OUR COMMITMENT TO PROTECTING YOUR PRIVACY
WHOSE PERSONAL INFORMATION DO WE COLLECT?
We may collect your personal information from a range of sources. For example, we may collect your personal information when you request or acquire a service from us, provide a service or product to us, apply for employment with us or communicate with us via our website, by e-mail, telephone or in writing.
WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We will only collect your information if you have consented to us doing so, for example when we conduct research we always ask participants to complete consent forms. The personal information we collect includes:
- Client details: names, e-mail addresses, phone numbers, payment details, occupation and other information to assist us in conducting our business, providing and marketing our services;
- Staff: information about potential staff, staff and partners, as required in the normal course of human resource management and the operation of a business.
- Research participants: names, email addresses, phone numbers, payment details, occupation and other information to assist us in conducting our services.
HOW DO WE COLLECT PERSONAL INFORMATION?
We only collect personal information by lawful and fair means. We usually collect personal information from:
- face-to-face meetings, interviews and telephone calls
- business cards
- electronic communications – for example, emails and attachments, and forms filled out by people, including as part of attendance at seminars or through acquiring a service from us
- subscriptions to marketing materials such as newsletters and electronic briefs
- third parties – for example, from research recruitment agencies and your representatives or agents
- our website and social media pages, including if you use them to contact us.
WHY DO WE COLLECT PERSONAL INFORMATION?
We collect the personal information: necessary for us to provide you with the services you have requested from us; for marketing purposes and to provide you with information about services that may be of interest to you; to improve the services we provide; and to enable us to conduct our business, including conducting research and your participation in that research. If you do not provide your personal information, we may not be able to supply the requested service, employ you or otherwise deal with you.
HOW WE DEAL WITH UNSOLICITED PERSONAL INFORMATION?
If we receive personal information about you that we have not requested, and we determine that we could not have lawfully collected that information under the APPs had we asked for it, we will destroy or de-identify the information if it is lawful and reasonable to do so.
DO YOU HAVE TO DISCLOSE YOUR IDENTITY WHEN DEALING WITH US?
Where lawful and practicable, we will give you the option of interacting with us anonymously or using a pseudonym.
USE OF PERSONAL INFORMATION:
We only use your personal information for the purpose for which it was provided to us, for related purposes or as required or permitted by law. Such purposes include:
- in the ordinary course of conducting our business. For example, supplying services such as consulting advice, acquiring products and services, responding to your enquiries and feedback, and providing information about our events, news, publications and services that may be of interest to you;
- conducting research projects, so that we know who is involved in the research projects
- market research and service development, so that we are able to better understand our clients’ needs and tailor our future services accordingly;
- performing general administration, reporting and management functions. For example, invoicing and account management, payment processing, credit and risk management, training, quality assurance and managing suppliers;
- employment-related purposes, such as recruiting and providing services to staff;
- other purposes related to or in connection with our business, including meeting our legal and contractual obligations to third parties and for internal governance purposes.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose, and you consent to us disclosing, your personal information to third parties:
- engaged by us to provide products or services, or to undertake functions or activities, on our behalf. For example, managing databases, marketing, research and advertising;
- that are authorised by you to receive information we hold,
- that are our business partners, joint venturers, partners or agents;
- such as our external advisers, and government agencies. For example, where disclosure is reasonably required to obtain advice, prepare legal proceedings or investigate suspected unlawful activity or serious misconduct; or
- as required or permitted by law.
MARKETING USE AND DISCLOSURE
We may use and disclose your personal information (other than sensitive information) to provide you with information about our services that we consider may be of interest to you. You may opt out at any time if you do not, or no longer, wish to receive marketing and promotional material. You may do this by: contacting us via e-mail or in writing at the address below and requesting that we no longer send you marketing or promotional material; or where applicable, clicking the “Unsubscribe” button.
USE OR DISCLOSURE OF SENSITIVE INFORMATION
We will only use or disclose your sensitive information for the purpose for which it was initially collected or for a directly related purpose, as required or permitted by law, or where you consent to the use or disclosure.
DISCLOSURE OF PERSONAL INFORMATION OVERSEAS
We do not disclose personal information to third parties outside Australia, unless required or permitted by law.
HOW IS MY PERSONAL INFORMATION KEPT SECURE?
We take reasonable steps to protect your personal information from misuse, interference, loss and unauthorised access, modification and disclosure. Such steps include: physical security over paper-based and electronic data storage and premises; computer and network security measures, including use of firewalls, password access and secure servers; restricting access to your personal information to employees and those acting on our behalf who are authorised and on a ‘need to know’ basis; retaining your personal information for no longer than it is reasonably required, unless we are required by law to retain it for longer; and entering into confidentiality agreements with staff and third parties.
Where we no longer require your personal information, including where we are no longer required by law to keep records relating to you, we will ensure that it is de-identified or destroyed.
We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date. However, we rely on you to advise us of any changes or corrections to the information we hold about you. If you consider that the information we hold about you is not accurate, complete or up-to-date, or if your information has changed, please let us know as soon as possible.
You may request access to the personal information we hold about you by contacting us. We will respond to your request within a reasonable time. We will provide you with access to the information we hold about you unless otherwise permitted or required by law. If we deny you access to the information, we will notify you of the basis for the denial unless an exception applies. Where reasonable and practicable, we will provide access to the information we hold about you in the manner you request. No fee applies for requesting access to information we hold about you. However, we reserve the right to charge a reasonable fee where we do provide access.
If you believe that personal information we hold about you is incorrect, incomplete or not current, you may request that we update or correct your information by contacting us. We will deal with your request within a reasonable time. If we do not agree with the corrections you have requested (for example, because we consider that the information is already accurate, up‑to‑date, complete, relevant and not misleading), we are not required to make the corrections. However, where we refuse to do so, we will give you a written notice setting out the reasons.
We do not adopt, use or disclose government related identifiers except as required or permitted by law.
If you have a complaint in relation to the collection, storage, use or disclosure of your personal information, please contact our Privacy Officer using the details below. You will need to provide us with details of your complaint, as well as any supporting evidence and information. We will review all complaints received and our Privacy Officer will respond to you. If you are not satisfied with our response, you may discuss your concerns with or complain to the Australian Privacy Commissioner via www.oaic.gov.au.
HOW TO CONTACT US
(a) by email to privacy [at] thinkplace.com.au
(b) by writing to: Privacy Officer, PO Box 5249 Kingston ACT 2604
(c) by telephone: (02) 6282 8852
(d) by fax: (02) 6282 8832
Effective date: 12 March 2019