Frazer Walker is committed to the protection of an individual’s privacy as set out by the Australian Privacy Principles in the Commonwealth Privacy Act 1988.
1. Purpose of policy
Our Privacy commitment to you
Frazer Walker is committed to protecting your privacy, in accordance with applicable Australian privacy laws. In this Policy we explain how we collect, store, use, handle and disclose personal information and the steps we take to protect this information and comply with privacy laws.
What is personal information?
Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
We will only ask for personal information that is relevant to our relationship with you and if it is reasonably necessary for one or more of our functions or activities.
We are required to comply with the Australian Privacy Principles (APPs) in the Privacy Act. The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal.
We are also required to comply with more specific privacy legislation in some circumstances, such as applicable State and Territory health privacy legislation.
2. What we collect
The type of personal information that we collect about you depends on the type of dealings you have with us. For example, if you:
- Are a client of Frazer Walker, we will collect your name, job title, address, contact details, information about our engagements with you and matters we conduct on your behalf
- Ask to be placed on one of our mailing lists, we will collect your name, address and contact details
- Supply goods or services to us, we will collect your name, address, contact details and financial details for payment purposes
- Send us an enquiry or provide us with feedback, we will collect your name, contact details and details of your enquiry or feedback
- Apply for a job with us, we will collect the information you include in your job application, including your cover letter, resume, contact details and referee reports.
Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection. It includes health and genetic information and information about racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record and some types of biometric information.
We only collect sensitive information (predominantly professional associations) where it is reasonably necessary for our functions or activities and either:
- The individual has consented or
- We are required or authorised by or under law (including applicable privacy legislation) to do so.
Collection of information other than personal information through our website
When you visit our website some of the information that is collected about your visit is not personal information, as it does not reveal your identity.
Site visit information
To administer our Web site and for research purposes, Frazer Walker uses third parties to track and analyse anonymous usage and volume statistical information from our visitors and members. Such information is not shared.
Cookies are small packets of information that are stored by your web browser. They are put on your web browser by the websites that you visit. These packets of information do not contain personal information about you, but they do allow us to know if you visit the same website twice or if you visit related websites.
We only use non-persistent cookies. That is, they are held on your browser’s memory only for the duration of your session.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website.
3. How we collect personal information
In the course of providing our services, we collect personal information in a number of ways, including:
- In person (for example, at a meeting or function)
- Through our website
- Over the telephone
- Through written and digital correspondence (such as emails and letters)
- On hard copy forms (for example, event feedback forms)
- From third parties
4. Why we collect personal information
The main purposes for which we collect, hold, use and disclose personal information are to:
- Provide our services to clients
- Send you information or invite you to seminars or events if you are on our mailing list, obtained through a variety of ways, including by mail, email, SMS, telephone or social media campaigns
- Obtain goods and services
- Perform research and statistical analysis, including for customer satisfaction and service improvement purposes
- Answer queries and resolve complaints and
- Recruit staff and contractors.
We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or which are:
Where you have consented to receiving these communications from us, that consent will remain current until you advise us otherwise. However, you can opt out at any time, by:
- contacting our Privacy Officer; or
- using the unsubscribe facility that we include in our commercial electronic messages (such as emails and SMSs) to opt out of receiving those messages.
5. Who we may share your personal information with
We may share your personal information with third parties where appropriate to provide services to our clients, including financial institutions for payment processing; referees whose details are provided to us by job applicants, and our contracted service providers where applicable. Should this be a bullet list?
6. Retention and destruction of personal information
We retain your personal information while there is a legal or a business need for us to do so. When we no longer require your personal information we will take reasonable steps to destroy it.
7. Data quality and security
We hold personal information in both electronic and hardcopy formats. We will take reasonable steps to protect the security of personal information. We have document management and retention policies and processes in place, and we employ physical controls such as swipe card access to our office really ?and locked filing units. Paper files may also be archived in boxes and stored offsite in secure facilities.
We take reasonable steps to:
- Make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant
- Protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure and
- Destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the APPs.
The steps we take to secure your personal information include access controls to our applications (such as login and password protection), controlled access to our corporate premises, policies on document storage and security, personnel security, staff training and workplace policies.
8. Access and Correction
You may access, correct, update, and/or delete any personally-identifiable information that we hold about you. We may require you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.
We will generally provide you with access to your personal information, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (e.g. by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
Except in the case of more complicated requests, we will endeavour to respond to access and correction requests within 30 days.
The Privacy Officer will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. When contacting us, please provide as much detail as possible in relation to the query, issue or complaint.
We will take any privacy complaint seriously. We will aim to resolve any such complaint in a timely and efficient manner, and our target response time is 30 days. We request that you cooperate with us during this process and provide us with relevant information we may require.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint with the Office of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia):
Office of the Australian Information Commissioner (OAIC)
Complaints must be made in writing
Phone 1300 363 992
Mail Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
10. Our contact details
If you have any queries about the personal information that we hold about you or the way we handle that personal information, please contact our Privacy Officer, Ian Chisholm.
Frazer Walker Privacy Officer,
Level 15 St Martins Tower
31 Market Street
Telephone: +61 2 9283 4825
11. Changes to this Policy
Version date: 30 October 2020