1. Policy Introduction
Beach is committed to protecting the privacy of individuals’ personal information.
“Personal information” is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or not and whether the information or opinion is recorded in a material form or not.
Beach is bound by the Privacy Act 1988 (Commonwealth) (Act) and the Australian Privacy Principles that are contained in that Act.
2. Collection of Personal Information
Beach may collect personal information about an individual in a variety of ways, including when an individual interacts with Beach in person or electronically, for example when an individual accesses Beach’s website.
Beach will only collect personal information about an individual where the information is reasonably necessary for one or more of Beach’s functions, operations or activities or to comply with the law. The kinds of personal information collected and held, how that information is collected and held and the purposes for which that information will be collected, held, used and disclosed will depend on the circumstances.
Examples of instances where personal information may be collected by Beach include:
(i) Shareholder Information;
(ii) As part of Beach’s general business operations;
(iii) Employees and contractors;
(iv) To manage on-site operations;
(v) Emergency management;
(vi) To assist with queries;
(vii) To consider applications from prospective employees or contractors;
(viii) To comply with the law.
Examples of the kinds of personal information Beach may collect and hold include:
(iii) Phone number;
(iv) Fax number;
(v) Email address;
(vi) Information about goods or services ordered, acquired or supplied;
(vii) Information from enquiries made;
(viii) Communications between Beach and an individual; and
(ix) Credit card information
Beach will take reasonable steps to ensure that the personal information that is collected, used or disclosed by it is complete and up to date.
Beach will generally collect information directly from the individual to whom it relates. Beach may also collect information about an individual from a third party, such as a contracting company or via third party service providers (including Beach’s share registry service provider and recruitment service providers providing services to Beach)
Beach may also receive third party personal information from its employees and contractors, including details of family members and next of kin.
Beach may supplement the information that it collects with information from other sources, such as generally available publications and other information accessible on the internet.
3. Use and Disclosure of Personal Information
In most circumstances, at or before, or if that is not practicable, as soon as practicable after, the time that the personal information is collected, Beach will take reasonable steps to ensure that the individual is aware of the matters required by the Australian Privacy Principles, including:
(i) Why the personal information is being collected;
(ii) Who else the personal information might be given to;
(iv) How to contact Beach, including to make a complaint.
If Beach collects personal information about an individual from someone else, Beach will take reasonable steps to ensure that the individual is aware that Beach has collected the information and of the above matters.
Beach will only use or disclose this personal information for:
(i) The purpose for which it was collected;
(ii) Any related purpose for which it would reasonably be expected to be used or disclosed;
(iii) A purpose required or permitted by law; or
(iv) A purpose for which the individual has provided consent.
Examples of instances where Beach may disclose personal information about individuals to third parties include disclosure to:
(i) Government agencies or regulatory authorities, where required;
(ii) Related bodies corporate of Beach;
(iii) Beach’s suppliers, service providers, professional advisers and agents (Beach requires its service providers to keep the personal information confidential and not use it for any purpose other than performing those services);
(iv) Joint venture partners;
(v) Anyone to whom Beach’s assets or business (or any part of it) is transferred;
(vi) Where necessary to protect the rights or safety of any of its employees or a third party;
(vii) Where an individual to whom the personal information relates has consented to the disclosure; or
(viii) Where otherwise required or permitted by law.
Where appropriate, Beach may handle personal information relying on exemptions that may be available under applicable privacy laws including, for example, the employee records exemption in the Privacy Act and provisions in the Privacy Act concerning the sharing of personal information among related bodies corporate.
4. Cross-Border Disclosures
Beach is unlikely to disclose personal information to overseas recipients. However, as Beach has subsidiaries in other countries, it is possible that Beach may disclose information to recipients that are located outside Australia. Beach may disclose personal information to overseas contractors, and may use offshore servers for the purpose of data storage.
Beach may also disclose certain personal information to its related entities in foreign countries, although such information will typically only relate to employees and internal corporate matters as required as part of Beach’s business operations.
Beach will take commercially reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
5. Cookies and IP Address Tracking
Beach’s website may also detect and use an individual’s IP address or domain name for internal traffic monitoring and capacity purposes or to otherwise administer the website. No personal information is obtained, rather the patterns of usage of visitors to the website may be tracked for the purposes of providing improved service and content based on aggregate or statistical review of user site traffic patterns.
6. Links to Other Sites
The Beach website may contain links to other websites. Beach is not responsible for the privacy practices or the content of such other websites. The privacy policies applicable to such other websites may differ substantially from this privacy statement. Beach advises individuals to read them before using those websites.
7. Security of Personal Information
Beach will take reasonable steps to ensure that the personal information that it holds is protected from misuse, interference and loss and from unauthorised access, modification and disclosure.
Beach implements physical and electronic measures to protect personal information. Please note however that the internet is not a secure environment and although all care is taken, Beach cannot guarantee the security of information provided to it via electronic means.
Beach will also take reasonable steps to ensure that personal information it holds that is no longer necessary for the disclosed purpose is destroyed or permanently de-identified, subject to any legal obligation to keep the personal information for any required period of time.
8. Access to, Updating and Correcting Personal Information
At the request of an individual, Beach will, in most circumstances, provide access to an individual to any personal information that is being held by Beach about that individual. There are certain circumstances where Beach will not provide an individual access to such personal information in accordance with the Act. These circumstances include where providing access would have an unreasonable impact on the privacy of others, where providing access would reveal commercially sensitive information about the organisation or where providing access would be unlawful. Where Beach will not provide access to personal information held about an individual, Beach will tell the individual why.
When an individual requests access to personal information, Beach may need to take measures to verify the individual’s identity before providing them with such information.
An individual can seek access to, and update or correct, any personal information that is being held by Beach about that individual by contacting the Company Secretary at (08) 8338 2833 or email@example.com.
9. Amendment of Policy
Beach may amend this Policy from time to time.
10. Intranet and Website
This Policy as amended from time to time is to be placed on Beach’s intranet and website and is also available upon request.
11. Concerns, Queries and Complaints
If a person has any concern, query or complaint about:
(i) Any personal information that may have been collected, used or disclosed by Beach;
(iii) A breach of the Australian Privacy Principles, they are to be referred to the Company Secretary.
Beach takes complaints very seriously and will respond shortly after receiving written notice of the complaint. If the complainant considers that Beach has failed to resolve the complaint satisfactorily, the complainant can complain to the Office of the Australian Information Commissioner.
For further information about Beach’s privacy policies or practices please contact the Company Secretary at (08) 8338 2833 or firstname.lastname@example.org