The Applied Property Development Institute (ADPI) is subject to the Australian Privacy Principles contained in the Privacy Act 1988 and the Privacy Amendment (Enhancing Privacy Protection) Act 2012.
The purpose of this Policy is to describe how the ADPI complies with the privacy requirements in protecting the personal information the APDI holds about individuals. This Policy is applicable to Applied Property Development Institute Pty Ltd and its controlled entities (collectively referred to as “APDI” below).
2. Personal Information
Personal Information is defined as information or an opinion that can identify or can reasonably identify an individual.
3. Collection of Personal Information
The type of personal information that the APDI collects will depend upon what dealings the relevant individual may have with the APDI. The APDI may collect and hold information about:
- Purchases or potential purchases (for example when enrolling in a unit or responding to requests for information about the APDI);
- Suppliers (for example, when establishing records and systems to enable payment for goods);
- Job applicants (for the purposes of employment);
- Other individuals who may come into contact with the APDI
The APDI only collects personal information which is reasonably necessary for its dealings with the relevant individual. The types of personal information may include, but are not limited to:
- Information that identifies the individual (for example, name, address, contact details, date of birth);
- Information about the individual that is required or authorised by law;
- The individual’s opinion about the APDI’s products, services or staff.
The Privacy Act imposes restrictions on collecting sensitive personal information (this includes information about religious views, ethnicity, political opinions, and personal health information). The APDI generally does not collect sensitive personal information about an individual. However, in certain circumstances, the APDI may collect some sensitive information if it is necessary to allow the APDI to deal with the individual and the individual has provided consent for the APDI to do so.
Whenever it is reasonable and practical to do so, the APDI only collects personal information directly from the individual. In some circumstances, personal information may be provided to the APDI by other parties.
4. Use and Disclosure of Personal Information
The APDI operates a business which handles personal information. APDI’s policy is only to use personal information for the purpose which was either specified or reasonably apparent at the time when the information was collected. The APDI may also use or disclose the information collected for any other related purpose for which the individual would reasonably expect it to be used.
If the APDI wishes to use or disclose the personal information in other circumstances, it needs to obtain the individuals consent to do so.
In general, the APDI uses personal information for the following purposes:
- Providing products or services that have been requested;
- Communicating with the individual;
- Helping the APDI manage and enhance its products and services to individuals that the APDI believes may be interested;
- Complying with regulatory and legal obligations;
- Recruiting of employees and contractors;
5. Disclosing Information to Other Parties
External parties may be given access to personal information held by the APDI in certain circumstances. These include, but are not limited to:
- The APDI’s contractors and service providers who assist the APDI in the operation of its business or to provide a customer service (for example, a company which helps maintain the APDI’s computer systems or sends out the APDI’s mail);
- Third party lenders and insurers
- The Australian Securities Exchange, the Australian Securities and Investments Commission and to other government agencies as agreed to or required by law;
- Anyone authorised by a provider of personal information;
- Relevant parties in situations when the APDI is required by law to provide the information.
The APDI limits the information disclosed to external parties to what is required for them to perform their services for the APDI or the relevant individual, or what is required by law.
The APDI may sometimes disclose personal information overseas to allow external parties to perform their services for the APDI but the APDI will only do so in accordance with the Australian Privacy Principles.
The APDI may send marketing materials to its customers or potential customers where the APDI has collected the personal information from the individual and the material is related to the purpose for which the information was collected.
The individual’s prior consent will be obtained before personal information is used for marketing purposes in situations where the personal information has not been collected directly from the individual or where sensitive information is involved.
If the customer no longer wishes the APDI to use his or her personal information in order for the APDI to provide marketing materials, the customer is to advise the APDI via the relevant method provided for in the electronic marketing message sent to the customer. The APDI will act and amend its records promptly.
8. Security of Personal Information
The APDI will take reasonable steps to protect personal information that it holds from unauthorised access, modification, misuse, interference and loss. Personal information is held on secure severs or in storage located in controlled environments. The APDI employees are required to maintain the confidentiality of any personal information held.
If other parties provide support services, the APDI requires them to agree to appropriately protect the privacy of the information provided to them.
9. Notification of Collection of Personal Information
10. Access to Personal Information
Any individual can request access to the personal information the APDI may hold about them. To obtain access to the information, the individual needs to write to the APDI Privacy Officer (contact details below). The APDI will require evidence to verify the identity of the individual.
This service is free of charge unless the personal information requested requires preparation time. In this situation, the APDI will provide an estimate of how much this service will cost and request agreement before proceeding.
In normal circumstances, the APDI will provide the individual with access to the individual’s personal information. However, in some circumstances, there may be legal, regulatory or administrative reason to deny the requested access. If success is denied, the APDI will provide the individual with the reason.
11. Changing Personal Information
If an individual wishes to update personal information that the individual believe may be inaccurate, out-of-date, incomplete, irrelevant or misleading, the individual may write to the APDI Privacy Officer requesting the information to be updated or deleted.
12. Changes in the Future
An individual can make a complaint about the way in which the APDI has handled an individual’s personal information by writing to the APDI Privacy Officer. The APDI will endeavour to act promptly in response to a compliant.
14. Additional Information on Privacy
For further information about privacy issues and the protection of privacy, visit the Office of the Australian Information Commissioner’s website at http://www.oaic.gov.au
15. Contacting the APDI
The APDI Privacy Officer can be contacted as follows:
Phone: 1300 306 856
Applied Property Development Institute
Level 2 / 20 Collins Street
Melbourne VIC 3000