Senetas Privacy Policy Statement

This statement sets out Senetas’ privacy policy and the practices that will be followed to respect the privacy of individuals who deal with Senetas. This statement is provided in accordance with the Privacy Amendment (Private Sector) Act 2000 (Cth) and the National Privacy Principles (“NPP’s”) which are set out in that Act.

Collection of information

The type of information collected by Senetas regarding individuals generally includes the following:

names
addresses (including e-mail addresses)
telephone and facsimile numbers

The information held by Senetas may come from a number of sources including:

potential employees
independent contractors
existing and new contacts and customers of the company
other sources

Collecting your information using this website

At Senetas, we have focused on implementing fair information practices that are designed to protect your privacy. We are also keen to understand better what our visitors most appreciate on our site, and the sections and pages they deem of most interest. This will allow us to gear senetas.com to the preference of our general audience.

To this effect, Senetas analyses visitor information related to www.senetas.com, we collect web traffic data and data related to your browser type and PC—on the basis of your IP Address. We cannot use that data to identify you personally.

Cookies are also used in this context. "Cookies" is a name for a technology that allows our site to store tokens of information in your browser, to give your browser an identifier used only by our site while you are on our site, but not to identify you. Cookies help us track traffic patterns in the aggregate so that we know what areas of our site users like and don't like based on traffic to those areas. Cookies are not used to determine or track the identity of any user on senetas.com. If you do not want to receive a cookie from senetas.com or any other site, you have the option of setting your browser to notify you when you receive a cookie allowing you to determine whether or not to accept it. Refer to your browser manual for instructions.

If you have any questions or concerns regarding to our measurement activities and how they impact your privacy while using senetas.com, please contact the Senetas Company Secretary.

Some information Senetas holds may be “Sensitive Information”

Sensitive Information is information or an opinion about an individual’s:

race or ethnic origin; or
political opinion; or
membership of a political association or religious beliefs, affiliations or philosophical beliefs; or
membership of a professional or trade association or membership of a trade union; or
sexual preferences or practices; or
criminal record.

Sensitive information also includes health information about an individual. Senetas will only collect sensitive information with the individual’s consent.

Senetas will not collect personal information unless the information is necessary for one or more of its functions or activities. Senetas will collect the personal information only by lawful and fair means and not in an unreasonably intrusive way. Whenever Senetas collects personal information about an individual, Senetas will take reasonable steps to ensure that the individual is aware of:

the identity of Senetas
the fact that he or she is able to gain access to the information
the purpose for which the information is collected
the organisations to which Senetas usually discloses information of that kind
any law that requires the particular information to be collected
the main consequences (if any) for the individual if all or part of the information is not provided.

If it is reasonable and practical to do so, Senetas will collect personal information about an individual only from that individual. If however this information is collected from someone else, Senetas will act reasonably to ensure the individual is or has been made aware of the matters listed above, unless certain exemptions apply.

The purposes for which Senetas uses this information

The purposes for which Senetas uses the personal information referred to above include the following:

to consider potential employee’s applications for employment by the company
to open and administer customer accounts
to provide IT services to customer
to administer independent contractors of the company
for marketing and sales initiatives such as Senetas publications, events and business programs.

Use and disclosure

As a general rule, Senetas will not use or disclose personal information about an individual other than for its primary purpose of collection, unless:

the individual has consented to the use or disclosure; or
Senetas has reason to suspect that unlawful activity has been, 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
the use or disclosure is required or authorised by, or under law; or
Senetas reasonably believes that the use or disclosure is reasonably necessary for a specified purpose by or on behalf of an enforcement body.

Senetas will use the information for our own direct marketing purposes only where:

it is impractical for Senetas to seek the individual’s consent before that particular use
Senetas will not charge the individual for giving effect to a request not to receive direct marketing communications
the individual has not made a request not to receive direct marketing communications
in each direct marketing communication with the individual, Senetas 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
each written direct marketing communication by Senetas with the individual (up to and including the communication that involves the use) sets out Senetas’ business address and telephone number and, if the communication is made by fax or email or other electronic means, a number or address at which Senetas can be directly contacted electronically.

Data quality

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

Data security

Senetas will take reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure.

Senetas will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.

Openness

Senetas has set out in this document its policies on management of personal information and will make this document available to anyone who asks for it.

On request by a person, Senetas will take reasonable steps to let the person know, generally, what sort of personal information we hold, for what purposes, and how we collect, hold, use and disclose that information.

Access and correction

As a general rule, Senetas will, on request by an individual, provide them with access to their personal information. Senetas may however choose not to provide individuals with access to such information. This would include cases where:

providing access would have an unreasonable impact on the privacy of other individuals
the request for access is frivolous or vexatious
the information relates to anticipated or existing legal proceedings and would not be discoverable in those proceedings
providing access would reveal the intentions of Senetas in relation to negotiations with the individual in such a way as to prejudice those negotiations
providing access would be unlawful
providing access would be likely to prejudice an investigation of possible unlawful activity
providing access would be likely to prejudice activities which are carried out by Senetas on behalf of an enforcement body.

Senetas may decide to impose a charge upon the individual to cover the cost of verifying a request for information and locating, retrieving, reviewing and copying any material requested.

Identifiers

Senetas will not adopt a government agency identifier (such as a tax file number or Medicare number) as its identifier of an individual.

Anonymity

Wherever it is lawful and practical, Senetas will allow individuals the option of not identifying themselves when entering into transactions with us.

Trans-border data flows

Senetas will only transfer personal information about an individual to a third party who is in a foreign country in specified circumstances. This would include:

where the individual consents to the transfer; or
where Senetas 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 the NPPs.

How can an individual complain about possible breaches of privacy by Senetas?

A complaint by an individual regarding an alleged breach of privacy by Senetas should be forwarded in writing to the following address:

Privacy Compliance Officer
Company Secretary
Senetas
Level 1/11 Queens Road
Melbourne 3004

The Privacy Complaints Enquiry Officer will be made available to investigate and resolve the complaint internally through mediation with the individual.

If the individual is not happy with the resolution of their complaint by the Privacy Complaints Enquiry Officer they may then complain to the Privacy Commissioner or Industry Code adjudicator about the act or practice they consider to be an interference with their privacy. The Commissioner then has the power to investigate the alleged breach by examining witnesses, obtaining documents and directing individuals to attend compulsory conferences. The Privacy Commissioner's determinations in such cases are
enforceable by the High Court.