RAW Marketing abides by the Australian Privacy Principles (“APPs”), which provide a scheme in relation to the collection, disclosure, use and storage of personal information. RAW Marketing’s objective is to handle information responsibly and provide you with some control over the way information about you is handled.
The Privacy Act provides for exemptions:
a) in relation to employee records (being records relating to a current or former employment relationship between RAW Marketing and the individual);
b) in relation to current and former contractors and subcontractors (for the purposes of meeting an obligation under a contract between the subcontractor and a contractor);
c) in relation to overriding state laws and/or Chapter 2 of the Criminal Code (except Part 2.5).
1. Collection of Personal Information
Personal information is information or opinion about an individual, or an individual who is reasonably identifiable (whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form). The nature of personal information collected by RAW Marketing generally comprises an individual’s name, address, phone number, fax, e-mail address, as well as interests and information about your transactions with us.
The primary purpose for collecting such information is to arrange, conduct and promote RAW Marketing’s business activities and provide you with requested services.
RAW Marketing may collect personal information from you in a number of ways. These include, but are not limited to situations in which you request to receive services from RAW Marketing, provide products or services to RAW Marketing, utilise RAW Marketing’s services, or when you communicate with RAW Marketing by telephone, fax, writing, email, or any other electronic means.
RAW Marketing also collects other types of personal information from time to time (e.g. credit information and drivers licence details), and will inform you upon collecting such information the purpose for which it is being collected.
RAW Marketing does not collect personal information unless it is reasonably necessary to perform one or more of our functions and activities or supply one or more of our services. On occasion, some of this personal information may be sensitive and RAW Marketing will only collect it with your consent or when required or authorised to by law. RAW Marketing or its agents will generally collect personal information from you directly. For example, we may collect personal information when you subscribe to one of RAW Marketing’s publications, complete a survey, become a client or supplier, attend a function or event, enter a competition, provide a resume or enter an agreement.
There may be other occasions when RAW Marketing needs to source personal information from third parties such as credit agencies, list brokers and recruitment agencies. If we do this, we will use reasonable efforts to notify you afterwards.
You may choose to deal with RAW Marketing anonymously or under a pseudonym where lawful and practicable (i.e. provided we are still able to provide the relevant service or do business with you without that information). For example, it might not be practical to deal with you anonymously if we need to process a payment, deliver goods or services or send personalised communications to you.
2. Use & Disclosure of Personal Information
Personal information provided to RAW Marketing may be shared with related companies. RAW Marketing takes all reasonably practical steps to keep such information strictly confidential. RAW Marketing may use and disclose your personal information for the purpose for which it was initially collected, namely all purposes necessary and incidental to the provision of goods or services by RAW Marketing or by anyone on behalf of RAW Marketing.
In addition, RAW Marketing may use and disclose your personal information for purposes related to the initial purpose of collection if that other purpose would be within your reasonable expectations. Related purposes include analysing your personal information for the purpose of identifying and referring you to services that may be of benefit or interest to you, displaying targeted advertising based on those interests, improving our services, conducting research, contacting you, internal auditing and administration, adding your name to a guest list or invitation list, or assisting RAW Marketing to carry out auditing, administration, or product enhancement.
Additionally, in the event of a re-organization, merger or sale, RAW Marketing may transfer any and all personal information we have collected from you to the relevant third party. RAW Marketing may also be required to disclose your personal information without your consent if the disclosure is:
a. required or authorised by law;
b. required in order to investigate an unlawful activity;
c. required by an enforcement body for investigative activities; or
d. necessary to prevent a serious and imminent threat to a person’s life, health or safety, or to public health or safety.
Generally, RAW Marketing will retain your personal information within Australia and not use or disclose it overseas. However, on some occasions the information may need to be transferred to overseas countries including but not limited to the US in order to perform one of RAW Marketing’s functions or activities. In these circumstances, RAW Marketing will either obtain your express or implied consent or will use its reasonable endeavours to ensure that the foreign entity to which your personal information is transferred has appropriate measures in place to protect your personal information.
Like most business organisations, RAW Marketing contracts out some functions and relies on third party suppliers to conduct specialised activities such as website management, mail out services, supply of equipment, and travel and hospitality services. Whilst personal information may be provided to these licensors and suppliers in order to enable them to perform the agreed tasks, RAW Marketing will make every effort to ensure that the supplier handles the personal information in accordance with the Australian Privacy Principles and confidentiality principles. RAW Marketing will require all such suppliers to provide privacy undertakings and enter confidentiality agreements.
3. Direct marketing
From time to time RAW Marketing may use your personal information to identify programs, products and services that may be of interest to you. RAW Marketing may use your personal information to send you information regarding RAW Marketing’s programs, products and services.
From time to time, RAW Marketing may also provide your personal information to carefully selected third parties for the purpose of them providing you with information regarding products and services specific to your needs, and to help RAW Marketing conduct product enhancement activities.
If you do not wish to receive direct marketing information from RAW Marketing or third parties (as applicable), please let RAW Marketing know by using the unsubscribe function in the communication you receive, or alternatively by contacting firstname.lastname@example.org/~rawmarke.
RAW Marketing will take immediate steps to ensure that you do not receive any such direct marketing information in future.
4. Personal Information Quality
RAW Marketing’s objective is to ensure that all personal information collected by RAW Marketing is accurate, complete and up-to-date. To assist RAW Marketing in achieving its objective, please contact the Privacy Officer if any of your details change. Further, if you believe that the information RAW Marketing holds is not accurate, complete or up-to-date, please contact the Privacy Officer on email@example.com/~rawmarke.
5. Personal Information Security
RAW Marketing is committed to keeping your personal information secure, and we will take reasonable precautions to protect your personal information from unauthorised access, loss, release, misuse or alteration. Your personal information may be stored in hard copy documents, but is generally stored electronically on RAW Marketing’s software or systems.
Whilst RAW Marketing takes all reasonable steps to secure your personal information from loss, misuse and unauthorised access, you acknowledge that all activities in which you intentionally or unintentionally supply information to RAW Marketing carries an inherent risk of loss of, misuse of, or unauthorised access to such information. RAW Marketing cannot be held responsible for such actions where the security of the personal information is not within the control of RAW Marketing, or where RAW Marketing cannot reasonably prevent such incident.
Additionally, you acknowledge that the collection and use of your personal information by third parties may be subject to separate privacy policies and/or the laws of other jurisdictions. 6. Access To Personal Information You may request access to the personal information RAW Marketing holds about you. The procedure for gaining access is as follows:
a. All requests for access to your personal information must be made in writing and addressed to the Privacy Officer.
b. You must provide as much detail as possible regarding the business entity, department or person to whom you believe your personal information has been provided, and when. This will allow RAW Marketing to process your request faster.
c. RAW Marketing will acknowledge your request within 14 days, and access will usually be granted within 14 days, or if it is more complicated, 30 days. RAW Marketing will inform you if this timeframe is not achievable.
d. You will be asked to verify your identity.
e. A fee may apply to such access in the event that a request for access is onerous or time consuming. Such a fee will cover staff costs involved in locating and collating information, and reproduction costs.
f. Depending on the circumstances, you may be forwarded the information by mail or email, or you may be required to personally inspect your records at the appropriate place.
g. You will be given the opportunity to correct any personal information that is no longer accurate.
In some circumstances, RAW Marketing may not be in a position to provide access. Such circumstances include the following:
a. access would create a serious threat to safety;
b. providing access will have an unreasonable impact upon the privacy of other individuals;
c. denying access is required or authorised by law;
d. the request is frivolous or vexatious;
e. legal proceedings are underway or anticipated, and the information would not be accessible through the process of discovery in the proceedings;
f. negotiations may be prejudiced by such access;
g. providing access is likely to prejudice law enforcement;
h. providing access is likely to prejudice action being taken or to be taken with respect to suspected unlawful activity or serious misconduct relating to RAW Marketing’s functions or activities; or
i. access would reveal a commercially sensitive decision making process.
If RAW Marketing denies access to your personal information, it will provide you with reasons in writing.
7. Changes To This Policy
RAW Marketing may, without notice, change this Policy from time to time for any reason and will update the Policy accordingly. We ask that you visit our website periodically in order to remain up to date with such changes.
If you believe that your privacy has been infringed or a breach of the APPs has occurred, you are entitled to complain. All complaints should initially be in writing and directed to the Privacy Officer. RAW Marketing will respond to your complaint as soon as possible, within 14 working days, to let you know who is responsible for managing your query. RAW Marketing will try to resolve the complaint within 30 working days. When this is not possible RAW Marketing will contact you to provide an estimate of how long it will take to handle the complaint.
If you believe RAW Marketing has not adequately dealt with your complaint, you may complain to the Privacy Commissioner whose contact details are as follows:
Officer of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992
GPO Box 5218 Sydney NSW 2001
9. Privacy Officer’s Contact Details
Please address all written correspondence to:
4F 182 Robertson Street,
Fortitude Valley, QLD, 4006