Privacy

Venntrack Privacy Policy

This Privacy Policy sets out the approach, which Venntrack takes in relation to the treatment of Personal Information. It includes information on how Venntrack collects, uses, discloses and keeps secure, individuals' Personal Information. It also covers how Venntrack makes the Personal Information it holds available for access to and correction by the individual.
This policy has been drafted having regard to Venntrack's obligations under the Privacy Act 1988 (including the new National Privacy Principles) (the Privacy Act). Nothing in this Policy changes Venntrack's existing obligations under the requirements of the Privacy Act.
This Policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.
1. Collection
1.1 Venntrack will only collect Personal Information where the information is necessary for Venntrack to perform its functions or activities. In this context, "collect" means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 Venntrack collects Personal Information primarily to supply customers with the products and services ordered from it.
1.3 Venntrack will notify individuals (including, but not limited to, our clients and candidates) of the matters listed below before collecting any Personal Information:
i) the reason that we are collecting Personal Information;

ii) our identity and how individuals can contact us, if this is not obvious;

iii)
(a) information or an opinion about an individual's:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual preferences or practices; or
(ix) criminal record; or
(b) Health Information about an individual.

iv) that individuals can access the Personal Information that Venntrack holds about them;

v) that individuals should contact us (even if they are not a client or candidate) if they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;

vi) the organisations or types of organisations to whom we usually Disclose the Personal Information;

vii) where applicable, any law that requires the Personal Information to be collected;

viii) the consequences (if any) for the individual if all or part of the Personal Information is not provided to Venntrack.

1.4 Where it is not practicable for Venntrack to notify individuals of all of the Collection Information before the collection of Personal Information, Venntrack will ensure that individuals are notified of the Collection Information as soon as possible after the collection. Venntrack will only engage in "post collection notification" in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.

1.5 When collecting Personal Information over the telephone, it may not always be practicable to provide all the Collection Information at that time. In such circumstances, we will provide the individual with Venntrack's contact details, and then provide the balance of the Collection Information in a confirming letter.
1.6 Venntrack will not collect Sensitive Information from individuals except with consent and only where it is necessary for Venntrack to collect such information.
1.7 Venntrack will not collect Personal Information secretly or in an underhanded way.
2. Use
2.1 Venntrack Uses Personal Information for the purposes listed in 1.2 above.
2.2 Venntrack will not use Sensitive Information for Direct Marketing.
2.3 Venntrack may use Personal Information to avoid an imminent threat to a person's life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.4 Venntrack will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
3. Disclosure
3.1 Venntrack may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.

3.2 Venntrack will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.

3.3 Venntrack may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.

3.4 Venntrack may Disclose Personal Information to avoid an imminent threat to a person's life or to public safety.

3.5 Venntrack will not sell or share its customer lists on a commercial basis with third parties.
4. Information quality
4.1 Venntrack will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 Venntrack will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.
5. Information security
5.1 Venntrack requires employees and contractors to perform their duties in a manner that is consistent with Venntrack's legal responsibilities in relation to privacy.

5.2 Venntrack will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Venntrack who have a genuine "need to know" as well as "right to know".
5.3 Venntrack will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6. Access and correction
6.1 Venntrack will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 Venntrack will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting Venntrack direct.
6.4 Venntrack will not charge a fee for processing an access request unless the request is complex or is resource intensive.
7. Openness
7.1 Venntrack websites will contain a prominently displayed privacy statement and will include a copy of this Venntrack Privacy Policy.
8. Anonymous transactions
8.1 Venntrack will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. Venntrack may however request visitors to provide Personal Information voluntarily to Venntrack (for example, as part of a questionnaire).
8.2 Venntrack will allow its clients and candidates to transact with it anonymously wherever that is reasonable and practicable.
9. Glossary
Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.
Disclosure generally means the release of information outside Venntrack.
Health Information means:
(a) information or an opinion about:

(i) the health or a disability (at any time) of an individual;
(ii) an individual's expressed wishes about the future provision of health services to him or her;
(iii) a health service provided or to be provided to an individual; or

(b) other personal information collected to provide or in providing a health service; or

(c) other personal information about an individual collected in connection with the donation; or intended donation by the individual of his or her body parts or body substances.
Venntrack means the company registered with ASIC.
Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.
Reasonable Expectation means a reasonable individual's expectation that their personal information might be Used or Disclosed for the particular purpose.
Sensitive Information means:
(a) information or an opinion about an individual's:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual preferences or practices; or
(ix) criminal record; or

(b) Health Information about an individual.
Use means the handling of Personal Information within Venntrack.