For the purposes of this, any reference to The Company, Company, or Company People shall include all of Longevity Group Australia Ltd and associated entities.
The Company’s policy is regularly reviewed and monitored against industry benchmarks and regulatory requirement to enable the Company to maximise the protection of personal data.
3 Roles & Responsibilities
|Board of Directors
||Endorse oversight, comply with and review policy. Assess performance of senior management.
||Comply with policy and implement policy. Assess and monitor management and staff.
||Comply with the policy. Report and monitor staff & consultants etc.
||Comply with Policy
Australian Privacy Act
Privacy Amendment (Enhancing Privacy Protection) Act 2012
Corporations Act 2001
Australian Privacy Principals (March 2014)
5 Policy Principles
5.1 Collection of Personal Information
The sort of personal information that the Company gathers will depend on the dealings the individual may have with the Company.
The Company may gather and hold personal information about people who:
- purchase, or express an interest to buy, a Longevity home;
- lease, or express an interest to rent, premises or spaces, including any related underwriters;
- supply products and/or service offerings (e.g. Required for setting up records and frameworks to allow instalment payments or the like);
- seek work with the Company or are the Company representatives;
- are security holders in the Company or are responsible for providing resources into the Company (for instance, setting up accounts etc.);
- register to join the distribution and contact lists for Company projects and products including announcements and pamphlets etc;
- use the Company’s sites, web-based social networking and other online services;
- use versatile applications created by the Company or logon to remote offices of the Company; or
- may generally come into contact with the Company.
The Company only gathers personal information which is required for its dealings with the person. The sorts of personal information held may incorporate, yet are not restricted to:
- information that recognizes the person (e.g. name, sex, address, date of birth, photographic or video pictures and voice recognition);
- information about the person’s monetary position and credit-value;
- data about the person that is required or approved by law;
- the person’s Tax File Number;
- the person’s supposition about the Company’s products, reputation or staff.
The Privacy Act forces limitations on gathering sensitive individual data, for example, data about religious perspectives, ethnicity, political conclusions and individual wellbeing. The Company for the most part does not gather sensitive personal information around a person. Having noted this, under specific conditions, the Company may gather some delicate data on the off chance that it is important to enable the Company to manage the person and if the person has given consent for the Company to do so.
5.2 Advice of collection of personal information
5.3 Use and disclosure of Personal Information
The Company has various associated entities which handle personal information. The Company’s arrangement is to utilise personal information for the reason which was either determined or clarified when the data was gathered. The Company may utilise or share the data gathered for some other related reason for which the person would sensibly anticipate that it will be utilised.
In the event that the Company wishes to utilise or share the personal information under different conditions, it needs to get the person’s agreement to do so.
As a rule, the Company utilises personal information for the purposes bulleted below:
- providing services or products that have been asked for;
- communicating with the person;
- assessing the reasonableness of planned occupants of a Longevity property;
- helping the Company oversee and upgrade its services and products, including reviewing client criticism and future client needs;
- providing updated information and showcasing services and products to people that the Company accepts might be potential customers;
- managing security and WHS prerequisites on the Company properties;
- complying with regulations;
- complying with legal obligations;
- recruiting Longevity people; or
- fulfilling its commitments to stakeholders.
5.4 Disclosure of Personal Information to other entities or bodies
Other entities or bodies might be offered access to personal information held by the Company in specific conditions. These incorporate, however are not restricted to:
- the Company’s temporary or contract workers and specialist organisations who help the Company in the task of its business or to give a client benefit (for instance, an organization which keeps up the Company’s Cyber frameworks or executes the Company’s sales);
- partners for when seeking regulatory authority approvals;
- third party loan specialists and insurance companies;
- the Australian Securities and Investments Commission and to other government offices as consented to or required by law;
- anyone approved by a supplier of personal information;
- relevant parties in circumstances when the Company is required by law to give the data.
The Company does not sell personal information to entities or bodies outside the Company.
The Company may send advertising materials to its customers or potential customers where the Company has gathered the personal information from the individual and the individual would sensibly anticipate that the Company will utilise the data for that reason.
The person’s earlier consent will be obtained before personal information is utilised for showcasing purposes in circumstances where the personal information has been gathered from the individual and the individual would not sensibly anticipate that the Company will utilise the data for that reason, the personal information has not been gathered directly from the individual or where delicate data is included.
Should the person wish the Company to cease utilization of their own data all together for the Company to provide sales or marketing materials, the person is to advise the Company by means outlined in the electronic advertising message sent to them or to contact the Company’s Privacy Officer.
The Company also collects, holds, uses and discloses your information for the following purposes:
- To improve our services through quality improvement activities such as audits, surveys and other quality improvement activities.
- To obtain professional advice.
5.6 Prospective employees, consultants and contractors
The Company collects privacy information from:
- The individual
- Referees proposed by the individual
- From previous employers
- National Police Check upon the individual’s provision of consent and identification information required to complete such a check
5.7 Cross border transfer or disclosure of information
In the event the Company engages in cross border transfer of information, such as routing or storing information on cloud servers located overseas, the Company will ensure that adequate security mechanisms are in place to protect your information. For example, the Company will enter into a contract with the cloud service provider that ensures the information is for the limited purpose of storing and managing the personal information.
The Company does not currently or plan to make cross border disclosures of privacy information to entities overseas.
5.8 Maintaining the integrity, currency & safety of privacy information
This section explains how the Company holds privacy information, how individuals can access their privacy information, update privacy information, complain about an alleged breach of the Australian Privacy Principles (APPs) or make any related enquiry. A link to the Australian Government website is embedded in this document: OAIC 13 Privacy Principles
5.8.1 Maintaining currency of Privacy information
The Company relies on accurate and reliable information to deliver necessary and effective services. If the company is satisfied that any of the information it holds about a person is inaccurate, out-of-date, irrelevant, incomplete or misleading, or the individual requests the Company corrects any information, we will take reasonable steps to ensure the information held by us is accurate, up-to-date, complete, relevant and not misleading.
The practical measures by which the Company avoids having an incorrect record of a customer, potential customer, stakeholder, consultant or a Company person’s information include asking individuals to complete the appropriate forms for their business with the company.
If the Company discloses privacy information that is later corrected, it will, or else the individual may ask it to, notify the entity that received the incorrect information about that correction.
Should the Company refuse to correct the information, the Company will explain the reasons for refusal. The Company will also show the individual the complaint procedure if you wish to lodge a formal complaint about its refusal.
5.8.2 Safety of Privacy information
All privacy information is securely stored using appropriate physical and/or electronic security technology, settings and applications, and by ensuring staff dealing with privacy information is trained in The Company’s privacy policies and procedures.
These policies are designed to protect privacy information from unauthorised access, modification or disclosure; and from misuse, interference and loss.
5.9 Transfer/closure of the Company
In the event that the Company ceases to operate, or the business is sold or transferred the Company will ensure that adequate mechanisms are in place to protect individuals’ privacy information. The Company will take all reasonable steps to notify individuals of the transfer or closure of the business or practice, including publishing a notice in a local newspaper that is circulated in the locality of the business.
The Company may elect to retain an individual’s privacy information or transfer it to the company that takes over the business or practice. In circumstances where the Company elects to retain privacy information, it will be secured or lawfully destroyed.
6 Accessing personal information or lodging a complaint
6.1 Accessing and correcting information
Individuals are entitled at any time, upon request, to access their privacy information held by the Company. The Company will respond within a reasonable time after the request is made and give access to the information in the manner requested by the individual, unless it is impracticable to do so. The Company is entitled to charge a reasonable administrative fee for giving access to the information requested.
Should an individual be refused access to their information, the Company will explain the reasons for refusal – any exceptions under the Privacy Act or other legal basis relied upon as the basis for such refusal – and, if the individual wishes to lodge a formal complaint about our refusal, we will explain the complaint procedure.
6.2 Lodging a complaint
The Privacy Officer will make good faith efforts to rectify the issue and respond within a reasonable period after the complaint is made.
6.3 Contact details
Longevity Group Australia
First Floor, 277 Camberwell Road
Camberwell, Vic 3124
Phone: (03) 9275 8000
||Directors, management, employees, secondees, contractors, consultants and visitors engaged in any Company related activities
||As defined by the Privacy Act
‘Information or an opinion about an identified individual, or an individual who is reasonably identifiable: whether the information or opinion is true or not; and. whether the information or opinion is recorded in a material form or not’.
||Longevity development property including but not limited to a unit; townhouse; or intergenerational home.
||Individual or company seeking or showing interest in either purchasing, leasing or renting a Longevity Property
||Any property either owned or operated by Longevity Group Australia Ltd
||includes information relating to health or religion, racial or ethnic origin.