Privacy Policy

1. Purpose

The purpose of this policy is to advise external parties that we are committed to protecting and maintaining the privacy, accuracy and security of their personal information by adhering to the Australian Privacy Principles as outlined in the Privacy Act 1988 (Cwth) and any of its amendments. The Privacy Amendment (Enhancing Privacy Protection) Act 2012 outlines the 13 Australian Privacy Principles which NineWire, as part of the Bayside Group, has adopted.

2. Related Documents

Procedure NAT AP 109               Privacy Procedure (for internal use only)

3. Actions and Responsibilities

We have incorporated the 13 Australian Privacy Principles (APPs) in our policy and procedure and summarise these herein to ensure we meet these minimum standards.

Open and transparent management of personal information (APP1)

Our policy, procedure and practices are set up to ensure we manage personal information in an open and transparent way. We only collect information that is directly related to our business. We do not collect or use personal information for the purposes of unlawful discrimination.

Anonymity and pseudonymity (APP2)

This principle allows for an individual to interact with an organisation by not identifying themselves or to use a pseudonym. The nature of our business means that an exemption applies regarding this principle.

Collection of personal and sensitive information (APP3)

We only collect personal information (e.g. addresses, phone numbers) that is necessary for our business. We only collect sensitive information (e.g. medical history, criminal history) that is necessary to fulfil our requirements and with the individual’s consent.

Dealing with unsolicited personal information (APP4)

If we receive unsolicited personal information, we will establish within a reasonable period whether or not we would have been able to collect the information under APP3 if we had asked for it. If we determine we could not have and it is not on Commonwealth record we will lawfully and reasonably destroy the information or ensure the information is de-identified.

Notification of the collection of personal information (APP5)

Personal information will be collected by our parent company Bayside BWE Pty Ltd for our use and on behalf of NineWire who might require access to your personal information in connection with our business.

We only collect information by lawful and fair means. We only collect from the individual directly unless it is unreasonable or impractical to so.

Our Privacy Procedure and Application Form clearly details the types of personal information we collect, as well as our process for dealing with complaints regarding the information held. A Privacy Officer has been appointed to deal with queries and complaints in line with the Privacy Principles.

Use or disclosure of personal information (APP6)

We will not use or disclose information for a secondary purpose without consent or unless an exemption applies.

Direct marketing (APP7)

We will not use or disclose personal information we hold for direct marketing purposes unless an individual consents to its use. An individual has the right to receive direct marketing communications from NineWire.

Cross border disclosure (APP8)

We may transfer personal information to a recipient overseas. If we do, we will take reasonable steps to ensure the recipient treats the information with regard to this principle. We may transfer information overseas without ensuring this APP is met only with your express consent.

Adoption, use or disclosure of government related identifiers (APP9)

We will not adopt government issued ‘identifiers’ (i.e. tax file number) for our own identification purposes.

Quality of personal information (APP10)

We will take reasonable steps to make sure the data we collect is accurate, up-to-date and complete. We will take reasonable steps to ensure that the personal information we use is all of the above and relevant.

Security of personal information (APP11)

We will take reasonable steps to protect personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure.

We will take reasonable steps to destroy or de-identify information if the organisation no longer needs the information for any authorised purpose unless required by law or is on Commonwealth record.

Access to personal information (APP12)

You are entitled to make a request to access your personal information. We will provide the information in the manner requested where practical in a reasonable time frame unless it is subject to an exemption as listed in the legislation and you are not a current or past employee. In some cases, we may impose a moderate charge for providing the information but you will not be charged because you lodged a request for access. Access will generally be granted but if refused the reasons for refusal will be advised in writing. You will also be able to access our complaints process if you wish to complain about the refusal. If you wish to access your information under this principle contact NineWire.

Correction of personal information (APP13)

We will take reasonable steps to correct personal information to ensure that it is accurate, up-to-date, complete, relevant and not misleading if you request correction and we are satisfied it needs correcting. If we do not agree the information is incorrect and we refuse to correct it as requested, you may ask us to place a statement you prepared with your information claiming the information is inaccurate. We will respond to a correction request within a reasonable period of time and you will not be charged for the correction or inclusion of your statement.

4. What Information We Hold and How We Collect It

Your personal information is held in a variety of ways, most is held in secure computer and paper-based storage and some may be held on portable devices such as mobile phones, laptops or in diaries held by our staff. We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification and disclosure.

We only collect personal information (e.g. addresses, phone numbers) that is necessary for our services. We only collect sensitive information that is necessary to fulfil our services and with the individuals consent.

We do not collect or use personal information for the purposes of unlawful discrimination. We do not collect personal information just because we think it could be useful at some future stage if we have no present need for it. If you browse our web site, we do not collect information that identifies you personally, though we may collect information related to your visit to our website.

5. How We May Use Your Personal Information

Will be used for our statutory compliance obligations.

6. Your Personal Information May Be Disclosed To

Any person with a lawful entitlement to obtain the information.

7. Legal Requirements For Personal Information

Some laws may require that we collect certain types of information. There may be cases where our duties of care or contractual duties require us to obtain and disclose certain types of personal information relevant to our services.

When requesting information of this type we will tell you whether the supply of that information by you is mandatory or voluntary.

8. If You Do Not Give Us All Or Part Of The Information We Need

We may be limited in our ability to service you;

We might decline to represent you.

9. Contact Us

If you wish to contact us regarding your personal information you may do so by contacting:

Your NineWire Representative

The Privacy Officer (NineWire/Bayside Group)

Bayside BWE Pty Ltd

P.O. Box 7280, St. Kilda Road VIC 8004

BH: 03 9864 6000