Civica Pty Limited and each of its related bodies corporate (as that term is defined in the Corporations Act 2001) in Australia (Civica) is committed to the protection of privacy of personal information which it regards as one of its most important core values.
What is personal information?
Personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about a living individual who is either identified or reasonably identifiable. Examples include an individual's name, address, contact number and email address.
Sensitive information is a subset of personal information that is generally given a higher level of privacy protection. Sensitive information includes health and genetic information and information about racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record and some types of biometric information.
Civica is required to comply with the Privacy Act (Cth) (Privacy Act) which includes the Australian Privacy Principles (APPs). The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection/receipt to use and disclosure, storage, accessibility and disposal. Civica is also required to comply with other laws, including more specific privacy legislation in some circumstances. They include Australian State and Territory health privacy legislation (including the Victorian Health Records Act 2001) when we collect and handle certain health information.
Civica is generally exempt from the Privacy Act when it collects and handles employee records.
2. The purposes for which we collect, hold, use and disclose personal information
The main purposes for which we collect, hold, use and disclose personal information are:
Establish and maintain your relationship with us;
Provide the products or services you have requested from us or your suppliers;
Answer any inquiry you make; and
Send notifications, reminders and relevant documentation.
We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or which are required or authorised by or under law or for which the individual has provided their consent.
We may also disclose your personal information to third parties who work with us in our business to provide, promote or improve the products or services you have requested or are interested in, such as: our related bodies corporate; third party service providers ; national regulators; and consultants and professional advisers.
2.2 Use by other Civica entities
2.3 Direct marketing
We may use your, specifically your name and relevant address details and information about your preferences for direct marketing, both as to the communication channels which you prefer for receiving direct marketing from us and the types of products and services in which you are interested, to let you know about our services, facilities and benefits and those of third party partners, contractors, suppliers of Civica, where we have your consent. Under Australian law, we are not permitted to do so unless we have your consent.
Where we are permitted by law to do so, we or our partners, contractors, suppliers may contact you for direct marketing purposes in a variety of ways, including by mail, email, telephone, online advertising or facsimile.
You may opt-out of receiving this direct marketing through the unsubscribe function that will be made available to you with each direct marketing communication, or by contacting us.
3. The kinds of personal information we collect and hold
The type of personal information that Civica collects and holds about you depends on the type of dealings that you have with us. For example, if you contact us with an enquiry, attend a Civica conference or seminar, are a supplier to Civica, receive services from Civica or apply for a job at Civica.
Generally, we collect personal information directly from you, such as when you submit information through our website, in person, in the course of us providing you with a requested product, service or benefit or when you have other dealings with us.
This information is likely to include any or all of the following:
name, address(es), telephone number(s) and other contact details;
dietary and accessibility requirements
payment information (such as credit card or bank details);
other personal information required to provide our services;
transaction details relating to your use of our products, services or benefits; and
your current and previous education and employment or student identification details
3.2. Sensitive information
Civica only collects sensitive information where it is reasonably necessary for our functions or activities and either the individual has consented or Civica is required or authorised by or under law to do so.
For example, we may collect: health information; information about your criminal record, racial or ethnic origin, or religion; information related to health and safety, workplace investigations or workplace environment.
You do not have to provide us with any personal information. However, if you do not do so we may not be able to provide you with the products, services or benefits you have requested.
3.3. Collection of information through our website
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website (such as preventing users from logging on).
3.4. What if you don't want to provide your personal information to us?
Civica seeks to provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to an individual's actual name.
In some cases however, if you don't provide us with your personal information when requested, we may not be able to respond to your request or provide you with the product or service that you are seeking.
4. How we collect and hold personal information
4.1. Methods of collection
Civica is required by the Privacy Act to collect personal information only by lawful and fair means. It is reasonable and practicable, we will collect personal information we require directly from you.
We collect personal information in a number of ways, including:
over the telephone
through written correspondence (such as letters, faxes and emails)
on hard copy forms
in person (for example, at job interviews)
through our website
at seminars and functions (for example, if you fill out an assessment form or leave us your business card)
electronic systems such as applications
through surveillance cameras (which we use for security purposes)
from third parties
4.2. Collection notices
When Civica collects personal information directly from you, Civica's policy is to take reasonable steps to notify you of certain matters. We generally do this at or before the time of collection, or as soon as practicable afterwards. The matters include:
our identity and how to contact us
the purposes for which we are collecting the information
whether the collection is required or authorised by or under by or under an Australian law or a court or tribunal order
the third parties (or types of third parties) to whom we would normally disclose information of that kind
whether any of those third parties are located overseas and, if practicable to specify, the countries in which they are located
We will generally include these matters in a collection notice.
4.3. Unsolicited information
Unsolicited personal information is personal information we receive that we have taken no active steps to collect (such as an employment application sent to us by an individual on their own initiative, rather than in response to a job advertisement).
We may keep records of unsolicited personal information if the Privacy Act permits it (for example, if the information is reasonably necessary for one or more of our functions or activities). If not, Civica will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.
5. Disclosure of personal information to third parties
Personal information may be disclosed to the following third parties where appropriate for the purposes set out above:
Financial institutions for payment processing
referees whose details are provided to us by job applicants
marketing and communications agencies
external business advisers (such as recruitment advisers, auditors and lawyers)
regulatory bodies as required by law
In the case of contracted service providers, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services.
6. Cross border disclosure of personal information
7. Data quality and security
We hold personal information in a number of ways, including in electronic databases, email contact lists, and in paper files held in drawers and cabinets, locked where appropriate. Paper files may also be archived in boxes and stored offsite in secure facilities.
We takes reasonable steps to:
make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant; and
protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure
Where we provide personal information to third parties, we use contractual measures to protect this information.
Additionally, we take reasonable steps to destroy or permanently de-identify personal information when we no longer need it.
The internet is not a secure method of transmitting information. We cannot and do not accept responsibility for the security of information you send to or receive from us over the internet, or for any unauthorised access or use of that information.
The steps we take to secure the personal information we hold include ICT security (such as encryption, firewalls, anti-virus software and login and password protection), secure office access, personnel security, training and workplace policies.
Our websites may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
8. Access and correction of your personal information
Individuals have a right to request access to the personal information that Civica holds about them and to request its correction.
You can contact us at the details set out below if you would like to access or correct the personal information that we hold about you. We may ask you to verify your identity before processing any access or correction requests, to ensure that the personal information we hold is properly protected.
Civica's policy is to provide you with access to your personal information, subject to some exceptions permitted by law. We may provide access in the manner that you have requested provided it is reasonable and practicable for us to do so. We may charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
If you believe that your privacy has been breached or you have a complaint in relation to our handling of your personal information, please contact us using the details below and provide details of the incident. We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and your complaint is resolved within a reasonable time (and in any event within the time required by the Privacy Act, if applicable).
If you are unhappy with our response, you can refer your complaint to the Office of the Australian Information Commissioner or, in some instances, other regulatory bodies, such as the Victorian Health Services Commissioner.
10. Retention of personal information
All personal information that has been collected from you will only be kept for a limited duration that is relevant to the purpose for which your personal information is to be used and for as long as required by applicable law.
11. Further information
Please contact Civica if you have any queries about the personal information that Civica holds about you or the way we handle that personal information. Our contact details for privacy queries and complaints are set out below.
Privacy Contact - People & Development
Civica Pty Limited
163 O'Riordan Street