Purpose
To define how Willow Ware Australia Pty Ltd will collect, use, keep secure and disclose personal information in accordance with the Privacy Amendment (Private Sector) Act 2000, Privacy Act 1988 and related National Privacy Principles (NPP).

Willow Ware Australia Pty Ltd is bound under the new private sector provisions that came into effect 21 December 2001.

Policy
Collection
Willow will not collect personal information unless the information is necessary for one or more of its business functions or activities. Where personal information is required, in the first instance it should be collected from that individual, where it is reasonable and practicable to do so. If this is not possible, it will be collected only by lawful and fair means and not in an unreasonably intrusive way.

Use and Disclosure
Willow will not disclose personal information about an individual for a purpose other than the primary purpose of collection unless:

  • the individual has consented to the use and disclosure;
  • the secondary purpose is related to the primary purpose;
  • the information is health related and the disclosure is necessary for public health and safety;
  • Willow suspects that unlawful activity has been, is being or may occur; and
  • the disclosure is required by law.

If Willow is required to disclose personal information on any of the above grounds, a written note of the disclosure must be made.

Willow must take reasonable steps to ensure that the personal information it collects, uses or discloses is accurate, complete and up-to-date.

Security
Willow will take reasonable steps to protect the personal information it holds from misuse, loss and unauthorized access, modification or disclosure. Reasonable steps will be undertaken to destroy or permanently de-identify personal information if it is no longer needed.

Access
Where Willow holds information about an individual, it will provide the individual with access to the information on request provided that:

  • it does not pose a serious an imminent threat to the life or health of any individual;
  • providing access would not have an unreasonable impact upon the privacy of other individuals;
  • the request is not for frivolous or vexatious intent;
  • the information does not relate to existing or anticipated legal proceedings between the individual and Willow that could be accessible by the process of discovery in those proceedings;
  • negotiations would not be prejudiced (between the individual and Willow); and
  • providing access would not be unlawful.

If any of the above issues are potential outcomes, consideration should be given to (if reasonable), the use of mutually agreed intermediaries to allow sufficient access to meet the needs of both parties.

RECORDS

  • AS3806-1998 Implementation of a Privacy Compliance Program;
  • Privacy Amendment (Private Sector) Act 2000, Privacy Act 1988;
  • National Privacy Principles;
  • Employee Records – Confidentiality of;
  • Willow Credit Card Policy;
  • Willow Customer Accounts Policy;
  • Willow Document Management Procedure;
  • Willow Drugs & Alcohol Policy;
  • Willow Employee Records Policy;
  • Willow IT Security Policy;
  • Willow Records Management Procedure;
  • Willow Sales & Customer Service Policy;

 


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