1. “Group” refers to all entities that are managed and administered together primarily by Estates Development Company 1948 Pty Ltd and includes companies, trusts and partnerships.
2. “Personal Information” is defined in the Privacy Act 1988 (Cth) as 'information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not'. The types of Personal Information that the Group collects and holds will depend on the circumstances and relationship between the individual and the Group. Personal Information that is commonly collected by the Group includes:
3. Data collected by the Group can in appropriate circumstances include:
4. “Privacy Statement” means a notification to an individual that address the following (as are reasonably in the circumstances):
2. Collecting Personal Information
1. The Group collects personal information in a number of ways depending on the type of dealings that a person may have with the Group:
2. The information is collected in a number of forms including over the phone, contractually, via settlement agents, through applications and in all digital formats, including but not limited to cookies referred to in clause 5.
3. The Group will not collect Sensitive Information (as defined in the Privacy Act 1988 (Cth)) unless:
4 The Group will take reasonable steps to provide a Privacy Statement to an individual at or before the time (or, if that is not practicable, as soon as practicable after) the Group collects Personal Information about the individual.
3. Purpose for the Collection of Personal Information
1. The Group collects personal information for a number of purposes:
2. The Group will not collect Personal Information unless the information is reasonably necessary, or directly related to, one or more of the Group's functions or activities.
3. If the Group receives unsolicited Personal Information, and the Group has no lawful basis on which to retain the information, the Group will destroy that information or ensure that it is de-identified.
4. If requested to do so, the Group will provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with the Group, except where:
1. The Group will not sell, rent or trade supply to third parties any personal information obtained unless consent is given.
2. The Group may disclose personal information in some circumstances relating to the operation of the Groups’ businesses including:
3. It is not standard practice for the Group to disclose personal information to overseas recipients. However, there is a possibility that on occasion your personal information may be disclosed to an overseas recipient. The location of any potential recipients will vary depending on the project or purpose concerned. Should you have any queries about the potential disclosure of your personal information to an overseas recipient, please contact the Company Secretary (contact details in clause 13).
1. A cookie is a packet of information placed on a user’s computer by a website for record keeping purposes. Cookies are generally used on the Groups’ sites to:
2. Cookies may also be used for other purposes but the information collected is not used to personally identify users.
3. Information collected through Cookies is not sold, traded or rented to third parties for their use. Information collected is used by the Group and is only made available to third party consultants or advisers, for the purposes of the Group.
1. The Group has security procedures in place and technology to protect against loss, misuse and/or alteration of the information under its control. Databases on the groups’ servers (externally located) are security protected.
1. All employees have access to Personal Information. Employees are responsible for maintaining the appropriate level of privacy in relation to Personal Information available to them.
2. To do this employees must:
3. An employee who misuses Private Information for their own purposes and gain will be subject to disciplinary action. The sale of any Personal Information maintained on a Data Base may result in dismissal.
8. Access to Personal Information
1. Organisations and individuals may contact the Group to request access to their Private Information. Subject to the relevant exemptions contained in the APPs and subject to an individual providing sufficient proof of his or her identity the Group will provide access to information that it holds relating to an individual. The Group reserves the right to charge a fee for the provision of this information based on the administrative cost of supplying the information requested. Further details as to these costs and the ability to access information held by us can be obtained by contacting our Company Secretary (contact details in clause 13).
9. Management of Personal Information
1. The Group will take such steps as are reasonable in the circumstances to:
2. If an organisation or an individual wishes to change personal information this is inaccurate or out of date, they may contact the Company Secretary (contact details in clause 13), providing details of the Private Information they want amended.
10. Retention of Private Information:
1. Personal Information that is no longer used by the Group may be retained if required to meet the Group’s legal obligation to keep records under tax, corporation or other legislation.
2. The Group will take reasonable steps to destroy Personal Information if:
1. If an individual believes that their Personal Information has not been handled by the Group in accordance with this Policy, the individual may make a compliant in writing or by email to Company Secretary (contact details in clause 13).
2. Complaints will be processed in a reasonable time (usually 30 days from the date on which the complaint was received). Individuals will be advised in writing of the Group's decision and any action taken.
3. The Group will comply with any applicable mandatory data breach notification requirements.
13 Contact details
Attention: Company Secretary
Address: 83 Pirie Street, Adelaide, SA, 5000
Phone: 08 8223 1488