1. COMMITMENT TO PRIVACY
Northerly Group Australia Pty Ltd (ABN 50 143 783 911), its subsidiaries and affiliates in Australia (collectively referred to as Northerly) are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws.
2. ABOUT NORTHERLY
Northerly is a full-service commercial and residential building and development company providing effective, efficient and economical construction services to the private sector and enterprise.
3. COLLECTED INFORMATION
‘Personal information’ is information or opinion (in recorded form or otherwise) about an identified, or reasonably identifiable, individual. This includes your name, your date of birth and your contact details, and may also include information about your dealings with us.
‘Sensitive information’ is a sub-set of personal information and includes information or opinions about your racial or ethnic origin, political opinions, memberships, religious beliefs, sexual orientation, health or criminal record.
Northerly will collect information and personal information from the following groups:
(a) Clients and prospective clients
When you enquire about our services or when you become a client of Northerly, a record is made which includes your personal information.
The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:
- your name, e-mail, postal address, telephone number and other contact details;
- information about your employer or an organisation who you represent;
- your professional details; and
- any additional personal information you provide to us, or authorise us to collect, as part of your interaction with Northerly.
(b) Prospective employees or applicants
We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.
We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions. This may include information about the employee’s health, their right to work in Australia, or other sensitive information. For some roles, employees may need to obtain a security clearance or provide a criminal history search.
Under the Privacy Act, personal information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship. We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.
(c) Other individuals
Northerly may collect personal information about other individuals who are not clients of Northerly. This includes customers and members of the public who participate in events we are involved with, individual service providers and contractors to Northerly, and other individuals who interact with Northerly on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with Northerly. Generally, it would include:
- your name, e-mail, postal address and other contact details;
- information regarding our interactions and transactions with you.
If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
In limited circumstances, Northerly may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by Northerly, we may collect health information about you in an emergency or otherwise with your consent.
You can always decline to give Northerly any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.
(d) Visitors to our websites
The way in which we handle the personal information of visitors to our websites is discussed below.
4. PROCESS AND PURPOSE FOR HANDLING PERSONAL INFORMATION
Northerly collects personal information reasonably necessary to carry out our business, to assess and manage our client’s needs, and provide services. We may also collect information to fulfil administrative functions associated with these services; for example, billing, entering into contracts with you or third parties, and managing client relationships.
The purposes for which Northerly usually collects and uses personal information depends on the nature of your interaction with us, but may include:
- responding to requests for information and other general inquiries;
- to provide our building, construction and development services;
- to provide you with our communications;
- to provide you with events or seminars;
- to obtain the services of third-party service providers as part of providing our services;
- to manage and improve our services and client relationships;
- where we are otherwise required or authorised to do so by law; and
- otherwise, to run our business.
Without collecting personal information, we would not be able to provide you with some of our services.
Northerly generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:
- our affiliated and related companies; and
- third party suppliers and contractors who assist us to operate our business
Northerly also collects and uses personal information for market research purposes and to innovate our delivery of products and services.
5. INTERACTIONS VIA THE INTERNET
You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our
Northerly’s website may contain links to third-party websites. Northerly is not responsible for the content or privacy practices of websites that are linked to our website.
6. ANONYMOUS INTERACTIONS
Northerly will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for Northerly to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.
7. STORAGE OF INFORMATION
Northerly stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
8. DATA SECURITY
Northerly maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.
We take steps to destroy or de-identify information that we no longer require.
9. DATA QUALITY
The accuracy of your personal information is important to us and is fundamental to providing you with proper health care services. We seek to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date and, in the case of use or disclosure, relevant.
10. DIRECT MARKETING
Northerly may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.
If you opt-out of receiving marketing material from us, Northerly may still contact you in relation to its ongoing relationship with you.
11. USE AND DISCLOSURE
(a) Clients and prospective clients
The purposes for which we may use and disclose your personal information will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may disclose information about you to service providers where this is relevant to our services.
(b) For customers and participants
If you are a customer or participant in an event (and subject to your prior approval) we may disclose your personal information to our clients and venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur.
(c) Disclosure to contractors and other service providers
Northerly may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.
Personal information may also be shared between related and affiliated companies of Northerly, located in Australia and overseas.
Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
(d) Use and disclosure for administration and management
Northerly will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
- administering billing and payments and debt recovery;
- planning, managing, monitoring and evaluating our services;
- quality improvement activities;
- statistical analysis and reporting;
- training staff, contractors and other workers;
- risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
- responding to enquiries and complaints regarding our services;
- obtaining advice from consultants and other professional advisers; and
- responding to subpoenas and other legal orders and obligations.
(e) Other uses and disclosures
12. OVERSEAS DISCLOSURE
We do not routinely disclose personal information overseas. We do disclose personal information overseas when it is specifically appropriate to providing our services for a particular client.
Unless we have your consent, or an exception under the Australian Privacy Principles applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.
In circumstances where your information is disclosed to overseas recipients, those recipients are likely to be located in countries where Northerly and its related entities and affiliates operate.
13. ACCESS AND CORRECTION
You are entitled to access your personal information held by Northerly on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.
You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information, we hold about you and letting us know if your personal details change.
However, if you consider any personal information, we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a written statement with your personal information about the requested correction.
14. QUERIES AND COMPLAINTS
You may make a complaint about privacy to the Privacy Officer at the contact details set out below.
The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint in a timely manner and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that Northerly may have breached the Australian Privacy Principles or the Privacy Act , a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au .
16. CONTACT NORTHERLY
The contact details for Northerly are:
|Northerly Privacy Officer:||Mr Alan Neville|
|Address:||Level 2 / 541 Hay Street, Subiaco WA 6008|
|Phone:||(08) 9442 3800|