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NORPRIM Privacy Policy
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This Privacy Policy sets out the approach which NORPRIM will take in relation
to the treatment of Personal Information. It includes information on how NORPRIM
collects, uses, discloses and keeps secure, individuals' Personal Information.
It also covers how NORPRIM makes the Personal Information it holds available for
access to and correction by the individual.
This policy has been drafted having regard to NORPRIM' obligations under the
Privacy Act 1988 (including the new National Privacy Principles) (the Privacy
Act).
This Policy is a public document and has been prepared in light of National
Privacy Principle 5, Openness.
1. Collection
1.1 NORPRIM will only collect Personal Information where the information is
necessary for NORPRIM to perform one or more of its functions or activities. In
this context, "collect" means gather, acquire or obtain by any means,
information in circumstances where the individual is identifiable or identified.
1.2 NORPRIM collects Personal Information primarily to supply customers with
the products and services ordered from it. NORPRIM also collects and uses
Personal Information for secondary purposes including:
(i) billing and account management;
(ii) business planning and product development; and
(iii) to provide individuals with information about promotions, as well as other
products and services.
1.3 NORPRIM will notify individuals (including, but not limited to, our
customers) of the matters listed below before collecting any Personal
Information:
i) the main reason that we are collecting Personal Information (this reason will
be the Primary Purpose);
ii) other related Uses or Disclosures that we may make of the Personal
Information (Secondary Purposes);
iii) our identity and how individuals can contact us, if this is not obvious;
iv) that individuals can access the Personal Information that NORPRIM holds
about them;
v) that individuals should contact our customer service department (even if they
are not a customer) if wish to access or correct Personal Information collected
by us or have any concerns in relation to Personal Information;
vi) the organisations or types of organisations to whom we usually Disclose the
Personal Information including Related Bodies Corporates and contractors;
vii) where applicable, any law that requires the Personal Information to be
collected (for example, information that is required to be collected for the
Integrated Public Number Database which is used by directory publishers);
viii) the consequences (if any) for the individual if all or part of the
Personal Information is not provided to NORPRIM.
1.4 Where it is not practicable for NORPRIM to notify individuals of all of the
Collection Information before the collection of Personal Information, NORPRIM
will ensure that individuals are notified of the Collection Information as soon
as possible after the collection. NORPRIM will only engage in "post collection
notification" in those circumstances where it is not practicable to notify
individuals about the collection of their personal information before it is
collected.
1.5 When collecting Personal Information over the telephone, it may not always
be practicable to provide all the Collection Information at that time. In such
circumstances, we will provide the individual with NORPRIM' contact details, and
then provide the balance of the Collection Information in a confirming letter.
1.6 NORPRIM will not collect Sensitive Information from individuals except with
consent and only where it is necessary for NORPRIM to collect such information
for an activity or function.
1.7 NORPRIM will not collect Personal Information secretly or in an underhanded
way.
1.8 NORPRIM will take steps to ensure that individuals on purchased lists are or
have been notified of the information as outlined at 1.3.
2. Use
2.1 NORPRIM will obtain an individual's consent for Use of non-sensitive
Personal Information for Secondary Purposes at the time of collection, unless
the Use is a related Secondary Purpose which would be within the relevant
individual's Reasonable Expectations.
2.2 NORPRIM Uses Personal Information primarily for the purposes listed in 1.2
above.
2.3 If NORPRIM relies on the Direct Marketing exception to Direct Market to
individuals it will ensure that:
i) the individual is clearly notified of their right to Opt Out from further
Direct Marketing;
ii) there is only one Use of the information before the Opt Out right is given
and this Use applies across all NORPRIM' Related Bodies Corporate (if the
information is shared between those Related Bodies Corporate);
iii) the individual is given an Opt Out in all further instances of Direct
Marketing if they have not previously chosen to Opt Out; and
iv) if the individual Opts Out of all Direct Marketing the Opt Out will be
respected by NORPRIM and all its Related Bodies Corporate.
2.4 NORPRIM will not use Sensitive Information for Direct Marketing.
2.5 NORPRIM may use Personal Information to avoid an imminent threat to a
person's life or to public safety. It may also use Personal Information for
reasons related to law enforcement or internal investigations into unlawful
activities.
2.6 NORPRIM will not use Personal Information without taking reasonable steps to
ensure that the information is accurate, complete and up to date.
2.7 NORPRIM will not attempt to match de-identified or anonymous data collected
through surveys or such online devices as "cookies", with information
identifying an individual, without the consent of the relevant individual.
3. Disclosure
3.1 NORPRIM may Disclose Personal Information to related or unrelated third
parties if consent has been obtained from the individual. This will include
obtaining the individual's consent for Disclosures made under the credit
reporting requirements of the Privacy Act.
3.2 NORPRIM may Disclose Personal Information between Related Bodies Corporate.
Where information is Disclosed to such a Related Body Corporate, that Related
Body Corporate is bound by the original Primary Purpose for which the
information was collected.
3.3 NORPRIM may Disclose Personal Information to unrelated third parties to
enable outsourcing of functions (such as billing), where that is Disclosure or
Use for a related Secondary Purpose and has been notified to individuals or
where such Disclosure is within the individual's Reasonable Expectations.
Individuals will be notified of NORPRIM' usual Disclosures via the Collection
Information, as outlined in 1.3.
3.4 NORPRIM will take reasonable steps to ensure that its contracts with third
parties include requirements for third parties to comply with the Use and
Disclosure requirements of the Privacy Act.
3.5 NORPRIM may Disclose Personal Information to law enforcement agencies,
government agencies, courts or external advisers where permitted or required by
law.
3.6 NORPRIM may Disclose Personal Information to avoid an imminent threat to a
person's life or to public safety.
3.7 If a Disclosure is not for a Primary Purpose; is not for a related Secondary
Purpose; or upfront consent has not been obtained, NORPRIM will not Disclose
Personal Information otherwise than in accordance with the exceptions set out at
3.1 to 3.6 above.
3.8 NORPRIM does not generally sell or share its customer lists on a commercial
basis with third parties but if it did, it would only do so if we had the
appropriate consent of the individual involved. If the consent provided is
conditional, NORPRIM will take steps to ensure (by contract) that the use of its
customer list by third parties does not exceed the scope of the consent.
4. Information quality
4.1 NORPRIM will review, on a regular and ongoing basis, its collection and
storage practices to ascertain how improvements to accuracy can be achieved.
4.2 NORPRIM will take steps to destroy or de-identify Personal Information after
as short a time as possible and after a maximum of seven years, unless the law
requires otherwise.
5. Information security
5.1 NORPRIM requires employees and contractors to perform their duties in a
manner that is consistent with NORPRIM' legal responsibilities in relation to
privacy.
5.2 NORPRIM will take all reasonable steps to ensure that paper and electronic
records containing Personal Information are stored in facilities that are only
accessible by people within NORPRIM who have a genuine "need to know" as well as
"right to know".
5.3 NORPRIM will review, on a regular and ongoing basis, its information
security practices to ascertain how ongoing responsibilities can be achieved and
maintained.
6. Access and correction
6.1 NORPRIM will allow its records containing Personal Information to be
accessed by the individual concerned in accordance with the Privacy Act.
6.2 NORPRIM will correct its records containing Personal Information as soon as
practically possible, at the request of the individual concerned in accordance
with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their
Personal Information should do so by contacting NORPRIM Customer Service, as per
the details on the back of this document. While some requests for access may be
handled by Customer Service, it may be necessary for your request to be
escalated to the NORPRIM Customer Relations Group.
6.4 NORPRIM will not charge a fee for processing an access request unless the
request is complex or is resource intensive.
7. Openness
7.1 NORPRIM' Customer Service representatives will be the first point of contact
for inquiries about privacy issues. Individuals wishing to make an inquiry or
complaint regarding privacy, should do so by contacting NORPRIM Customer
Service, as per the details on the back of this document.
7.2 Privacy complaints will be managed in accordance with NORPRIM' Complaint
Handling Policy.
7.3 NORPRIM websites will contain a prominently displayed privacy statement and
will include a copy of this NORPRIM Privacy Policy.
8. Anonymous transactions
8.1 NORPRIM will not make it mandatory for visitors to its web sites to provide
Personal Information unless such Personal Information is required to answer an
inquiry or provide a service. NORPRIM may however request visitors to provide
Personal Information voluntarily to NORPRIM (for example, as part of a
competition or questionnaire).
8.2 NORPRIM will allow its customers to transact with it anonymously wherever
that is reasonable and practicable.
9. Glossary
Collection Information means the information outlined in 1.3 notified to
individuals prior to, or as soon as practical after, the collection of their
Personal Information.
Direct Marketing means the marketing of goods or services through means of
communication including written, verbal or electronic means. The goods or
services which are marketed may be those of NORPRIM or a Related Body Corporate
or those of an independent third party organisation.
Disclosure generally means the release of information outside NORPRIM, including
under a contract to carry out an "outsourced function".
Health Information means:
(a) information or an opinion about:
(i) the health or a disability (at any time) of an individual; or
(ii) an individual's expressed wishes about the future provision of health
services to him or her; or
(iii) a health service provided or to be provided to an individual; that is also
personal information; or
(b) other personal information collected to provide or in providing a health
service; or
(c) other personal information about an individual collected in connection with
the donation; or intended donation by the individual of his or her body parts or
body substances. Opt Out means an individual's expressed request not to receive
further Direct Marketing.
Personal Information means information or an opinion (including information or
an opinion forming part of a database), whether true or not and whether recorded
in a material form or not, about an individual whose identity is apparent, or
can reasonably be ascertained from the information or opinion.
Primary Purpose is the dominant or fundamental reason for information being
collected in a particular transaction.
Reasonable Expectation means a reasonable individual's expectation that their
personal information might be Used or Disclosed for the particular purpose.
Related Body Corporate means that where a body corporate is:
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a holding company of another body corporate;
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a subsidiary of another body corporate; or
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a subsidiary of a holding company of another body corporate,
the first mentioned body corporate and the other body corporate are deemed to
be related to each other.
Sensitive Information means:
(a) information or an opinion about an individual's:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual preferences or practices; or
(ix) criminal record;that is also personal information or
(b) Health Information about an individual.
Use means the handling of Personal Information within NORPRIM.
Contacting NORPRIM
If you require further information regarding NORPRIM' Privacy Policy, you can
contact NORPRIM Customer Service Centre on:
Telephone: 07 4623 1141
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