The Message Centre Pty Limited (TMC) and its related companies comply with the Australian Privacy Principles contained in the Privacy Amendment (Enhancing Privacy Protection) Bill 2012, amending the Privacy Act 1988 (Cth) and the Information Privacy Principles contained in the New Zealand Privacy Act 1993 (to the extent these apply to each TMC entity).
Personal information is any information that could identify a person or be used to establish a person’s identity, including information of a customer, or their customer.
How different types of personal information are collected
The personal information that TMC collects could include your name, age, gender, the organisation you work for and ABN, your physical address, postal address, telephone and fax numbers and your e-mail address. In some circumstances, a failure to provide such information could result in TMC being unable to assist you or provide its services to you. TMC primarily collects information about you when you use or request a product or service, complete a survey, questionnaire or when you communicate with TMC by e-mail, telephone, in writing or in person. TMC also collects information about you if you are providing goods or services to TMC or, if you apply for employment at TMC, through the staff recruitment and selection process.
We will only collect information about an individual for purposes which are relevant to TMC business. For example, we may collect an individual's name, contact information and other details relevant to our business relationship with that person. In some cases we may also be required by law to collect personal information, for example, occupational health and safety laws, laws relating to consumer credit, anti-money laundering or corporations. This information may be required to respect an individual's request or provide our services.
In some instances if all necessary personal information is not provided, TMC may be unable to assess or process your information or provide you with the services you require.
We may also collect anonymous information regarding visitors to our TMC website. This may include Internet Protocol (IP) address, previous sites visited, internet provider location and date and time of the visit.
We may collect sensitive information, such as health information and information about personal attributes such as nationality when it relates to the provision of a service or its evaluation. Sensitive information also includes information or an opinion relating to a person’s racial or ethnic origin, political views or memberships, religious beliefs or affiliations, membership of a professional or trade association or trade union, sexual orientation or practices and criminal record – though we would need a specific need if we were to request such information. TMC will only collect this information with your consent or otherwise in accordance with the Australian Privacy Principles and the New Zealand Privacy Act 1993 (to the extent either are applicable).
How personal information is used
TMC uses personal information to assist it in providing services and for associated business development. TMC also uses personal information to perform its corporate and contractual obligations. Unless otherwise required by law, TMC will not use the information for any purpose other than the purpose disclosed when TMC collects the information. TMC may also collect information in order to improve its service to users of this TMC website.
How personal information is disclosed
Personal information held by TMC is disclosed by TMC in accordance with the Australian Privacy Principles and the Information Privacy Principles contained in the New Zealand Privacy Act 1993 (to the extent either are applicable). TMC will only disclose personal information to a third party where TMC has your consent, or where the disclosure is permitted or required by law. For example, TMC may disclose information as follows:
- TMC related companies
- Clients where required for specific business purposes
- External providers, such as suppliers, consultants and agents, including organizations that provide information technology and infrastructure support services
- Tax, financial, audit and legal advisers
- Government, regulatory and law enforcement bodies
Personal information collected from TMC existing and prospective customers, prospective employees, contractors and suppliers may be transmitted to and stored on databases and/or servers operated and processed by TMC, or their external service providers.
By submitting your personal information, you agree to this transfer, storing and processing. TMC takes reasonable steps to ensure that your personal information is given the same privacy protection as it is afforded in Australia or New Zealand (as the case may be). By providing such personal information customers, employees, contractors and suppliers agree to this transfer, storing and processing of personal information.
Security of your personal information
TMC takes precautions including administrative, technical and physical measures to safeguard your personal information against loss, theft and misuse, as well as against unauthorized access, modification, disclosure, alteration and destruction. We protect electronic data using a variety of security measures including password access, data back-up and firewalls. These measures also include instructing our staff who handle personal information to respect the confidentiality of the information and the privacy of individuals.
Keeping personal information up to date
TMC seeks to ensure that the personal information it holds is accurate, up-to-date and complete. If TMC is informed that the information it holds is inaccurate, out-of-date or incomplete, TMC will correct the information or ensure that the amendments or errors are noted, including by accessing correct information from external sources such as public records.
What we do with personal information when no longer needed
We destroy personal information if it is no longer needed for the purposes for which it was collected, and the law no longer requires us to retain it. We use secure methods to destroy or de-identify the information. We dispose of all hard copy documents and delete electronic information from our systems.
Access and correction
At any time you can advise TMC of changes to your personal information. You have the right to ask for the personal information held about you and to advise of any inaccuracy. If you make an access request, TMC will ask you to verify your identity and specify what information you require. Your request to the Privacy Officer must be in writing. Our contact details are provided in the Further Information section at the end of this document.
TMC may ask the reason for your request so we can assist you most effectively. However, you are under no obligation to provide a reason if you do not wish to. TMC reserves the right to charge a fee for any significant costs incurred by us in providing access to personal information. These costs will be notified to you for your approval prior to providing access.
Although it is not our preference to deny requests for access to a person’s own personal information, TMC may refuse access in certain situations, including where: • giving access would have an unreasonable impact on the privacy of other individuals • giving access would be unlawful, or where denying access is required or authorised by an Australian law or a court order • both of the following apply: (i) The Message Centre has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been, is being or may be engaged in; and (ii) giving access would be likely to prejudice the taking of appropriate action in relation to the matter • giving access is likely to interfere with law enforcement activities.
TMC takes breaches seriously and has procedures to help identify and resolve a breach, potential breach or complaint as quickly as possible. This includes appropriate escalation processes to the General Counsel and notification processes in the event of a breach.
Every complaint is forwarded by the staff member who receives it to the Privacy Officer. You will be notified of the process for dealing with the breach or potential breach. Your complaint will be thoroughly investigated and a suitable resolution negotiated with you.
If you are not satisfied with the resolution of your complaint by TMC, in Australia you may contact the Office of the Australian Information Commissioner (OAIC)(http://www.privacy.gov.au/complaints) who may investigate your complaint. In New Zealand, you may contact the Privacy Commissioner (http://www.privacy.org.nz) who can offer further guidance and investigate your complaint if necessary.
For enquiries or feedback about this policy or for complaints about TMC handling of personal information, please e-mail the Privacy Officer at firstname.lastname@example.org, or by post to Privacy Officer at The Message Centre Pty Ltd, 41 Northern Road, HEIDELBERG WEST Australia 3081, or Telephone 1300 728 268.
This document was last updated on 10th August 2015.