Privacy

  1. Scott Paine Consulting Pty Ltd Privacy Policy
  2. We at Scott Paine Consulting (ABN: 49 118 332 880) is committed to ensuring that in all our operations we treat the personal information we collect in accordance with the Australian Privacy Principles as set out in the Privacy Act 1988 (Cth) (Privacy Act). The Privacy Act sets the minimum standards we have to meet when handling personal information. This Privacy Policy sets out how Scott Paine Consulting collects, stores, uses and discloses this information.

    Except as specifically provided below, this Policy does not apply to information collected by Scott Paine Consulting by other means such as information collected offline. 

    The Privacy Act contains 13 Australian Privacy Principles (APPs). A plain English summary of the APPs is set out in Schedule 1 of this privacy policy.

    These APPs:

    1. set out legally binding standards for handling personal information
    2. regulate how we collect, store, use and disclose personal information
    3. allow people to access the information we keep about them, and
    4. allow people to correct or update the information we keep about them.

    We are committed to managing all personal information in an open and transparent way. To that end, we will take reasonable steps to implement practices, procedures and systems to ensure we comply with the Australian Privacy Policies (APPs) and any binding registered APP code, and ensure that we are able to deal with any related inquiry or complaint.

  3. What is the purpose of this Privacy Policy
  4. The purpose of this privacy policy is to:

    • clearly express how we handle personal information
    • increase the transparency of our operations, and
    • provide a complete explanation of the sort of personal information that we hold, and the way we handle that information.

    What is personal information? ‘Personal information’ is defined in 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.

    This policy, which sets out our management of personal information, is available on our website http://www.scottpaine.com.au or on request. We will also ensure that where a reasonable request is made to receive this policy in an alternative format, such request will be granted.

  5. What kinds of personal information do we collect and hold?
  6. The majority of information we collect is via a solicited request to either an individual or an agency, organisation or small business operator to provide personal information, or to provide a kind of information in which that personal information is included.  A request for such information may not involve direct communication between us and you i.e. you sign up to receive our newsletter.

    The kinds of personal information that we may collect and hold are:

    • Names, job titles, contact details and address details.
    • Details of projects you engage SPC for, including but not limited to, project duration, cost, location as well as company documentation i.e. policies, forms, procedures.
  7. Sensitive information
  8. It may at times be necessary for SPC to collect and hold sensitive information about you for recruiting purposes. Types of sensitive information we may collect include ethnic origin, criminal record, health information and membership to any professional bodies.

  9. Anonymity
  10. When dealing with SPC it is generally not practical to remain anonymous or to use a pseudonym as we usually need to use your personal information to provide specific services to you.

  11. How do we collect personal information?
  12. Generally we will collect personal information directly from you. This may be in person, over the telephone, or online (for example, signing up our regular email updates). There may be times where we are given your personal information from a third party i.e. your employer may be our client and ask us to make contact with you on their behalf.

    If we collect personal information about you from a third party and it is unclear that you have consented to the disclosure of your personal information to us, we will take reasonable steps to ensure that you are aware of the circumstances surrounding the collection and purposes for which we collected your personal information.

    Personal information held by us is generally stored in computer systems. These may be operated by us or by our service providers. In all cases, we have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, personal information.

  13. Purpose for collecting, holding and using personal information
  14. SPC will only collect personal information if it is reasonably necessary for, or directly related to, one or more of our functions or activities:

    • To provide professional services;
    • To maintain contact with our clients and other contacts;
    • To keep our clients and other contacts updated on our services and other relevant updates we put out i.e. an email newsletter;
    • Providing you with information on events we are organising or supporting i.e. AHRI WHS seminars, other conferences & events;
    • Conduct surveys or seek feedback;
    • To meet our regulatory obligations;
    • Any other business related purpose such as but not limited to communicating with you in relation to our operations, activities and objectives, to verify personal information and improve and evaluate our services.

    We may use Personal Information that is provided to us for the following purposes:

    • for the purposes for which you specifically provided it including, without limitation, to enable us to respond to your inquiries and fulfil your requests;
    • to tell you about products, services, programs, and offers that we believe may be of interest to you via email, SMS, telephone or postal mail (if you have consented to receiving such);
    • to send you information about your relationship or transactions with us; and
    • for our internal business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our services, identifying usage trends, determining the effectiveness of any promotional campaigns we conduct;
    • to complete professional services to you, or otherwise provide you with products or services, for example, to process your payments, communicate with you regarding service we are providing for you and provide you with related customer service.

    Personal information about an individual will not be used or disclosed for a secondary purpose unless:

    • the purpose is closely related to the primary purpose and the individual would reasonably expect the information to be used in that way; or
    • the individual has consented (recognising the competence to consent); or
    • we have a legal obligation to disclose personal information which overrides the provisions of the primary legislation.

    We will not sell, exchange or release personal information about an individual for commercial gain. 

  15. The use of Direct Marketing
  16. In some instances, information you provide may be used to keep you better informed about the activities and services we offer, such as by way of a newsletter. We will ensure that if you subscribe to any of our services you can readily request to opt-out of it. By electing not to opt-out, it will be assumed that you give us your implied consent to send similar information and communications in the future.

    We will ensure that personal information about you is not provided to third parties for the purpose of direct marketing.

  17. Security of information
  18. We will take all reasonable steps to protect the personal information that we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. This includes:

    • Taking appropriate measures to protect electronic materials and materials stored and generated in hard copy, and ensuring that people we contract with are subject to the same strict privacy obligations that we operate under.
    • Personal information will be destroyed or permanently de-identified when it is no longer needed for the purpose for which it was collected.
    • Our website contains links to other websites.  We do not accept responsibility for the privacy practices or the content of linked websites.
    • Our team is dedicated to ensuring that any interaction they may have with your personal and/or sensitive information in the course of their duties will be done so in a respectful manner and your confidentiality is ensured at all time. We will not disclose your personal information to any third party without your explicit consent. 
  19. Do third parties see and/or have access to information obtained by us?
  20. Yes.  We will share some of your personal information with third parties in the ways that are described in this Policy. We may disclose your Personal Information:

    • to our local and offshore third party service providers who provide services on our behalf, such as website hosting, data analysis, infrastructure provision, IT services, customer service, email delivery services, auditing, list management services, and other similar services. (These third parties will be supplied with or have access to your Personal Information for the purpose of providing these services to us or on our behalf); and
    • to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
  21. Access & Correction
  22. We will always endeavour to ensure that the personal information we collect, use or disclose is accurate, up-to-date and complete. Reasonable steps will be taken to allow you, on request, to ascertain generally what sort of personal information is held, for what purpose, how it was collected, stored and used.

    If we are satisfied that personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information.

    Reasonable steps will be taken to allow you access, at any time, to the personal information we hold about you, and provide the opportunity for the information to be corrected or to include a statement indicating that the  information is inaccurate, out of date, incomplete, irrelevant or misleading. All requests to correct information held by us will managed by our company Director who will endeavour to respond to such a request within 30 days. You can email requests to scott.paine@scottpaine.com.au.

    We will not charge you for making the request, for giving you access to your personal information, for correcting your information or for associating a statement with your information about its accuracy

  23. Cross-border transfer of personal information
  24. We use “cloud-based” service providers and data hosting facilities to assist us with providing our services to you. As a result, your personal information may be transferred to, and stored at, a destination outside Australia.

    We will take all practicable steps to ensure that any overseas third party service providers we engage do not breach the Australian Privacy Principles, including through contractual arrangements.

    If your personal information is collected using a collection notice that references this Privacy Policy, you are taken to consent to the disclosure, transfer, storing or processing of your personal information outside of Australia to one of our contracted service providers.

  25. Website usage information and cookies
  26. When you access our website, we may use software embedded in our website (such as JavaScript) and we may place small data files (or cookies) on your computer or other device to collect information about which pages you view and how you reach them, what you do when you visit a page, the length of time you remain on the page, and how we perform in providing content to you.

    A cookie does not identify individuals personally, but it does identify computers. We may gather IP addresses as part of our business activities and to assist with any operational difficulties or support issues with our services.

  27. Grievance procedure relating to the Privacy Act
  28. You may make a complaint to us if you consider that we have interfered with your privacy or otherwise breached our obligations under the APPs in relation to the management of your personal information. The complaint should be in writing, providing as much detail as possible.

    The complaint should be addressed to:

    Managing Director
    Scott Paine Consulting
    PO Box 1112, Darlinghurst
    NSW 1300, Australia

    Or via email scott.paine@scottpaine.com.au

    We will take reasonable steps to investigate any complaint, and to notify you of the outcome of our investigation within seven (7) days of complaint being received.

    If you are not satisfied with the outcome of our investigations, you can make a complaint directly to the Office of the Australian Information Commissioner. Further details about how to make a complaint are set out at http://www.oaic.gov.au/privacy/making-a-privacy-complaint

  29. Policy Review
  30. The Managing Director will ensure that this Privacy Policy is reviewed at least once every three years to ensure it takes into account changes to law and/ or technology, as well as changes to our functions, operations and practices. The current policy will be available on the Scott Paine Consulting website.

    This policy was last reviewed in October 2014.

“Consulting is all about good communication.”