About this Policy
· clearly communicate the personal information handling practices of VERNet Pty Ltd (VERNet, we or us),
· enhance the transparency of VERNet’s operations, and
· give individuals a better and more complete understanding of the sort of personal information VERNet holds and the way VERNet handles that personal information.
VERNet’s obligations under the Privacy Act
VERNet is bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (the Privacy Act), which regulate how businesses collect, use, store and disclose personal information, and how individuals may access and correct personal information held about them or make complaints about the handling of their personal information.
Personal information is defined in section 6(1) of the Privacy Act as ‘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’.
What constitutes personal information will vary, depending on whether an individual can be identified or is reasonably identifiable in the particular circumstances.
The kinds of personal information collected and held by VERNet
We only collect personal information when it is reasonably necessary for our business activities.
The types of personal information we collect from you will depend on the circumstances in which the information is collected, and may include information such as:
· your name and contact details (including postal address, email address and phone numbers);
· information used to verify your identity (including date of birth and driver’s licence);
· details about your relationship with us (including your occupation, title and place of work); and
· records of your dealings with us (including your correspondence with us).
We do not generally require you to provide us with any sensitive information about yourself. In limited circumstances, we may require you to provide us with certain health information (for example, if you apply for a job with us).
If you do provide sensitive information to us for any reason, you consent to us collecting that information and to us using and disclosing that information for the reason that you provided it to us and as permitted by the Privacy Act.
You may notify us that you wish to deal with us by not identifying yourself or using a pseudonym. However, if we are not able to collect personal information about you we may not be able to provide you with the products, services, information or assistance you require.
Security and storage of personal information
We may store personal information on computer databases and/or in hard copy, and we employ reasonable commercial physical and electronic security measures to protect any records that we hold which contain your personal information.
We may also engage third party service providers to assist in storing and processing certain types of personal information for us. Some of these service providers may be located overseas, or use facilities located overseas to provide us with services.
We take all reasonable steps as required by the Privacy Act to ensure that records of personal information collected by VERNet are secure from unauthorised access, use or disclosure, and from misuse, interference and loss.
However, except to the extent that liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to your personal information. Please notify us immediately if you become aware of any breach of security.
VERNet does not guarantee the secure transmission of information across the Internet. While we take reasonable efforts to provide online security, you should be aware that there are inherent risks in the transmission of information across the Internet. The VERNet website does not use encrypted email services. We are not responsible for the privacy practices or the content of any third party web sites linked to this site.
If you do not wish to use the internet, please write to or call us; our postal address and telephone number are provided in the “Contact Us” section of this site.
How VERNet collects and holds your personal information
When VERNet collects personal information about you, in the majority of cases, we will collect this information directly from you. For example, when you:
· provide personal information to our staff;
· request information, join a mailing list or request information from us;
· apply for a job with us; or
· conduct business with us.
We may also collect personal information about you from publicly available sources, from our related companies or from third parties (for example, from referees if you apply for a job with us).
If you e-mail us, we will record your email address and copies of your e-mail correspondence with us. We will generally only use your e-mail address for the purpose for which you provided it to us, or otherwise as required or permitted by law. We will not add your e-mail to a mailing list unless you have consented.
If you register or use an online form on the VERNet website, we may collect personal information to fulfil your request, manage you as a registered user of our site and provide news and materials from time to time with your consent. This information may include your name, e-mail address, street address, telephone number, occupation and company. We will only use this information for the purpose for which you provided it or otherwise as required or permitted by law. This information will not be added to a mailing list unless you have consented.
How VERNet uses and discloses personal information
How we use your personal information will generally depend on why we collected it and the nature of your relationship with us.
We may use or disclose your personal information:
· for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
· for other purposes to which you have consented; and
· as otherwise authorised or required by law.
Generally, we will only use and disclose the personal information that we collect about you so that we can do business together and for purposes connected with our business operations. These purposes may include:
· verifying your identity;
· contacting you (including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner);
· assessing your suitability for employment or other relationships with us;
· improving our products or services;
· providing goods or services to you or receiving goods or services from you;
· addressing any issues or complaints that we or you have regarding our relationship;
· developing and improving our business (including by conducting member satisfaction surveys);
· protecting the safety and security of VERNet visitors, staff and property; and
· investigating and responding to claims against VERNet.
We may disclose and provide access to your personal information to third parties in connection with the purposes above.
Some of the third parties that we may disclose your personal information to include:
· third parties to whom you have asked us to disclose your personal information (e.g. referees);
· our related companies;
· our contractors (including recruitment agencies, mailing houses, insurance providers, website and data hosting providers and other IT suppliers) and others persons who provide services to us;
· our accountants, insurers, lawyers, auditors and other professional advisers;
· in the event that we or our assets are or may be acquired by a third party (or where we acquire, or are seeking to acquire, a third party business or its assets), that third party and their advisors;
· in certain circumstances, third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
· other third parties as permitted or required by law.
Mailing lists and marketing
We may use and disclose your personal information for the purpose of direct marketing (for example, by adding you to our mailing list) where you have consented to us doing so or it is otherwise permitted by law.
Direct marketing involves communicating directly with you for the purpose of promoting the sale of goods and services. Direct marketing can be delivered by a range of methods including mail, telephone, email or SMS.
How to access and seek correction of your personal information
Individuals have a right to request access to their personal information and to request its correction if it is inaccurate, out of date, incomplete, irrelevant or misleading.
How to contact us
You can contact us about privacy issues (or unsubscribe from direct marketing) by sending an e-mail to firstname.lastname@example.org, or by calling us on (03) 9914 5700. Alternatively, you can write to us at PO Box 25138, Melbourne VIC 3004.
If you want to make a privacy complaint, please read the section below for more details.
How you can complain about the treatment of your personal information and how the complaint will be handled
You can make a complaint if you believe VERNet has breached the APPs or mishandled your personal information.
All privacy complaints and alleged breaches will be investigated by VERNet’s CEO (and/or appropriate staff appointed by the CEO) with the aim of resolving any issue in a timely and efficient manner and in accordance with the Act. We request that you cooperate with us during this process and provide us with relevant information we may require. We will, in most cases, advise you of the outcome of our investigation once it has been completed.
In the first instance, any privacy concerns or complaints should be reported to VERNet’s CEO. This can be done by:
Phone: 03 9914 5700
Mail: VERNet Pty Ltd, Attn: CEO, PO Box 25138, Melbourne VIC 3004
If you are not satisfied with VERNet’s handling of your complaint, you also have the option of contacting the Privacy Commissioner using the following contact details:
Phone: 1300 363 992
Mail: OAIC, GPO Box 5218 Sydney NSW 2001