1. About this policy
Coventry Group Ltd (CGL) recognises the importance of protecting the privacy of our customers. CGL is bound by the Privacy Act and the principles thereunder when handling personal information. This document sets out CGL's practices and procedures on the collection, use, protection and storage of personal information collected from and about its customers. Further details concerning your privacy rights can be found at "The Office of the Australian Information Commissioner" web site at http://www.oaic.gov.au/privacy/privacy-act/the-privacy-act. The Privacy Amendment (Private Sector) Act 2000 extended the operation of the Privacy Act to include the private sector throughout Australia. The Privacy Act 1988 (Cth) and the National Privacy Principles (NPP) stipulate means by which the private sector handles personal information. The Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Privacy Amendment Act) came into operation on 12 March 2014 and includes a set of new, harmonised, privacy principles that will regulate the handling of personal information by both Australian government agencies and businesses. These new principles are called the Australian Privacy Principles (APPs). They replaced the existing Information Privacy Principles (IPPs) that applied to Australian Government agencies and the National Privacy Principles (NPPs) that applied to businesses. Further information on these reforms can be found at the Commissioner’s website: http://www.oaic.gov.au/privacy/privacy-act/privacy-law-reform.
2. Personal information The Privacy Act applies to "personal information" relating to a natural living person. In order for CGL to provide you with the products and services you request, we will collect and store personal information about you, including your:
This information allows us to identify you. In certain circumstances, we may also collect sensitive information such as your membership of a professional or trade association.
- mailing address
- email address
- telephone number
- fax number
3. Collection CGL collects personal information about you when you send us an order, deal with us over the telephone, visit our website or visit us in person. We may also receive personally identifiable information from other sources, such as:
- Business partners
- financial or credit organisations
- suppliers and
- trade referees
4. Use and disclosure CGL uses the information collected about you to meet your requests for our products or services and for the ongoing administration and management of the products and services provided to you.
4.1 Marketing As part of our service, we may use the information to enable us to:
If you do not want to receive marketing information from us let us know and we will remove you from our contact list as soon as possible. CGL does not disclose your contact details to third parties for their marketing purposes.
- Identify products and services which may be beneficial to you
- tell you about new or existing products or services and conduct market research or customer satisfaction surveys.
4.2 Disclosures to other organisations In general, CGL will keep your personal information confidential, and only use and disclose it in accordance with your authority – there are some exceptions to this, which are specified below. The types of organisations that CGL usually discloses your personal information to includes:
All of whom will be required to treat your information in accordance with the Australian Privacy Principles.
- CGL's Associates – which means a holding company, subsidiary or subsidiary of a holding company, and any company in which CGL has a controlling interest or shareholding;
- Aggregate Information to Third Parties – which means any other information, statistical and non-identifiable, may be used and/or distributed to third parties to develop and enhance CGL’s services. Our suppliers and manufacturers - in relation to, for example, recall or warranty claims;
- Market research companies; and
- Debt collecting agencies.
5. Exceptions – use and disclosure without your consent In certain circumstances, CGL may use and disclose your information without your consent. These circumstances include: If the use or disclosure is required or authorised by law, or in accordance with allowable uses and disclosures under the Australian Privacy Principles. Examples of circumstances in which CGL may use and disclosure your information without your consent include: Information that is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body (refer to APP 6.2(e)) or a permitted general situation exists in relation to the use or disclosure of the information (refer to APP 6.2(c)).
6. Data Maintenance and Storage CGL appreciates that it is important to keep your information accurate, complete and up to date and will endeavour to take reasonable steps to do so. CGL will take reasonable steps to destroy or permanently de-identify information when it is no longer needed for any further purposes.
- an information security policy
- allocated information security responsibilities
- regularly perform security education and training
- have a system in place for reporting security incidents
- have a business continuity management plan
- locks and security systems over our paper and electronic data stores and premises monitored online security systems
8. Access and correction You may request access to the personal information that CGL holds about you, and if you believe that it is not correct, you may ask for it to be corrected. You can contact us by:
There is no fee for requesting access, although we may charge a reasonable fee for the cost of processing your request. In certain circumstances, access may be denied, these circumstances include where:
- Writing to us as per Contact Details below (point 12), Attention Privacy Officer
- Telephoning us as per Contact Details below (point 12). We will ask questions to identify you
- Calling into one of our offices and providing appropriate identification
If CGL denies you access for any reason, or refuses to correct your personal information, we will provide you with the reasons why you have been refused access, or the right to correct your personal information. How you can gain access If you are able to establish that information that CGL holds about you is not accurate, complete and up to date, then CGL will take reasonable steps to correct the information so that it is accurate, complete and up to date.
- providing access would have an unreasonable impact on the privacy of others
- the request is frivolous or vexatious
- access relates to existing or anticipated legal proceedings
- denying access is required or authorised under law
- providing access would be unlawful
9. How to Lodge a Complaint? You may use the contact details to notify us of any privacy complaint you have against us, including if you think that we have failed to comply with the Australian Privacy Principles (APP) or any binding APP code that has been registered under the Privacy Act. We are committed to acknowledging your complaint in a prompt manner. While we hope that we will be able to resolve any complaints you may. If you’re not satisfied with our handling of your matter, you can refer your complaint to external dispute resolution. We suggest you do this only once you’ve first followed our internal complaint processes set out above. You may also be able to lodge a complaint with a relevant regulator such as the Australian Information Commissioner (www.oaic.gov.au).
10. Identifiers Identifiers are numbers assigned by an organisation to an individual to identify the individual for the purposes of the organisation's operations. CGL will not use or disclose Commonwealth Government agency identifiers except where required by a Commonwealth Government agency, the Privacy Act or the APP.
WEBSITE PRIVACY AND SECURITY STATEMENT When you look at the CGL website we/our Internet Service Provider collects information about you. The information collected will depend on how you use the site.
1. Information collected If you visit our site to browse or download information we/our Internet Service Provider will record the date and time of your visit and the pages viewed or downloaded. We use this information for statistical purposes only and do not attempt to identify the user.
2. Emails If you email us we will record the email address. This address will only be used for the purpose for which you provided it. We will preserve the content of any email if we believe we have a legal requirement to do so. Emails may be lost or incorrectly sent to the wrong address. You should use a return receipt on emails which you send to confirm that they have been received. The content of your email may be monitored for quality control, systems administration or security purposes.
6. Website Fiscal Information Unless otherwise stated, all details on this website should be considered unaudited. Coventry Group reserve the right to update, where necessary, unaudited information to reflect changes in the business' veracity. This Website Privacy and Security Statement was last updated on 28 April 2014.