HB Land Pty Ltd A.B.N. 46 637 165 498 (“HB Land”, “we”, “us”, “our”) is bound by the Privacy Act 1988 (“the Act”) and the Australian Privacy Principles (“APPs”) set out in the Act. We are committed to respecting your right to privacy and protecting your Personal Information.
We will ensure that our employees and contractors are aware of, and understand, our obligations, as well as their own obligations, under the Act. We achieve this through developing and maintaining internal policies and procedures to prevent Personal Information from being improperly collected, used, disclosed, retained, accessed or disposed of.
This policy applies to all of your dealings with us, whether in person, by telephone or by written correspondence.
The purpose of this policy is to:
Inform you about the types of Personal Information we collect and hold;
Describe how and when we collect, disclose, use, store and otherwise handle Personal Information;
Explain why we collect, hold, use and disclose Personal Information;
Inform you about how you may access your Personal Information, and seek correction of your Personal Information;
Clarify how you can make a complaint, and how we will deal with any such complaint.
3. The kinds of Personal Information we may collect and hold:
We may collect and hold certain types of Personal Information about you, including but not limited to:
Contact information including your residential, business and postal address, contact telephone number and email address;
Date of birth;
Financial information including, but not limited to, income, expenses, assets and liabilities;
Credit reporting information;
We will not usually collect any Sensitive Information and we will only collect this information if:
it is reasonably necessary in order to carry out our duties; and
you consent to our collection of the Sensitive Information; or
we are required or authorised by law to collect the Sensitive Information.
For the purposes of this policy:
Personal Information means 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;
(b) whether the information or opinion is recorded in a material form or not.
Sensitive Information means information or an opinion about an individual’s racial or ethnic origin, or political opinions, or membership of a political association, or religious beliefs or affiliations, or philosophical beliefs, or membership of a professional or trade association, or membership of a trade union, or sexual orientation or practices, or criminal record, or health information, or genetic information, or biometric information or biometric templates.
4. How we will collect Personal Information:
We will collect the Personal Information directly from you when you complete a form or deal with us in person, by telephone and/or by written correspondence.
We may, with your knowledge and consent, collect your Personal Information from a third party or a publicly available source. For example, we may collect Personal Information from a credit reporting agency or a third party that you indicate to us holds the relevant Personal Information.
5. Holding and protecting your Personal Information:
We take appropriate measures to protect your Personal Information, which may be stored in hard copy documents or electronically. Hard copy documents containing your Personal Information will be stored in lockable filing cabinets within a secured office.
Personal Information kept electronically will be stored on our central server which is located within a secured room, where all of our secure data is stored. All of our data, including Personal Information, is securely backed up.
Access to your Personal Information is limited to our employees and contractors. Our employees and contractors are bound to keep all information we hold confidential.
We only collect and store your Personal Information when it is reasonably necessary or directly related to providing the services which you have engaged us to provide.
6. Use and disclosure (sharing) of Personal Information:
We will only disclose Personal Information to the persons or entities for the purpose that it was initially collected, that is, for the purpose of providing the services you have engaged us to perform. We will advise you of:
the particular purpose that we are collecting Personal Information; and
the persons or entities that we intend to share the Personal Information with;
By providing the Personal Information for this purpose, you consent to us sharing the information with those persons or entities.
We may use Personal Information for the purpose that it was initially collected. We may also use Personal Information for direct marketing purposes, if you do not consent to the use of your Personal Information for direct marketing purposes, you may advise us by email at any time.
We will not disclose your Personal Information to government agencies, private companies or any other third party unless:
You have consented to the disclosure of the information; or
You have been informed, or would reasonably expect, that such information is usually passed to those parties; or
It is required or authorised by law for us to do so; or
It is reasonably necessary for enforcement activities conducted by, or on behalf of, an enforcement body.
7. Accessing your Personal Information
You have the right to request access to your Personal Information we hold and to request a correction be made to inaccurate information.
If you make a request, we will send an acknowledgement of your request within 14 business days. Usually the access will be granted within 14 business days from receipt of our acknowledgement. If the request involves complex considerations or clerical work and we will not be able to provide the access within 14 days, we will advise you of the anticipated date for access.
You will need to verify your identity before access to your Personal Information is granted.
We do not charge a fee for your request to access or correct Personal Information. However, a fee may be payable on account of our collation and reproduction costs if we are required to provide the Personal Information in your preferred format.
We will usually provide the Personal Information to you by mail or email. We will endeavour to make the information available to you in your preferred manner unless, in the circumstances, it would be unreasonable to do so.
We may refuse to grant you access to Personal Information if:
we believe that it would pose a serious threat to the life, health or safety of any individual or the public;
it would have an unreasonable impact upon the privacy of other individuals;
denial of access is required or authorised by law or by a Court or Tribunal;
the request is frivolous or vexatious;
legal proceedings are underway or anticipated and the information would not be accessible pursuant to a discovery process;
it is likely to prejudice enforcement related activities conducted by an enforcement body, or action being taken with respect to suspected unlawful activity or serious misconduct relating to our functions or it would reveal information in connection with a commercially sensitive decision.
If we refuse you access to, or do not agree to correct your Personal Information, we will provide written reasons for the refusal and our internal complaint process.
If you believe that we have breached the Australian Privacy Principles, you have the right to make an internal complaint.
We will acknowledge receipt of a complaint within 14 days.
We will investigate and provide a response to the complaint within 20 business days from the date we receive the complaint. If we are unable to respond within this timeframe, we will provide an alternate timeframe in which we will investigate and provide our response.
If your complaint remains unresolved after you receive our response, you may:-
Contact the Office of the Australian Information Commissioner:
Mail: Office of the Australian Information Commissioner (OAIC)
GPO Box 5218
Phone: 1300 363 992