SPG Projects Pty Ltd ABN 19 601 486 864 (“SPG”) is subject to the Australian Privacy Principles contained within the Privacy Act 1988 (“Act”).
The purpose of this policy is to describe how SPG collects, holds, uses and discloses personal information and complies with the privacy requirements in protecting the personal information SPG holds about individuals.
Personal information is defined in the Act as “information or an opinion about an identified individual, or an individual who is reasonably identifiable:
a) Whether the information or opinion is true or not; and
b) Whether the information or opinion is recorded in a material form or not.”
Collection of personal information
The types of personal information about SPG collects will depend upon what dealings the relevant individual may have with SPG. SPG may collect and hold information about:
SPG employees: personal information such as contact details, banking details, date of birth, other payroll details, superannuation information, tax file number and emergency contacts
Applicants for jobs at SPG: personal information such as contact details, employment history and other background information as required and as permitted by law
SPG website enquiries: information that allows SPG to respond to enquiries made through the SPG website, such as name, contact number and email address
SPG website subscribers: information that allows SPG to communicate with website subscribers, such as name and email address. SPG will only do so where individuals have“opted in” to receive this information
Suppliers: information required to establish and maintain records and systems to enable payment for goods and services
Individuals as contractors: information required to establish and maintain records and systems to enable payment for services
SPG investors: personal information such as contact details in order to respond to enquiries and/or provide information
SPG clients or prospective clients: information required in order to deliver services, such as name, address, e-mail address and phone number, company, work email, work address, role and job function, years of experience
Other individuals who may come into contact with SPG.
The Act imposes restrictions on collecting sensitive personal information. This includes information about religious views, ethnicity, political opinions and personal health information. SPG generally does not collect sensitive personal information about an individual, except in the instances where a pre-employment medical is undertaken as part of the selection and onboarding process. If sensitive personal information is collected, SPG will only deal with that information as permitted by the Act.
Use and disclosure of personal information
SPG’s policy is to only use personal information for the purpose which was either specified or reasonably apparent at the time the information was collected. SPG may also use or disclose the information collected for any other related purpose for which the individual would reasonably expect it to be used.
If SPG wishes to use or disclose personal information in other circumstances, the individual’s consent would need to be obtained.
SPG deals with personal information for a number of purposes, such as:•
- Performing payroll functions
Recruiting of employees and contractors
Improve and maintain the administration of employee benefits
Operate IT and communication systems
Internal business operations such as communicating with clients
Distribution of subscription emails
Responding to SPG website enquiries
Managing SPG’s everyday business needs such as payment processing, communicating with individuals and other companies about SPG’s services, contract management, analytics, corporate governance, reporting and legal compliance.
Disclosing information to other parties
SPG restricts its sharing of an individual’s personal information. In using personal information, SPG may need to disclose personal information to various third parties, sometimes outside of Australia. These include, but are not limited to:
SPG’s contractors and service providers who assist SPG in the operation of its business or to provide a customer service. SPG may share personal information with its service providers and contractors, who are bound by law or contract to protect the personal information and only use personal information as necessary to perform their services
Third party lenders and insurers
Anyone authorised by a provider of personal information
Relevant parties in situations when SPG is required by law to provide the information
Legal and regulatory authorities (such as the Australian Taxation Office), to accountants, auditors, lawyers and other outside professional advisers
Although most recipients of personal information are within Australia, others may be located, or have relevant operations elsewhere. Therefore, it may be necessary to transfer personal information abroad. Some of the countries to which information is transferred may not have laws regulating the collection and disclosure of personal information. In this instance, SPG will take reasonable steps to ensure that any recipients of personal information comply with the Act.
SPG understands that individuals do not want SPG to provide their personal information to third parties for their own marketing purposes and will not do so unless that individual has provided their consent for SPG to do so.
Cookies and other data collection technologies
In relation to SPG website usage, SPG collects certain information by automated means, using technologies such as cookies and browser analytics tools.
For example, when SPG’s website is visited, SPG places cookies on the individual’s computer. Cookies are small text files that websites send to computers or other internet connected devices to uniquely identify the browser or to store information or settings in the browser. In many cases, cookie preferences can be managed, and the individual can opt out of having cookies and other data collection technologies used by adjusting the settings on their browser.
The information SPG collects using cookies and other tools are only used in a non-identifiable way, without any reference to personal information. For example, SPG uses the information it collects about all website users to optimise SPG’s website and to understand website traffic patterns.
Applying for employment with SPG
SPG collects personal information from individuals who submit applications with SPG. If the application is unsuccessful, SPG may retain the information in case a more appropriate opportunity becomes available. The unsuccessful candidate can then contact SPG to request SPG not to retain the applicant’s information.
Security of personal information
SPG will take reasonable steps to protect the personal information that it holds from unauthorised access, modification, misuse, interference and loss. Personal information is held in the cloud on Microsoft Azure servers and services.
Internally, SPG restricts access to personal information to employees or parties who need access to the information in order to do their jobs. These employees are limited in number and are committed to maintaining confidentiality.
Access and changing personal information
SPG respects the right of an individual to access and amend their personal information. SPG will give individuals access to their personal information on request, subject to the Act. If any information is incorrect, out of date, incomplete, irrelevant or misleading, SPG will amend it upon request.
SPG may require substantiation of any request to access or amend personal information.
If SPG provides you with copies of the information you have requested, SPG may charge you a reasonable fee to cover the administrative costs of providing you with that information.
An individual can make a complaint about the way in which SPG has handled an individual’s personal information by writing to either of the following:
Head of People & Culture – Nicole Ford email@example.com
Head of Finance & Commercial – Lina Caldwell firstname.lastname@example.org
SPG will endeavour to act promptly in response to a complaint.
If you are not satisfied by SPG’s response to your complaint, you can contact the Australian Privacy Commissioner at its website www.oaic.gov.au or by phoning 1300 363 992.
Additional information in privacy
For further information about privacy issues and the protection of privacy, visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au .