Purpose
People + Culture Strategies Pty Ltd ( “PCS”, “we” or “us”) recognises and respects your privacy and is committed to complying with the Australian Privacy Principles as set out in the Privacy Act 1988 (Cth) (the “Privacy Act”). This policy describes the way in which PCS endeavours to comply with its privacy obligations.
This policy applies to everyone who interacts with us, including clients, suppliers, users of our website and job applicants, however, a separate privacy policy applies to PCS’ employees. By providing personal information to PCS, you consent to the collection, use and disclosure of that information as set out in this policy.
PCS may amend this policy from time-to-time and an up-to-date version can be found on PCS’ website.
Collecting your personal information
“Personal information” includes information or opinion about an individual, whether true or not, whose identity is apparent or can be reasonably ascertained. The personal information PCS collects from you depends on the nature of our interaction with you. PCS collects personal information from a range of people including clients, suppliers, job applicants and from individuals who access our website, for example, to provide feedback, subscribe to a publication or to express interest in employment.
The information that might be collected and held about you includes:
- name, job title, address (personal and/or business), telephone number, email address;
- bank account or credit card details;
- interest in and/or attendance at events;
- interest in and/or downloading of publications, papers or articles.
PCS will collect personal information only by lawful and fair means. Where practicable, we will collect the information directly from you. From time to time, we may collect personal information about you from a third party, such as your employer or a publically accessible website.
Personal information may be collected in writing (including by email, facsimile or text message), through PCS’ website, via telephone or during meetings. It will be held in electronic and/or hard copy form, in accordance with the security section of this policy.
If you provide personal information to PCS about another person, you must ensure that you are an authorised or permitted by that person to disclose that information and that PCS is permitted to collect, use and disclose that information for the purposes described above.
Website
Should you use PCS’ website (www.peopleculture.com.au), please note that we only collect personal information from you voluntarily. This includes if you subscribe to publications or send us a query. We also collect anonymous information when you access our website, such as pages visited, duration of visit and whether you are a new or returning visitor. You cannot be identified from this information and it is used for internal analytical purposes. PCS also provides links to third party websites, such as hosts of PCS’ webinars. PCS cannot control such third party websites.
The PCS website uses temporary internet cookies. A cookie is a small piece of data sent from a website which is stored in your web browser. While some cookies can collect and store information, you can block cookies using the settings on your web browser.
Sensitive information
Sometimes, it may be necessary for PCS to collect ‘sensitive information’ about you. It is a type of personal information and includes information or an opinion, whether true or not, about a person’s race, ethnic origin, political opinions, membership of political, professional or trade associations, religious beliefs or affiliations, philosophical beliefs, sexual preferences or practices, criminal record or health information.
PCS will not collect sensitive information about you unless you consent and the information is reasonably necessary for or directly related to PCS’ functions or activities, or if an exemption exists, such as authorisation at law.
Pseudonym
If practicable to do so and no legal barrier exists, PCS may give individuals the option of not identifying themselves or using a pseudonym when dealing with PCS. If you do not provide personal information to us, however, we may at our discretion refuse to provide our services to you.
Unsolicited information
If PCS receives unsolicited personal information, it will determine within a reasonable period, whether or not it could have collected the information if it had solicited it. If PCS determines that it could not have collected the personal information, it will, as soon as practicable and if lawful and reasonable to do so, destroy the information or de-identify it.
Use and disclosure of personal information
PCS may use or disclose personal information for the primary purpose for which it was collected. PCS may also use or disclose that information for a related purpose if you have consented or if you would reasonably expect disclosure of that information and the disclosure is related to the primary purpose, or if there is another exemption, such as a requirement by law.
The purposes for which we collect, use and disclose information will normally be obvious at the time of collection. Examples include:
- for the provision of services to you;
- to develop our (existing or potential) relationship with you;
- to directly market and tailor our services to you (and PCS provides the opportunity to opt out of direct marketing communications);
- to provide you with information about our publications and / or upcoming events;
- responding to queries from you;
- for potential employment-related purposes; and
- to comply with legal and regulatory obligations
PCS may disclose your personal information to external service providers or contractors who assist with our business systems and operations, such as archiving and storage services or information technology experts, so that they can assist us with providing and marketing our services to you.
When dealing with the personal information of clients, PCS must comply with its professional obligations of confidentiality.
Where available, PCS relies on exemptions in the Privacy Act, including the employee records exemption.
Cross-border disclosure
Generally, PCS does not disclose personal information to overseas recipients.
Storage and security of information
PCS makes all reasonable efforts to ensure that personal information it holds is protected from misuse, interference, loss, modification, unauthorised access or disclosure. Security measures include:
- requiring staff who handle personal information to respect and maintain the confidentiality of that information;
- password protection of computer systems;
- the use of firewalls, encryption and virus scanning devices to prevent unauthorised access to PCS’ computer systems; and
- maintaining strict control to securing its physical premises.
Complete security of your information cannot, however, be guaranteed.
Accuracy and correction
PCS will act reasonably where possible to ensure that personal information that it collects is accurate, up-to-date and complete. PCS requests that you notify us of any information we hold about you which you believe is inaccurate and of any changes to your personal information as soon as possible. Generally, PCS will take reasonable steps rectify the relevant information. If PCS refuses to correct the information as requested by you, PCS will give you a written notice setting out the reasons for the refusal and the mechanisms available to complain.
Access
If you wish to access personal information that PCS holds about you, contact the Privacy Officer (see details below). You may be required to verify your identity. PCS can refuse a request to access personal information in certain circumstances, for example, where it would have an unreasonable impact on the privacy of others or if access would be unlawful. PCS may charge you a fee if access is provided. If PCS refuses to give you access to personal information it will give you a written notice setting out the reasons for the refusal and the mechanisms available to complain.
Complaints
You can complain to PCS if you believe there has been a breach of the Australian Privacy Principles by emailing the Privacy Officer or telephoning (02) 8094 3100 and requesting to speak to PCS’ Privacy Officer. PCS will consider your complaint and contact you as soon as reasonably practicable to inform you whether we need further information, whether we accept your complaint or whether we do not believe there has been a breach. If you are not satisfied with PCS’ response, you may complain to the Office of the Australian Information Commissioner.
Contact
Any queries that you have about this policy can be directed to:
The Privacy Officer
People + Culture Strategies
Level 9, 255 George Street, Sydney NSW 2000
E: info@peopleculture.com.au
T: +61 2 8094 3100 | F +61 2 8094 3149