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July 27, 2017

Privacy Policy

Glenco’s Privacy Policy sets out our commitment to the protection of personal privacy as required under the Privacy Act 1988 (Cth) (“the Privacy Act”). Our privacy principles are based on the National Privacy Principles contained in Schedule 3 of the Privacy Act. The information in this document details how Glenco complies with the requirements of the Privacy Act in protecting the personal information we hold about individuals. These principles deal with the collection, use and disclosure of personal information, as well as access to information and intrusion issues.

1. COLLECTION

Glenco will only collect personal information that is necessary for one or more of its functions or activities. Glenco will only collect personal information by lawful and fair means and not in an unreasonably intrusive way. At or before the time (or, if that is not practicable, as soon as practicable after) Glenco collects personal information about an individual from the individual, Glenco will take reasonable steps to ensure that the individual is aware of:

  1. the identity of Glenco and how to contact it;
  2. the fact that he or she is able to gain access to the information;
  3. the purposes for which the information is collected;
  4. the organisations (or the types of organisations) to which Glenco usually discloses information of that kind;
  5. any law that requires the particular information to be collected; and
  6. the main consequences (if any) for the individual if all or part of the information is not provided.

If it is reasonable and practicable to do so, Glenco will collect personal information about an individual only from that individual. If Glenco collects personal information about an individual from someone else, Glenco will take reasonable steps to ensure that the individual is or has been made aware of the matters listed from (a) to (f) above except to the extent that making the individual aware of the matters would pose a serious threat to the life or health of any individual.

2. USE & DISCLOSURE

Glenco will not use or disclose personal information about an individual for a purpose other than the primary purpose of collection unless:

    1. both of the following apply:
      1. the secondary purpose is related to the primary purpose of collection and, if the personal information is sensitive information, directly related to the primary purpose of collection;
      2. the individual would reasonably expect Glenco to use or disclose the information for the secondary purpose; or
    2. the individual has consented to the use or disclosure; or
    3. if the information is not sensitive information and the use of the information is for the
    4. secondary purpose of direct marketing:
      1. it is impracticable for Glenco to seek the individual’s consent before that particular use; and
      2. Glenco will not charge the individual for giving effect to a request by the individual to Glenco not to receive direct marketing communications; and
      3. The individual has not made a request to Glenco not to receive direct marketing communications; and
      4. In each direct marketing communication with the individual, Glenco draws to the individual’s attention, or prominently displays a notice, that he or she may express a wish not to receive any further direct marketing communications; and
      5. Each written direct marketing communication by Glenco with the individual (up to and including the communication that involves the use) sets out Glenco’ business address and telephone number and, if the communication with the individual is made by fax, telex or other electronic means, a number or address at which Glenco can be directly contacted electronically; or
    5. the information is health information and the use or disclosure is necessary for research, or the compilation or analysis of statistics, relevant to public health or public safety:
      1. it is impracticable for Glenco to seek the individual’s consent before the use or disclosure; and
      2. the use of disclosure is conducted in accordance with guidelines approved by the
      3. in the case of disclosure – Glenco reasonably believes that the recipient of the health information will not disclose the health information, or personal information derived from the health information; or
    6. Glenco reasonably believes that the use or disclosure is necessary to lessen or prevent:
      1. a serious and imminent threat to an individual’s life, health or safety; or
      2. a serious threat to public health or public safety; or
    7. Glenco has reason to suspect that unlawful activity has been, is being or may be engaged in, and uses or discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities; or
    8. The use or disclosure is required or authorised by or under law; or
    9. Glenco reasonably believes that the use or disclosure is reasonably necessary for one or more of the following by or on behalf of an enforcement body
      1. the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing an penalty or sanction or breaches of a prescribed law;
      2. the enforcement of laws relating to the confiscation of the proceeds of crime;
      3. the protection of the public revenue;
      4. the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct;
      5. the preparation for, or conduct of, proceedings before any court or tribunal, or

implementation of the orders of a court or tribunal. If Glenco uses or discloses personal information under paragraph (h) above, it will make a written note of the use or disclosure. The first paragraph above operates in relation to personal information that Glenco has collected from a related body corporate as if Glenco’ primary purpose of collection of the information were the primary purpose for which the related body corporate collected the information.

3. DATA QUALITY

Glenco will take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up-to-date.

4. DATA SECURITY

Glenco will take reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure. Glenco will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed under Glenco Privacy Protection Principle 2 Use and Disclosure.

5. OPENNESS

Glenco has a document that clearly expresses policies on its management of personal information. Glenco will make the document available to anyone who asks for it. On request by an individual, Glenco will take reasonable steps to let the individual know, generally, what sort of personal information it holds, for what purposes, and how it collects, uses, and discloses that information.

6. ACCESS AND CORRECTION

If Glenco holds personal information about an individual, it will provide the individual with access to the information on request by the individual, in a form or manner suitable to the individual’s reasonable needs, except to the extent that:

      1. in the case of personal information other than health information, providing access would pose a serious and imminent threat to the life or health of any individual; or
      2. in the case of health information – providing access would pose a serious threat to the life or health of any individual; or
      3. providing access would have an unreasonable impact upon the privacy of other individuals;or
      4. the request for access is frivolous or vexatious; or
      5. the information relates to existing or anticipated legal proceedings between Glenco and the individual, and the information would not be accessible by the process of discovery in those proceedings; or
      6. providing access would reveal the intentions of Glenco in relation to negotiations with the individual in such a way as to prejudice those negotiations; or
      7. providing access would be unlawful; or
      8. denying access is required or authorised by or under law; or
      9. providing access would be likely to prejudice an investigation of possible unlawful activity; or
      10. providing access would be likely to prejudice:
        1. the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; or
        2. the enforcement of laws relating to the confiscation of the proceeds of crime; or
        3. the protection of the public revenue; or
        4. the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or
        5. the preparation for, or conduct of, proceedings before any court or tribunal, or
      11. an enforcement body performing a lawful security function asks Glenco not to provide access would be likely to cause damage to the security of Australia.

However, where providing access would reveal evaluative information generated within Glenco in connection with a commercially sensitive decision-making process, Glenco may give the individual an explanation for the commercially sensitive decision rather than direct access to the information. If Glenco is not required to provide the individual with access to the information because of the above reasons, Glenco must, if reasonable consider whether the use of mutually agreed intermediaries would allow sufficient access to meet the needs of both parties. If Glenco levies charges for providing access to personal information, those charges:

  1. will not be excessive; and
  2. will not apply to lodging a request for access.

If Glenco holds personal information about an individual and the individual is able to establish that the information is not accurate, complete and up-to-date, Glenco will take reasonable steps to correct the information so that it is accurate, complete and up-to-date. If the individual and Glenco disagree about whether the information is accurate, complete and up-to date, and the individual asks Glenco to associate with the information a statement claiming that the information is not accurate, complete or up-to-date, Glenco will take reasonable steps to do so. Glenco will provide reasons for denial of access or a refusal to correct personal information.

7. IDENTIFIERS

Glenco will not adopt as its own identifier of an individual an identifier of the individual that has been assigned by:

  1. an agency; or
  2. an agent of an agency acting in its capacity as agent; or
  3. a contracted service provider for a Commonwealth contract acting in its capacity as contracted service provider for that contract.

Glenco will not use or disclose an identifier assigned to an individual by an agency, or by an agent or contracted service provider mentioned above unless:

  1. the use of disclosure is necessary for Glenco to fulfil its obligations to the agency; or
  2. one or more of paragraphs (e) to (h) in Privacy Protection Principle 2 above (inclusive) apply to the use of disclosure; or
  3. the use of disclosure is by a prescribed organisation of a prescribed identifier in prescribed circumstances.

8. ANONYMITY

Wherever it is lawful and practicable, individuals must have the option of not identifying themselves when entering transactions with an organisation.

9. TRANSBORDER DATA FLOWS

Glenco will transfer personal information about an individual to someone (other than Glenco or the individual) who is in a foreign country only if:

  1. Glenco reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to Glenco’ Privacy Protection Principles;
  2. The individual consents to the transfer;
  3. The transfer is necessary for the performance of a contract between the individual and Glenco, or for the implementation of pre-contractual measures taken in response to the individual’s request;
  4. The transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between Glenco and a third party;
  5. All of the following apply:
    1. The transfer is for the benefit of the individual; and
    2. It is not practicable to obtain the consent of the individual to that transfer;
    3. If it were practicable to obtain such consent, the individual would be likely to give it;
  6. Glenco has taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with Glenco’ Privacy Protection Principles.

10. SENSITIVE INFORMATION

Glenco will not collect Sensitive Information about an individual unless:

  1. the individual has consented; or
  2. the collection is required by law; or
  3. the collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual, where the individual whom the information concerns:
    1. is physically or legally incapable of giving consent to the collection; or
    2. physically cannot communicate consent to the collection; or
  4. if the information is collected in the course of the activities of a non-profit organisation, the following conditions are satisfied:
    1. the information relates solely to the members of the organisation or to individuals who have regular contact with it in connection with it’s activities;
    2. at or before the time of collecting the information, the organisation undertakes to theindividual whom the information concerns that the organisation will not disclose the information without the individuals consent; or
  5. the collection is necessary for the establishment, exercise or defence of a legal or equitable claim.

Despite the first paragraph, Glenco may collect health information about an individual if:

      1. The collection is necessary for any of the following purposes:
        1. Research relevant to public health or public safety;
        2. The complication or analysis of statistics relevant to public health or public safety;
        3. The management, funding or monitoring of a health service; and
      2. that purpose cannot be served by the collection of information that does not identify the individual of from which the individual’s identity cannot reasonably be ascertained; and
      3. it is impracticable for Glenco to seek the individual’s consent to the collection; and
      4. the information is collected:
      5. as required by law (other than the Privacy Act); or
      6. in accordance with rules established by competent health or medical bodies that deal with obligations of professional confidentiality which bind Glenco; or
      7. in accordance with guidelines approved by the Privacy Commissioner under section 95A of the Privacy Act.

If Glenco collects health information about an individual in accordance with this last paragraph, Glenco will take reasonable steps to permanently de-identify the information before Glenco discloses it.

Contacting Glenco

If you require further information regarding Glenco’s Privacy Policy, you can contact Glenco:

Phone: (02) 9700 9996

Fax: (02) 9700 9966

Email: service@glenco.com.au

Address: Unit 16, 34-36 Ralph Street, Alexandria NSW 2015, Australia