- NI provides delivery of document generation services. VL provides content for certain documents generated via NI's services.
- The purpose of this Policy is to detail how we protect your privacy and how we comply with the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
- “Personal information” is any information that allows an individual to be personally identified.
This policy describes:
- From whom we collect information;
- The types of personal information collected and held by us;
- How this information is collected and held;
- The purposes for which your personal information is collected, held, used and disclosed;
- How you can gain access to your personal information and seek its correction;
- How you may complain or inquire about our collection, handling, use or disclosure of your personal information and how that complaint or inquiry will be handled;
- Whether we are likely to disclose your personal information to any overseas recipients;
- How we report any data breaches.
2. Who do we collect personal information from?
NI and VL collects information from our clients, our suppliers, our staff and our sub-contractors.
3. What kinds of personal information do we collect?
In using the Will Service you acknowledge and agree as follows:
- The kinds of personal information NI and VL collects is largely dependent upon whose information we are collecting and why we are collecting it, however, generally we collect personal information such as name, address, telephone numbers, email address. Sometimes we may collect other personal information from you, such as the type of services you may be interested in NI and VL providing to you. We endeavour not to collect personal information that we do not require.
- We endeavour to collect personal information directly from the individuals concerned. However, if this is not practicable, we may collect personal information about individuals from third parties, including from publicly available sources. If we do, we will take reasonable steps to ensure that the individuals concerned are made aware of the collection of their information.
- If you are a business contact, such as a supplier or from a government agency, we may collect basic business contact information from you, such as your name, title and work contact details. We will not ask to collect sensitive information about you (such as details of your racial or ethnic origin, political affiliation, religious beliefs, sexual preferences, criminal convictions or health information) unless it is needed for the purposes of providing services.
4. How do we collect your personal information?
We may collect personal information from you when you:
- Answer questions via the online services;
- Instruct NI or VL to provide you with services;
- Purchase or subscribe to a NI or VL online service;
- Subscribe to a NI or VL newsletter;
- Attend a NI or VL seminar or marketing event
- Have business dealings with NI or VL; or
- Apply or register your interest for employment with NI or VL.
5. How do we use your Personal Information?
- We only to use personal information collected from business contacts for the business purpose for which it was collected.
- We also collect personal information so that we can communicate new developments to our clients and to those people who have subscribed to our website or mailing lists. If, at any time, you do not wish to receive these kinds of communications, please let us know.
6. Will Your Personal Information be given to anyone else?
We do not sell, rent or otherwise trade Personal Information with third parties.
Personal information may be disclosed only in the following circumstances:
- We may disclose personal information to external service providers who help us operate our business. We will take steps to ensure that those external service providers comply with the Australian Privacy Principles when they handle personal information about you (even if they may be exempt from the privacy laws) and are authorised only to use Personal Information for the limited purposes specified in our agreement with them.
- Where we engage external information technology service providers, we ensure that wherever possible, our data is stored within Australia. Some of our vendors do however store data in overseas locations.
- Otherwise, we will only disclose personal information if this is required by law or permitted under the Privacy Act. We are bound by professional obligations of confidentiality, including in relation to personal information.
7. Storage and security of personal information
- We store personal information in a variety of formats including on databases, in hard copy files and on personal devices including laptop computers, mobile phones, cameras and other recording devices. We may store information in the ‘cloud’ which may mean that it resides on servers which are situated outside Australia.
The security of your personal information is of importance to us and we take all reasonable steps to protect the personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure. These steps include:
- Restricting access to information on our databases on a need to know basis with different levels of security being allocated to staff based on their roles and responsibilities and security profile.
- Ensuring all staff are aware that they are not to reveal or share personal passwords.
- Implementing ICT security systems, policies and procedures, designed to protect personal information storage on our computer networks.
- Implementing human resources policies and procedures, such as email and internet usage, confidentiality and document security policies, designed to ensure that staff follow correct protocols when handling personal information.
- As far as practicable, where personal information we hold that is no longer needed is destroyed in a secure manner, deleted or de-identified as appropriate.
- Our website may contain links to other websites. We do not share your personal information with those websites and we are not responsible for their privacy practices. Please check their privacy policies.
8. When we disclose personal information
- We only use personal information for the purposes for which it was given to us, or for purposes which are related (or directly related in the case of sensitive information) to one or more of our functions or activities.
We may disclose your personal information to government agencies, our service providers, agents, contractors, business partners and other recipients from time to time, only if one or more of the following apply:
- You have consented;
- You would reasonably expect us to use or disclose your personal information in this way;
- We are authorised or required to do so by law;
- Disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety;
- Where another permitted general situation or permitted health situation exception applies;
- Disclosure is reasonably necessary for a law enforcement related activity.
- Sometimes our website contains links to other websites, for your convenience and information. When you access a website other than NI or VL’s website, please understand that neither NI nor VL is responsible for the privacy practices of that site. We suggest that you review the privacy policies of each site you visit.
9. Notification of Data Breaches
If we have reasonable grounds to suspect that a data breach has occurred, we will:
- Complete an assessment of the suspected data breach within 30 days;
- If appropriate, take remedial action to address any potential harm to individuals that may arise due to a relevant data breach before any serious harm is caused to individuals to whom the information relates.
- We will otherwise comply with privacy data breach notification requirements, including notifying affected individuals and the Office of the Australian Information Commissioner as applicable.
10. Access to your Personal Information
Under the Privacy Act, you have the right to:
- Seek access to your personal information handled by us;
- Ask us to update or correct your personal information when it is inaccurate, incomplete or out of date; and
- Opt-out of receiving direct marketing communications from us.
- If you wish to access the personal information that NI and VL holds about you, please set out your request in writing, and forward this to NI and VL.
11. Privacy Complaints
- If you wish to make a complaint about a breach by us of the Australian Privacy Principles you may do so by providing your written complaint by email to either email@example.com or firstname.lastname@example.org, letter, or by personal delivery to Principal. You may also make a complaint verbally.
- We will respond to your complaint within a reasonable time (usually no longer than 30 days) and we may seek further information from you to provide a full and complete response.
- Your complaint may also be taken to the Office of the Australian Information Commissioner.
12. How to Contact Us
- To contact VL about this Policy or about your personal information you can email email@example.com and to contact NI you can email firstname.lastname@example.org.
- If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so.
Last updated: 08 June 2017