introduction

srt marketing has prepared this policy to assist our staff, clients and other individuals to understand the purpose of our collection and use of personal information.

Rights of access to personal information and the procedure for lodging complaints in relation to alleged breaches by us of privacy are also addressed.

We acknowledge our responsibilities in the proper handling of personal information we collect and hold. The Privacy Act 1988 (Cth) as amended formalises our existing privacy obligations to individuals whose personal information is held by us.

If you have any questions regarding this policy, please get in touch.

definitions

Terms used in this policy are defined as follows (unless otherwise stated):

• clients means clients of srt marketing
• collection means the gathering of personal information of any individual and includes the retention of personal information. Collection can be by accident and includes involuntary gathering of personal information
• health information includes information or opinions about the health or disability of any individual or the nature of health services received or receivable by an individual
• srt marketing means srt marketing, ABN 304 127 602 99 and also means we, us and our
• personal information means any information or an opinion capable of identifying an individual (whether a member or third party), including the individuals name, address, contact telephone numbers and email address
• policy means this privacy policy
• primary purpose in relation to use and disclosure depends on the nature of the business of the person or organisation collecting the information. It is the main or dominant reason for which information is collected
• sensitive information includes health information and other personal information about the political affiliation, religion, sexuality, racial or ethnic origin and any criminal record
• use and disclosure occurs when information is handled within the organisation of the person collecting the information. Disclosure is made when personal information is released outside the organisation of the person collecting the information.

collection of personal information

We will only collect information that is necessary for our functions and operation.

We collect personal information for the primary purpose of providing marketing and communications consulting services to our clients.

To assist with this primary purpose, we collect and hold personal information and relevant personal information arising from our clients' activities.

We will be fair in the way we collect information.

When we require personal information from our clients, this information will be collected directly from the client or another person authorised by that person, wherever possible.

use and disclosure of personal information

We will only use or disclose information for the purpose for which it was obtained.

In providing advice and consulting services, we may be required to disclose personal information to third parties, including our insurers, professional advisers, governmental and other regulatory bodies and authorities, mail houses, printers and any freelance contractors we choose to appoint depending on the engagement.

Personal information held by us will only be disclosed for the purpose of providing the above services. Wherever practicable, and lawful, this personal information will be provided in a de-identified form.

We may, as permitted by The Privacy Act 1988 (Cth), disclose your personal information in any emergency and in consequence of an investigation of suspected criminal activity or where we are authorised or required by law.

We may from time to time provide statistical data to third parties for research purposes. Wherever practicable and lawful, this information will be de-identified prior to disclosure.

data quality

We will take reasonable steps to ensure that information is accurate when collected, used or disclosed.

We will update personal information to ensure as far as possible that the information we hold is accurate complete and current. Updating personal information will be considered as collection and will be undertaken in accordance with the provisions on collection as set out in this policy.

data security

We will keep information secure.

We protect the personal information we hold by:

• securing our premises to allow access to staff only
• placing passwords and varying access levels on databases to limit access and protect electronic information from unauthorised access, modification and disclosure, and
• providing locked cabinets for the storage of physical records.

We will provide our staff with information and training on the National Privacy Principles, the privacy implications of the information they handle and our policy on handling of information.

We will dispose of or de-identify any personal information we no longer require, safely and securely.

openness

We will be open about what kinds of personal information we hold and how it is used.

Our policy is available in documentary form to anyone who asks for a copy of it at no charge to the individual. On written request by an individual, we will disclose in general terms what sort of personal information we hold about the individual, why that personal information is held, how it was collected, and how it is to be used.

To make a request, please get in touch.

access and correction

We will, wherever possible, allow access by individuals to the information we hold about them and correct that information if it is wrong.

To make an access request, please get in touch.

No costs will be associated with this request. We will endeavour to respond to requests within 30 days of receipt. Should a request for access be declined, reasons for this will be provided, together with an outline of the procedure to have this decision reviewed.

We will, upon request, correct any information about an individual that the individual considers is not accurate, correct or up to date.

Should an individual find after accessing their personal information that the record is inaccurate in any way they should notify us in writing of the inaccuracy. We will then either correct the information if appropriate, or include the notified correction with its records.

identifiers

We will not use any identifier assigned by a government agency.

We will continue to identify our clients by way of code assigned by us. We will not use or disclose any Tax File Number, Social Security Number, ACN, ABN, Medicare number or other such Commonwealth identifier we may hold, except as required by law.

trans-border data flows

We will take reasonable steps to protect privacy if we send personal information overseas.

We may be required to transfer personal information we hold to a foreign country. Should this be necessary we will endeavour to ensure that the recipient will not hold, use or disclose that information in a manner which is inconsistent with the National Privacy Principles.

sensitive information

We will limit the collection of sensitive information.

Wherever practicable, we will not collect sensitive information relating to health, racial or ethnic origin, sexuality, political opinion, religious beliefs or affiliations.

breach of the National Privacy Principles and complaints

An individual who believes that one or more of the National Privacy Principles has been breached by us has the right to make a complaint.

To make a complaint, please get in touch.

Upon receipt of a complaint we will consider the complaint and attempt to resolve it.

Individuals who are dissatisfied with the outcome may ask the Federal Privacy Commissioner to make a determination in accordance with The Privacy Act 1988 (Cth).

If you have any questions regarding this policy, please get in touch.

srt marketing’s privacy policy, published June 2009, version 1.0