RATIONALE:
This Privacy Policy sets out the principles undertaken by GP Network (The Company) in the management of personal information of individual customers. A copy of this Privacy Policy will be made available to anyone upon request.
The Company is committed to protecting the privacy of personal information of individual customers. The Company is bound by the Australian Privacy Principals set out in the Privacy Act 1988. We will only collect, use or disclose information in accordance with this Act and this Privacy Policy.
POLICY:
Comprehensive Collection and Disclosure Statement
The Company informs customers in disclaimer notices attached to all promotions that it collects customer data and that such data may be provided to third parties.
The customer is informed that if he/she does not wish their personal data (name/address) to be used or released to third parties, they should notify The Company who will then ensure that their personal data is used in the manner they indicate, unless otherwise required or permitted by law.
The Company conducts an “opt out” provision in its disclaimer, and individuals can opt out from receiving direct marketing communications from The Company at any time by contacting The Company via the details specified in the disclaimer and below.
Refer to the Collection and Disclosure Statement and the Standard Disclaimer Notice attached to all promotions.
Collection of Personal Information
Whenever it is reasonable and practicable to do so, The Company will only collect information about an individual directly from that individual.
The Company only collects personal information about an individual which is reasonably necessary to:
- Provide an individual with products or services;
- Consider applications and approaches made by an individual to The Company;
- Maintain an individual’s contact details;
- Fulfill The Company’s legal obligations under applicable laws and rules; and
- To conduct market research and sales and other marketing activities.
The personal information relating to an individual held by The Company pertains to the products and services offered by The Company or sought by an individual (e.g. Name, address, contact details (e.g. phone and email), credit card details, etc.).
The Company collects information from individuals via letter, fax, email, web sites, publicly available sources, rental or purchase of lists. The Company may have occasion to collect information about the customer from a third party, in accordance with and as allowed by the Privacy Act. For example:
- Market research companies contracted by us to improve our products and services;
- Trade directories and associations to ensure quality assurance; or
- List brokerage and list owners.
Where applicable, records of prospects who do not purchase within a certain timeframe (i.e. 3 months after mailing the prospect) will be deleted.
Promotional mailings sent by The Company include an option (i.e.opt-out box) in promotional disclaimers, for individuals that wish to be self-excluded. Individuals who inform The Company that they require exclusion from receiving mail, will be excluded and will be notified of compliance with their instruction. The same facility is available for internet customers.
Use and Disclosure
The Company will only use or disclose personal information for the purpose which was either specified or reasonably apparent at the time of collection. The Company may also use or disclose personal information for any other related purpose for which such information would reasonably be expected to be used, to the extent permitted by the Privacy Act.
Where and as permitted by the Privacy Act, The Company may also use your personal information to send marketing or promotional material to you and disclose it to other selected affiliated companies for this purpose, unless you indicate to us that you do not wish for this to occur.
The Company does not generally disclose personal information to third parties except, The Company may disclose personal information to other members of affiliated companies, which may only use it as described above, and The Company may also provide customer information to:
- Third parties, such as service providers, engaged by The Company to perform functions on behalf of The Company such as processing credit card information, mail debt collection, marketing, research, legal compliance and advertising;
- Carefully selected third parties that may wish to provide additional promotional material to our customers for their interest and convenience. Such transfers of information are usually conducted under a rental exchange agreement where the third party can only mail customers a limited amount of promotional material during a specific time period only; or
- Law enforcement agencies and governments worldwide for security purposes and regulatory compliance.
Security and Storage of Personal Information
The Company will take reasonable steps to protect personal information collected and ensure such information is accurate and complete. Information is held on secure servers or within controlled environments (e.g. in The Company’s offices, on hard drives or with selected third party service providers). Employees of The Company are required to maintain the confidentiality of any personal information held by The Company.
With regard to International Credit Card regulations, The Company is governed by the Payment Card Industry Data Security Standard which, amongst other things, requires The Company to have:
- A security incident response plan formally documented and disseminated to appropriate responsible parties;
- An incident response team ready to be deployed in case of a cardholder data compromise; and
- A periodic self-assessment process to undergo validation processes that must result in full compliance being granted for both validation processes, including an on-line questionnaire and port scanning review.
The Northern Territory Government also reviews and approves company security control systems.
Access, Correction and Accountability of Personal Information Retained
Individuals have the right to seek access to and correction of their personal information held by The Company and to advise us of any inaccuracy. There are exceptions to these rights as set out in the Privacy Act, and access may be denied if such an exception applies.
If an individual requests access or correction to information relating to the individual, the Company will ask the individual to verify their identity and specify the nature of their request. The Company may charge a fee to cover the costs of meeting the request, where permitted by the Privacy Act. Any request will be dealt with in a reasonable timeframe.
Information may be obtained or corrected by referring to company contact details on the relevant website or by e-mail to: cs@interprocesscentre.com
Accuracy of Personal Information
The Company takes reasonable measures to ensure all personal information is accurate, complete and up-to-date, when collected or used. If any information is incorrect, customers are encouraged to advise The Company by telephone or in writing.
Customer Service Consultants are trained to confirm and update where necessary, contact details of individuals.
Transfer of Personal Information Overseas
The Company may transfer personal details of customers overseas to fulfill the services requested of The Company, for example:
- To overseas offices of an affiliated company; or
- Internal or outsourced data processors, list brokers, marketing companies.
In the majority of cases the transfer of information is necessary for the fulfillment of company obligations. Unless otherwise advised, we will use reasonable steps to ensure that these overseas entities comply with the Australian Privacy Principles.
Concerns and Complaints
If an individual has a complaint about a breach of our Group Privacy Policy, the Privacy Act or any other applicable code, or requires further information about this subject, they can contact The Company:
Via e-mail: cs@interprocesscentre.com
In writing:
Customer Service Department – International Processing Centre
Reply Paid 36528,
Winnellie NT 0907,
Australia
The Company takes any such concerns seriously and will generally respond within 7 business days of receipt. If you are not satisfied with the Company’s response, you may contact the office of the Australian Information Commissioner to lodge a complaint at:
https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint
Or in writing at:
GPO Box 5218
Sydney NSW 2001
Changes to this Privacy Policy
The Company may, as necessary, review and update this Group Privacy Policy due to changes in law, technology or business operations. All personal information held by The Company will be governed by The Company’s Group Privacy Policy referred to in mail promotions.
Written copies of this Policy will be provided to individuals who contact The Company:
Via e-mail: cs@interprocesscentre.com
In writing:
Customer Service Department – International Processing Centre
Reply Paid 36528,
Winnellie NT 0907,
Australia