Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.
Collection of personal information
EGN primarily collects personal information which is necessary for the performance of the services we offer. EGN collects personal information by lawful and fair means. EGN uses your personal information in order to keep a database and so that we may contact you with any promotions and regular mailing lists.
The following table details the kinds of personal information we collect:
|Customers purchasing products from EGN||Name and contact details including email address, and other personal information.|
|Applicants for employment with and employees of EGN||Name and contact details, professional qualifications and education, applicable licences or certificates, prior employment history, references and any other information that an applicant chooses to provide.|
|Suppliers and other EGN business partners||Name and contact details, current and prior business history and dealings, internal governance information and such other information as EGN may obtain on request.|
This policy does not apply to personal information contained in employee records held by us where the collection, use or disclosure of such information is directly related to the employment of a current or former employee.
We primarily collect personal information about an individual from the individual, except where:
- the individual has consented to us collecting personal information from someone other than the individual by completing a consent form;
- we are required or authorised under an Australian law, or a court/tribunal order to collect personal information about an individual from someone other than the individual; or
- it is unreasonable or impracticable to do so.
In the event that we come into possession of personal information about an individual via a third party, which is not reasonably necessary for or directly related to one or more of our functions or activities, we will destroy the information or de-identify it as soon as reasonably practicable provided that it is lawful to do so in accordance with EGN’s retention and disposal procedure, set out below.
Use and disclosure
The primary purpose for which EGN uses personal information is to enable it to provide a high standard of service to our customers, to keep a database, to contact you with promotional material and mailing lists. EGN may also use the information for internal business purposes, such as quality assurance and administration and for promotion (through its website, other social media pages or social medium) to the general public.
EGN shall only disclose personal information outside EGN in the following circumstances:
- To law enforcement agencies as required by law or a court;
- To suppliers, contractors or agents who are engaged as part of EGN’s provision of services, or to organisations that provide services to EGN, such as legal advisers, auditors; or
- To properly authorised persons or agencies.
Security and Protection of Personal Information and Confidential Information
All personal information or confidential information held by EGN shall be held in locked storage facilities. Personal or confidential information held in electronic format shall be password protected and shall always be removed from these devices before they leave our control.
Retention and Disposal of Personal Information and Confidential Information
Records including personal information or confidential information shall be securely destroyed as we consider appropriate and if it is no longer required by us to be retained.
Keeping Personal Information up to Date
EGN shall take care to ensure that the personal information it holds is accurate and up to date as provided by the individual. Changes to personal information shall be repeatedly updated on our records once we have been advised. If advised that confidential information is no longer confidential we shall remove it from (or amend) our records to reflect that.
Access to Personal Information
EGN does not charge an individual for access to their files, however, copying of files shall be at an individual’s own expense.
Requests for access to a customer’s information shall only be accepted if in writing, include proof of identity and be signed by the relevant person, to protect individuals from improper disclosure of their personal or confidential information. The EGN management team shall endeavour to acknowledge a request for access within 14 days.
A request for information shall be denied if the request is considered frivolous or vexatious, poses an imminent threat to life, health or privacy of an individual, would breach the individual’s confidential information or is unlawful.
Access to personal information shall be provided under supervision to ensure security of records held by the EGN.
If you are of the view that we have breached your privacy, you may make a complaint by writing to the Privacy Officer.
You will be contacted within 24 hours on week days, or as soon as possible in relation to complaints received on weekends, regarding your complaint. The Privacy Officer will, if necessary, go on to investigate the complaint further.
Within 14 days, you will be advised of the outcome of the Privacy Officer’s investigation, including any corrective action to be undertaken. In the event that the Privacy Officer is unable to determine the complaint within 14 days, you will be notified of this and advised of the outcome of the investigation as soon as possible.
In the event that a complaint is found to be vexatious, unreasonable or disrespectful, the Privacy Officer may, at their discretion, discontinue their investigation and in such case will record their reasons for so doing on the relevant file and advise the complainant of same.
We do not operate overseas however if we do disclose personal information to an overseas recipient, such as our supplier(s), we will take all reasonable steps to ensure that the overseas recipient does not breach your privacy unless:
- the overseas recipient is subject to similar laws to the Privacy Act 1988 and the Australian Privacy Principles and the individual has mechanisms to take action against the overseas recipient;
- we reasonably believe the disclosure is necessary or authorised by Australian law; or
- the relevant individual provided express consent to the disclosure.
You can contact EGN’s Privacy Officer, Kelly, about any privacy related issue by phone or email as follows:
- Phone: 0412 129 485
- Email: firstname.lastname@example.org