We acknowledge that we must take reasonable steps when handling personal information. Whilst we cannot warrant that this Privacy Policy will be followed in every instance, we will endeavour to follow this Privacy Policy. Similarly, while we cannot warrant that loss, misuse or alteration of information will never occur, we will take all reasonable steps to prevent these things from occurring. We have taken reasonable steps to endeavour to comply with the APP and the Act, some examples are noted below.

1. Implementation of this Privacy Policy.
2. Staff training and education.
3. Use of checklists to ensure that all APP are complied with.
4. Clear and transparent procedures regarding the handling of complaints and disclosure of information.

If you require a hardcopy of this Privacy Policy, please contact our Privacy Officer on the details below and we will provide you with a copy.

Collection

It is our usual practice to collect personal information directly from the subject individual or their authorised representative(s).

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, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Some examples of the personal information we might collect include (but are not limited to): your name;
your contact details (such as telephone numbers, addresses (residential and business), and email addresses etc.); your age or date of birth; your occupation and employment details (current and former); personal identification documentation (including government related identifiers); details relating to your use of our goods and services;
payment details;
banking details;
images from video surveillance and other cameras we use; and customer survey information.

Identification

You may choose to interact with us using a pseudonym and/or not identify yourself.

In circumstances where we are required to do so, or are authorised by law, a court or tribunal to ask for your identification, we will request your personal information.

Further, it is likely that it will be impractical for us to interact with you without some form of identification, and therefore we will request identification details from you at the beginning of each transaction. For example, we will not be able to open a commercial credit trading account or process a commercial credit application for you without obtaining identification details.

If you do not consent to the collection of your personal information, in accordance with this Privacy Policy, we may not be able to assist you with the provision of certain services.

We only collect and hold personal information by lawful and fair means.

There are several ways we may collect your personal information, including when you:

visit, or submit information through, our website; apply with us for a position of employment or as a contractor; deal with us face-to-face, in writing (by letter, facsimile, or email), or by telephone; participate in any of our events, promotions, or surveys, or subscribe to any of our publications; or submit an application, quotation, purchase order, or service request to us. In some circumstances, we may collect and hold personal information that has been collected from a third party (such as an associated entity or service provider) or a publicly available source.

This will likely occur in instances where:

you have consented for this collection (which would usually be via our privacy statement and/or credit application form); or you would reasonably expect us to collect your personal information in this way and it is necessary for us to collect this information for a specific purpose (such as investigation of a complaint). We will take steps to hold personal information in a manner which is secure and protected from unauthorised access.

Your personal information may be held in either a physical form or in electronic form on our IT system.

Where stored in electronic form on our IT system, we will take steps to protect the information against modification, disclosure, or misuse by including such things as physical restrictions, password protections, internal and external firewalls, and anti-virus software.

We will also endeavour to ensure that our service providers have protection for electronic IT systems and other necessary restrictions.

We will endeavour to ensure our staff are trained with respect to the security of the personal information we hold, and we will restrict any access where necessary.

While we retain personal information for as long as necessary in relation to the purposes for which it is collected, we will endeavour to destroy and de-identify the personal information once it is no longer required, except as required for business record purposes. In the event we hold personal information that is unsolicited, and we were not permitted to collect it, the personal information will be destroyed as soon as practicable.

If we collect personal information about you from someone else, we will advise you as soon as practicable that this information has been collected and the circumstances which surround the collection.