the circumstances to associate the statement in such a way that will make the statement apparent to users of the information.
MY ACCOUNTS will:
3.6.1.1 You have the right to access any information held by MY ACCOUNTS about you, subject to some restrictions listed in Federal Government legislation
For example:
a. if providing access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety or
b. if providing access would have an unreasonable impact upon the privacy of other individuals or
c. the request for access is frivolous or vexatious or
d. the information relates to existing or anticipated legal proceedings between MY ACCOUNTS and the individual, and would not be accessible by the process of discovery in those proceedings or
e. providing access would reveal the intentions of MY ACCOUNTS in relation to negotiations with the individual in such a way as to prejudice those negotiations or
f. providing access would be unlawful or
g. denying access is required or authorised by or under an Australian law or a court/tribunal order or
h. MY ACCOUNTS has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to MY ACCOUNTS’s functions or activities has been, is being, or may be engaged in and
i. providing access would be likely to prejudice the taking of appropriate action in the matter or
j. providing access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body, or
k. providing access would reveal evaluative information generated within MY ACCOUNTS in connection with a commercially sensitive decision-making process.
3.6.1.2 However where providing access would reveal evaluative information generated within MY ACCOUNTS in connection with a commercially sensitive decision making process, MY ACCOUNTS may give the individual an explanation for the commercially sensitive decision rather than direct access to the information.
3.6.1.3 If MY ACCOUNTS is not required to provide the individual with access to the information because of one or more of above stated reasons, MY ACCOUNTS will, where reasonable in the circumstances, give access in a way that meets the needs of both MY ACCOUNTS and the individual, including through the use of a mutually agreed intermediary.
Wherever it is lawful and practicable, individuals will have the option of not identifying themselves, or of using a pseudonym, when dealing with MY ACCOUNTS, except:
3.11.1 MY ACCOUNTS will not disclose any personal information without first establishing the identity of the person requesting the information.
3.11.2 If access to personal information held by MY ACCOUNTS is required, a written request specifying the information sought may be made to an individual’s usual contact at MY ACCOUNTS or the Privacy Officer / National Senior Executive Human Resources. Adequate identification by or authority from an individual must be supplied to MY ACCOUNTS before any personal information will be provided
3.11.3 Access to personal information will be provided within five business days of receiving a request. If this cannot be complied with MY ACCOUNTS will advise within the five day period when access will be provided.
3.11.4 The nature and the timing of access will be agreed between MY ACCOUNTS and the individual.
3.11.5 MY ACCOUNTS may charge a reasonable fee for providing access to personal information, (but not for lodging a request for access).
3.11.6 If MY ACCOUNTS refuses access due to subclause 3.6.1.1, we will provide written notice to the individual which sets out:
(a) the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so
(b) the mechanisms available to complain about the refusal, and
(c) any other matter prescribed by the regulations.
3.12.1 Any complaint by an individual regarding MY ACCOUNTS’s management or handling of personal information should be directed to MY ACCOUNTS’s Privacy Officer. Contact details are set out below.
3.12.2 To enable a complaint to be properly understood and acted upon it is requested that it be made in writing, specifying the personal information involved and the contact or process at MY ACCOUNTS that is the subject of the complaint.
3.12.3 All complaints will be acknowledged within three (3) working days of receipt. Contact details of the person dealing with the complaint and the Privacy Officer will also be advised to the individual making the complaint at this time.
3.12.4 Complaints will be responded to within fifteen (15) working days. If this is not possible the individual will be advised as to when MY ACCOUNTS expects to be able to respond.
3.12.5 If MY ACCOUNTS’s response does not resolve the complaint MY ACCOUNTS and the individual will, in good faith, promptly agree to a process and time frame for dealing with the complaint.
The responsibilities of the Privacy Officer will include:
4.1.1 investigating any complaints raised with respect to privacy and personal information
4.1.2 reviewing he organisation’s current and future practices and procedures to ensure compliance with this policy and current legislation
4.1.3 reviewing this policy and advising on the education of management and staff of their responsibilities under this policy and providing information on the Privacy and Health Records Acts.
If you have any questions relating to privacy or the storage of information about you, please contact us on: 1300 784 122 and ask for the Privacy Officer
