Innovare Distribution (“Innovare”) and its subsidiaries are bound by the Australian Privacy Principles, which are set out in schedule 1 of the Privacy Act 1988 (Cth). The Australian Privacy Principles can be found at https://www.oaic.gov.au/privacy-law/privacy-act/australian-privacy-principles.
This Policy applies to personal information collected by Innovare Distribution.
This Policy will commence operation from the “Date Issued” date in the panel below. It replaces all previous Innovare Distribution Privacy policies.
Innovare Distribution will only collect personal information (other than sensitive information) by lawful and fair means, and the information is reasonably necessary for, or directly related to, one or more of Innovare Distribution's functions or activities including the supply of goods and services by Innovare Distribution. Innovare Distribution will take reasonable steps to ensure that the individual is aware that information is being collected and, should they require access to information collected, shall provide access subject to reasonable request.
We usually collect personal information such as your name, address, telephone number and, in some cases, financial details. We may collect personal information from publicly available sources.
As a general rule we do not collect sensitive information. However, if we do, it will be where the information is reasonably necessary for the purposes of providing our services and we will seek your consent to collect it.
We collect personal information when we provide our services to you. Generally we will tell you why we are collecting information when we collect it and how we plan to use it and hold it or these things will be obvious when we collect the information.
Sometimes we collect personal information from a third party if you have consented or would reasonably expect us to collect the information in this way, for example from publicly available sources such as websites or telephone directories. If we receive personal information which we did not solicit we will within a reasonable period after receiving the information, determine whether or not we could have collected the information under Australian Privacy Principle 3 if we had solicited the information. If it is deemed to have not been able to have been solicited and is not contained in a Commonwealth record we may destroy the information or ensure that the information is de-identified.
We may use your information to provide our services to you, to fulfil administrative functions associated with these services (for example assessment of credit worthiness), to enter into contracts with you or third parties, and for marketing and client relationship purposes.
We intend to rely upon the employer exemption relating to employee records to the extent that it applies.
You are not required to provide us with any personal information when visiting our website. However, sometimes we need to collect your information from our website to provide services that you request.
We do not collect personal information about you if you only browse our website. Our website only uses session cookies during a search query of the website. When you close your browser the session cookie is destroyed and no personal information is kept which might identify you to us in the future.
4. USE AND DISCLOSURE
Innovare Distribution will only use the provided information for the purposes for which you give it to us and for related, internal management purposes.
We may disclose your personal information to our service providers and contractors from time to time to help us to provide and market our services to you. If we do this we generally require these parties to protect your information in the same way we do. You may request not to receive direct marketing communications from ATF by contacting our Group Manager Operational Services & Compliance.
5. DATA QUALITY
Innovare Distribution will take reasonable steps to ensure that the data collected, is accurate, complete and up-to-date.
Innovare Distribution will take reasonable steps to ensure that the data used or disclosed is accurate, up-to-date, complete and relevant.
6. DATA SECURITY
Innovare Distribution will take reasonable steps to protect personal information it holds from unauthorised access, modification or disclosure and also against misuse, interference and loss.
Innovare Distribution will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed.
We use a variety of physical and electronic security measures [including restricting physical access to our offices and firewalls and secure databases to keep personal information secure from misuse, loss or unauthorised use or disclosure].
The Internet is not a secure environment. If you send us information, including your email address, it is sent at your own risk.
7. ACCESS AND CORRECTION
Generally you have a right to access most personal information we hold about you and if we deny access in some circumstances we will tell you why. Subject to a reasonable request being made, you have a right to seek correction of your personal information by ATF.
8. SENSITIVE INFORMATION
Innovare Distribution will not collect sensitive information about an individual unless the individual has consented or the collection is required by law.
9. IMPORTANT INFORMATION:
If you would like more information about our approach to privacy, please contact our Head Office on (02) 8860 8114.
Our Office is bound by the Information Privacy Principles of the Privacy Act 1988.
Our website follows the Privacy Commissioner’s Guidelines for Federal and ACT Government Websites.
Please contact our Group Manager Operational Services & Compliance to ask for access to your information or if you have a complaint concerning your information privacy.
If you would like more information about our approach to privacy please contact our Group Manager Operational Services & Compliance.
10. PRIVACY COMPLAINT HANDLING
This Privacy Complaint Handling Procedure sets out the process we will undertake to deal with complaints regarding breaches of Australian privacy law including under the Privacy Act.
Any complaints should be made in writing to the Group Manager Operational Services & Compliance at PO Box 47, Concord NSW 2137 or by email at firstname.lastname@example.org.
Innovare Distribution will resolve privacy complaints through this procedure:
- A privacy complaint is received (“Complaint”)
- Within ten (10) business days following receipt of the Complaint, Innovare Distribution will send a communication via post or email to the person whom made the complaint (“Complainant”) acknowledging receipt of the Complaint.
- Following the acknowledgement of receipt of the Complaint, the Group Manager – Operational Services & Compliance will conduct an investigation of the Complaint. During this process a request for further information may be made to the Complainant.
- Within forty-five (45) business days from the date all information is received, the Group Manager – Operational Services & Compliance will notify the Complainant of proposed avenues of resolution. The Complainant and the Group Manager- Operational Services & Compliance may work together to collaboratively resolve the Complaint to the Complainant’s satisfaction.
- The Group Manager – Operational Services & Compliance will notify the Complainant if additional time is needed to respond due to the complexity of the inquiry.
- In circumstances where resolution cannot be achieved in accordance with the above, the Group Manager – Operational Services & Compliance will advise the Complainant that they may direct their Complaint to the Federal Privacy Commissioner or take independent advice as to their rights.
The following are situations where Innovare Distribution may decline to deal with a complaint:
- The complaint does not concern the personal information of the complainant.
- The complaint concerns the personal information of a child and the person making the complaint is not the parent or guardian of the child.
- The complaint concerns the personal information of an individual and the person lodging the complaint is not an agent of the individual authorised to act on the individual’s behalf.