Roytal Enterprises respects and upholds the rights of individuals
to privacy in relationship to personal information. This policy
demonstrates that commitment to privacy.
This policy relates to the collection, holding, use, correction,
disclosure and transfer of personal information by Roytal
Enterprises Ltd.
This policy statement is provided in accordance with the
Commonwealth Privacy Act 1988, the Privacy Amendment (Private
Sector) Act 2000 and the National Privacy Principles which
are set out in the Act.
Roytal has adopted the National Privacy Principles (NPPs’)
as designated by the Privacy Commissioner and has agreed to
be held accountable for complying with them.
The National Privacy Principles Address Ten Core Issues:
- Collecting of personal information.
- Use and disclosure.
- Data quality
- Data security
- Openness
- Access and correction
- Identifiers
- Anonymity
- Transborder data flow
- Sensitive information
Roytal will collect personal information about you in a number
of ways, telephone, email, written and via a third party.
- By telephone; Information received by telephone may be
recorded in files as a means of dealing with you as part
of our ongoing commercial dealings.
- Email; Electronic information may be stored in email files
and used in future dealings with you as part of our ongoing
business.
- Written; Personal information received in writing may
be retained and stored as a record or for future use by
our organisation as part of our ongoing business dealing
with you.
- Third party; Information from a third party will only
be accepted by us on the basis that the third party had
prior approval from you to supply us with your personal
information.
Roytal will collect personal information on a lawful and
fair basis and not in an unreasonably intrusive way.
Roytal will ensure that the individual is aware of;
- The identity of Roytal and how to contact us.
- The fact that a person is able to gain access to their
information.
- The purposes for which the information is being collected.
- To whom Roytal discloses information.
- Any law that requires information to be collected.
- The main consequences (if any) for an individual if information
is not provided.
Roytal will not collect your personal information other than
for commercial activities in express dealings with you in
a business capacity.
Roytal may use your personal information in order to;
- Discharge it’s duty of care.
- Provide the services you require.
- Administer and manage those services including charging,
billing and collecting debts.
- Satisfy the organisation’s legal and contractual
obligations.
Roytal will not use or disclose personal information about
an individual other than for it’s primary purpose of
collection, unless;
- The individual would reasonably expect the organisation
to use or disclose information for a secondary purpose,
or it is related to the primary purpose.
- The individual has consented to the use or disclosure.
- It is impractical for Roytal to seek the individual’s
consent and the disclosure is necessary to provide the individual
appropriate care or treatment.
- Roytal has reason to suspect that unlawful activity has,
or may be engaged in.
- The use or disclosure is required or authorised by law.
- Roytal believes that the use or disclosure is reasonably
necessary for a specified purpose by, or on behalf of, an
enforcement body.
Roytal will take reasonable steps to make sure that the personal
information we collect, use or disclose is accurate, complete
and current.
Roytal will take reasonable steps to protect the personal
information it holds from misuse and loss from unauthorised
access.
Roytal will take reasonable steps to destroy or permanently
de-identify personal information if it is no longer required.
In addition, our employees and the contractors who provide
services related to our business are obliged to respect the
confidentiality of any personal information held by Roytal.
Roytal will make this policy, on our management of personal
information, available upon request and undertake to review
this policy on a regular basis.
Roytal will take reasonable steps, upon written request,
to let an individual know what personal information we hold,
for what purposes, and how we collect, hold, use and disclose
that information.
All information concerning clients/customers is to be considered
confidential. Roytal will not convey any information contained
in our records to any unauthorised person.
As a general rule, Roytal will, upon written request by an
individual, provide them with access to their personal information.
Roytal may however choose not to provide individuals with
access to such information in cases where;
- Providing access would pose a threat to life or health.
- Providing access would have an unreasonable impact upon
the privacy of others.
- The request for access is frivolous or annoying.
- The information relates to anticipated or legal proceedings.
- Law allows denial of access.
- Providing access would be likely to prejudice investigation
of possible lawful activity.
- Providing access would be unlawful.
Roytal may decide to impose a charge upon the individual
to cover the cost of verifying a request for information and
locating, retrieving, reviewing and copying any material requested.
In this circumstance the cost will be fair and reasonable.
While Roytal will take reasonable steps to ensure that the
information it holds is accurate, complete and current. Where
there is a disagreement between Roytal and the individual
concerning the information held and the individual asks Roytal
to associate with the information a statement claiming that
the information is not accurate, complete or current, Roytal
will take reasonable steps to do so.
Roytal will convey to the individual our reasons for any
denial of access or refusal to correct personal information.
Where an individual is dissatisfied that Roytal has declined
to provide information they can use internal disputes resolution
process.
Our commitment to performance and ongoing improvement means
that we are constantly reviewing our procedures and we reserve
the right to change our privacy policy at any time and notify
you of any updated version of the policy.
Roytal will, wherever it is lawful and practicable to do so,
give people the option to operate anonymously.
Roytal will only transfer personal information about an individual
to a third party outside Australia in specific circumstances.
This would include;
- Where the individual consents to the transfer; or
- Where Roytal has taken reasonable steps to ensure that
the information to be transferred will not be held, used
or disclosed by the recipient of the information inconsistently
with Australia’s National Privacy Principles.
Roytal will not collect personal information revealing racial
or ethnic origin, political opinions, religious or philosophical
beliefs, trade union membership, criminal record or details
of sex life or health unless
- The individual has consented or;
- The collection is required or specifically authorised
by law; or
- The collection is necessary to prevent or lesson a serious
or imminent threat to the life or health of an individual,
where the subject of the information is physically or legally
incapable of giving consent; or
- The collection is necessary for the establishment, exercise
or defence of a legal claim.
Individuals may lodge a complaint with Roytal Enterprises
Ltd, which will be dealt with in line with Roytal’s
current complaint handling practices.
All privacy related complaints would be dealt with in a
serious and prompt manner.
A complaint by an individual regarding an alleged breach of
privacy by Roytal should be forwarded in writing to the following
address:
Privacy Officer,
Roytal Enterprises Ltd,
P O Box 665, Kew
Vic 3101
All written complaints will be acknowledged within five
working days upon receipt and will be answered within 30 days
of receipt.
Should the individual not be satisfied with the response
from Roytal, the complaint may be referred to the Federal
Privacy Commissioner:
Office of Federal Privacy Commissioner
GPO Box 5218
Sydney NSW 1042
Roytal will ensure that all staff receives appropriate training
in the application and observance of the stated principles
and complaints handling procedure.
All new members of staff will be introduced to our privacy
policy and complaints handling procedure.
Dated: 25th October 2002
|
