This Privacy Statement sets out the policy of PHiQ Group Pty Ltd (“PHIQ”) with respect to the way in which we collect, use, disclose, store, secure and dispose of Personal Information about our clients, including through our website at www.phiqgroup.com
PHIQ is bound by the Australian Privacy Principles (“Principles”) as contained in the Privacy Act 1988 and amended by the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (“the Privacy Laws”). A copy of the Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au
PHIQ is dedicated to ensure that personal and sensitive information is gathered with respect to the individual and aims to exercise the highest standard of care in preserving privacy of information in all areas of operation.
For the purposes of this Statement, “Personal Information” is characterised as being information or an opinion about an individual whose identity is apparent or can reasonably be ascertained from that information or opinion.
The types of Personal Information generally collected by us include name, address, mobile and telephone numbers, e-mail address, and company details. Personal Information is also collected when individuals provide business cards or other documentation to us containing such Personal Information. Personal Information also includes information we collect in the course of providing services to individuals and external communications.
We will allow you to provide Personal Information without identifying you unless your identification is necessary for us to provide you with services. It is unlikely that we will practically be able to accept a pseudonym or de-identified information for us to perform our services. While we endeavour to collect Personal Information from the individual involved, in some instances we may also receive Personal Information about you from third parties if it is impractical to collect it from you.
Any Personal Information that we collect about individuals will be used and disclosed by us to provide the services required or otherwise to enable us to carry out our functions.
Personal Information that is in our possession is not subject to rent, sale or any other disclosure to any other company or organisation, without prior consent of individuals where that consent is required by law. Individuals consent to our use and disclosure of their Personal Information where it is incidental to a sale of our business to a third party. We may also use your Personal Information for related purposes that you would reasonably deem to be incidental or related to the services we provide you.
We may disclose your Personal Information to our employees, officers, contractors, agents, and are likely to disclose your personal information to overseas recipients such as related bodies corporate and service providers outside of Australia, who need to work closely with us to complete their work for us. Your provision to us, or our agents of your Personal Information will constitute your consent for us to disclose this information to our employees, officers, contractors, agents, related bodies corporate and affiliated companies, and service providers located outside of Australia.
PHIQ will disclose personal information if it is under a legal requirement to do so (for example, under a court order, or if required under legislation), or if an authorised request is made from a law enforcement agency.
Otherwise, we will only disclose personal information with the consent of the relevant individuals.
PHIQ will handle Personal Information collected online with the utmost care, and will not knowingly use it in ways not explicitly consented to by the user who supplied the information and to whom the information refers.
PHIQ will handle Personal Information collected online consistently with the way that it handles Personal Information collected offline. Other matters specific to our handling of Personal Information online are set out below.
No Personal Information is collected by PHIQ when individuals visit our website, unless they chose to provide it to us (for example, by sending us emails through our website). However, we may collect certain data that does not identify individuals (sometimes called “web log information”) when they visit certain pages (such as the type of browser and operating system they have). We may also use “cookies” which are small files that are stored on computer and that manage the security and navigation process of the site. Users can choose to block these cookies but some portions of the site may not function correctly if they do. This type of data is collected for statistical purposes only, and while cookies will identify computer, they are unlikely to identify users personally.
b) Email/SMS marketing
We will not SMS our marketing material unless customers have consented to this. This is a requirement of the Spam Act 2003. Further, customers can unsubscribe from our e-newsletter or other bulletins by using the “unsubscribe” facility contained in each electronic publication we send. Occasionally, PHIQ will send email messages to prospective clients to marker a service or activity. This will only be done on reasonable belief that prospective clients would be interested in the subject matter. In every case clients will be provided with clear and simple instructions on how to be removed from our mailing list
c) Hyperlinks to other websites
d) Social Networking Acceptable Use Policy
PHIQ encourages all comments on any of our social networking pages (Facebook, LinkedIn), as we would like to hear from our clients, friends and staff. Client views, news, ideas, insights and criticisms about PHIQ are very important to us, yet the social networking sites must not be used to abuse others, expose others to offensive or inappropriate content, or for any illegal purpose.
It is the user’s responsibility to protect their personal privacy when using our social networking pages. We advise users not to include any Personal Information of either themselves or of others in their posts to the wall (such as email addresses, private addresses or phone numbers).
In addition, it is recommended to refrain from posting materials to the page that infringe the intellectual property rights of others and not to include internet addresses or links to websites, or any email addresses in posts to the wall.
Any information posted to the PHIQ Social Networking pages (Facebook, LinkedIn) is recorded and used for the purpose of administering pages and addressing any comments made, while no attempt will be made to identify users except where authorised by law.
We are not responsible for the privacy practices or content of social networking pages (Facebook, LinkedIn). The responsibility of PHIQ is limited to our own postings made on our Facebook and LinkedIn pages.
We use reasonable endeavours to secure any Personal Information that we hold about clients and aim to keep this information accurate and up-to-date. Technical and organisational security measures are in place to ensure the security of information and to protect it against deliberate or accidental manipulation, interference, destruction, use, disclosure loss or unauthorised access.
The access to Personal Information that we and/or contractors hold can be obtained on request. It is at discretion of PHIQ to provide this information to individuals, depending upon legal circumstances. Users are entitled to tell us if they do not wish us to hold their information, we will remove all such information from our database. Individuals also have the right to ask us to correct information about them which is inaccurate, misleading, incomplete or out of date. Access to your Personal Information may be refused in a number of circumstances, such as where access poses a health or safety risk, the information relates to anticipated legal proceedings or the request for access is frivolous or vexatious. If we deny or restrict your access, we will give you reasons why.
If you wish to seek access to or correction of personal information that PHIQ holds about you, please contact us the Privacy Officer – contact details are set out below. We may ask you to put your request in writing. It is important to us that the Personal Information we hold about you is accurate, complete and up to date.
You can provide a written request or complaint to us by sending it to the Privacy Officer using the following contact details:
· By letter: PHiQ Group Pty Ltd, PO Box 2032 Taren Point NSW 2229, Australia;
· By email to firstname.lastname@example.org.
If we decide not to correct or provide you with access to your personal information, we will give you our reasons for our decision.
If you have a complaint about the way we have dealt with your personal information, please contact us via the above contact details. We will ensure that your complaint is registered with us, and may request that you provide the complaint to us in writing. The Privacy Officer will ensure that the complaint is referred to the right persons within the organisation to investigate and respond to the complaint. Any response or action will be notified to you as soon as practicable.
We will make all reasonable attempts to respond to your complaints or requests.