Simonds Group Limited (‘SGL’, ‘Group’, ‘Simonds’, ‘it’) is bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) (‘Privacy Act’) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012.
The purpose of this Policy is to describe how Simonds complies with the privacy requirements in protecting the personal information it holds about individuals. This Policy is applicable to Simonds Group Limited and its controlled entities.
Please read this Policy as it describes what happens to your Personal Information.
Personal Information is defined as information or an opinion (whether true or not) that can identify or can reasonably identify an individual.
Collection of Personal Information
The type of personal information that Simonds collects will depend upon what dealings the relevant individual may have with the Group. We may collect and hold personal information about individuals who:
- purchase, or express an interest to purchase, a Simonds home, for example, when entering into a sale and purchase agreement, or when responding to requests for information about a Simonds home;
- lease, or express an interest to lease, a display home, including any related guarantors for example, when negotiating, entering into or applying to enter into a lease with SGL;
- supply goods and services for example, when establishing records and systems to enable payment for goods and services;
- seek employment with SGL or are SGL employees for example, when conducting background checks for the purposes of employment;
- are security holders in SGL shares or who may wish to invest in SGL shares for example, requesting a prospectus to subscribe for Simonds that it may issue;
- enter a SGL office or gallery or building site for example, when maintaining visitor registrations for a Simonds display gallery, capturing video or images through surveillance systems in a SGL office or gallery;
- register or subscribe to join SGL marketing programs, newsletters or competitions;
- use SGL’s websites, social media and other online services;
- logon to wireless facilities provided in a Simonds office or gallery;
- may otherwise come into contact with SGL such as to resolve a complaint; or
- are provided loans or other financial accommodation by a Simonds preferred mortgage broker.
SGL only collects personal information which is reasonably necessary for its dealings with the relevant individual. The types of personal information may include, but is not limited to:
- information that identifies the individual for example, name, gender, address, contact details, date of birth, photographic or video images;
- information about the individual’s financial position and credit-worthiness;
- information about the individual that is required or authorised by law;
- the individual’s tax file number;
- the individual’s opinion about the Simond’s products, services or staff.
The Privacy Act imposes restrictions on collecting sensitive personal information such as information about religious views, ethnicity, political opinions and personal health. Simonds generally does not collect sensitive personal information about an individual. However, in certain circumstances, it may collect some sensitive information if it is necessary to allow it to deal with the individual and provided the individual has given consent for SGL to do so.
Whenever it is reasonable and practical to do so, Simonds only collects personal information directly from the individual. In some circumstances, personal information may be provided to Simonds by other parties such as the individual’s agent or Simond’s authorised agents and subcontractors. Simonds will take reasonable steps to inform the individual that it has the individual’s personal information, unless it is obvious from the circumstances.
Notification of Collection of Personal Information
Use and Disclosure of Personal Information
Simonds operates a number of businesses which handle personal information. Simonds 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. Simonds 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 Simonds wishes to use or disclose the personal information in other circumstances, it needs to obtain the individual’s consent to do so.
In general, Simonds uses personal information for the following purposes:
- providing goods or services that have been requested;
- communicating with the individual;
- helping Simonds manage and enhance its goods and services, including analysing customer feedback and future customer needs;
- providing ongoing information and marketing about goods and services to individuals that Simonds believes the individual may be interested in receiving and where the individual has signed up;
- managing security and safety requirements in Simonds offices, galleries and building sites;
- complying with regulatory and legal obligations;
- recruiting employees and contractors; or
- fulfilling its obligations to employees.
Disclosing Personal Information to Other Parties
Simonds may disclose personal information to other entities within the Simonds Group.
External parties may be given access to personal information held by Simonds in certain circumstances. These include, but are not limited to:
- Simonds contractors and service providers who assist in the operation of its business or who provide a customer service for example, a company which helps maintain Simonds computer systems or sends out Simonds mail;
- third party lenders and insurers;
- the Australian Securities Exchange (ASX), the Australian Securities and Investments Commission (ASIC) 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 Simonds is required by law to provide the information.
From time to time, Simonds may disclose personal information to external parties located outside Australia to allow the external parties to perform their services for Simonds or a Simonds controlled entity. This is currently restricted to organisations located in China and Vietnam. Simonds will only disclose personal information overseas when it is necessary for the services provided by these external parties and when it is in accordance with the Australian Privacy Principles. This includes taking reasonable steps to ensure that the external party has appropriate data handling arrangements in place.
Simonds does not sell personal information to entities outside the Simonds Group.
Simonds may send marketing materials to its customers or potential customers where it has collected the personal information from the individual and the individual would reasonably expect Simonds to use the information for that purpose.
The individual’s prior consent will be obtained before personal information is used for marketing purposes in situations where the personal information has been collected from the individual and the individual would not reasonably expect Simonds to use the information for that purpose, or the personal information has not been collected directly from the individual or where sensitive information is involved.
If the customer no longer wishes Simonds to use his or her personal information in order to provide marketing materials, the customer is to advise Simonds via the relevant method provided for in the electronic marketing message sent to the customer or to write to Simonds Privacy Officer (refer to contact details below). Simonds will act and amend its records promptly.
Applying for Employment with Simonds
Simonds collects personal information from individuals who submit applications or register an interest for employment with it or any of its controlled entities. If the application is unsuccessful, Simonds may retain the information in case a more appropriate opportunity becomes available. The unsuccessful applicant will be advised that they can contact Simonds to request it not to retain the applicant’s information.
Security of Personal Information
Simonds will take reasonable steps to protect personal information that it holds from unauthorised access; modification or disclosure, misuse, interference and loss. Simonds maintains physical security measures over its physical premises, and a range of computer and network security measures (such as systems access, firewalls, data encryption) over its electronic systems. Simonds employees are required to maintain the confidentiality of any personal information held.
If other parties provide support services, Simonds requires them to agree to appropriately protect the privacy of the information provided to them.
Access to Personal Information
Any individual can request access to the personal information Simonds may hold about them. To obtain access to the information, the individual should write to Simonds Privacy Officer (refer to contact details below). Simonds must be satisfied that any request for personal information is made by the individual concerned and 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, Simonds may seek to recover reasonable costs incurred for providing any of the personal information held about an individual. Simonds will provide an estimate of how much this service will cost and will request agreement to these costs before proceeding.
In normal circumstances, Simonds will provide the individual with access to the individual’s personal information, however, in some circumstances, there may be legal, regulatory or administrative reasons to deny the requested access. If access is denied, Simonds will provide the individual with the reasons for doing so.
Changing Personal Information
If an individual wishes to change personal information that the individual believes may be inaccurate, out-of-date, incomplete, irrelevant or misleading, the individual may write to the Privacy Officer requesting the information to be changed.
If Simonds disagrees with the individual that the personal information should be changed, it will provide the individual with the reasons for doing so. The individual has the right to request that a notation be included with their personal information to indicate their disagreement with their personal information held by Simonds.
Collection of Other Information
Simonds may also collect the following information about you:
When customers register to use Wi-Fi services provided by Simonds, Simonds collects their personal information in relation to their use of the Wi-Fi services, and for any other purposes they have consented to.
Changes in the Future
Simonds reserves the right to change this Policy at any time. Simonds will notify any changes to this Policy by posting an updated version of the Policy on its websites at http://www.simondsgroup.com.au or http://www.simonds.com.au
Simonds Privacy Officer can be contacted as follows:-
The Privacy Officer Simonds Group Limited Locked Bag 4002 South Melbourne Victoria 3205 Email: email@example.com
Tel: 1300 SIMONDS / 1300746 663
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.