Fourth Line Pty Ltd ACN 628 372 378 (we or us) are aware of the importance of protecting the privacy of individuals who come in contact with us.
We are committed to ensuring the privacy of the personal information we collect in the course of our business. We believe that respect for your privacy forms part of the ongoing trust we wish to develop with you.
We apply the 13 Australian Privacy Principles contained in the Privacy Act 1988 (Cth). The Australian Privacy Principles set out the way in which organisations can collect, use, keep secure and disclose personal information, including sensitive information. The Privacy Act also generally gives individuals the right to know what personal information an organisation holds about them and the right to correct that information if it is wrong. Further information on the Australian Privacy law is available from the Office of the Australian Information Commissioner (oaic.gov.au).
‘Personal information’ is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.
What kinds of personal information do we collect and hold?
The personal information we may collect and hold varies and is dependent on the nature of our dealings with you. The kinds of personal information we may collect and hold about you can include, but is not limited to
- residential address (and previous address if relevant)
- postal address
- telephone number
- mobile number
- email address
- employment details
- information about your use of our website, products or services
- transaction data such as purchases, purchase amount, date of purchase and payment method
- tracking data, such as time spent using our services, pages visited, language preferences and other anonymous tracking data
- financial information (including assets, liabilities, income and expenditure)
- banking and credit card details
- Australian Business Number
- trading name
- any user number or subscriber number that we assign to you
- any user credentials that we assign to you to use any service that we provide
- identifying information about any device that you use to access our website or the Fourth Line service, including internet protocol address, device type, operating system, internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the version of your services that you are using, and
- photographic or video surveillance footage.
- We may also collect anonymous device, usage and tracking data from you via cookies on devices that you use to access our website or our services.
- The above information is collected and recorded about individuals who interact with us such as:
- our customers, potential customers and their representatives
- our suppliers and their representatives
- contractors and their representatives providing goods and services to us
- our employees past and present, including job applicants, and
- any other person who comes into contact with us.
In the course of providing services to our customers, we may also collect the above information about our customers’ clients and other individuals with whom our customers have interacted.
In most cases, if we do not collect the information we require, then we may be unable to undertake certain activities, such as providing you, or the organisation with which you are connected, with the requested information, goods and/or services.
How do we collect personal information?
Generally, when providing goods and services to our customers or obtaining goods and services from our suppliers or contractors, we collect personal information directly from the individuals where it is reasonable and practical to do so.
We may collect personal information directly from you when you:
- provide information to us in any way (including in person, by facsimile, by email, by post, disclosing information over the phone (which may be recorded), by providing a business card or by completing a form on our website)
- visit premises from which we operate
- acquire goods from us or use our services
- visit our website
- request information about us, our products or our services
- provide feedback, or
- where we are required or authorised by law to do so.
We may also collect information about you from other sources such as:
- nominated representatives (e.g. accountant, power of attorney, brokers and other professional advisors)
- forms you have completed on any website operated by us
- cookies installed on devices that you use to access our website and/or the Fourth Line service
- third party suppliers who we have arranged to provide products or services to you
- credit reporting bodies
- publicly available sources of information, including third party suppliers who gather public profile information for our use
- our related companies
- lawyers, agents, investigators and insurers, and
- our customers who have supplied documents containing personal information about you to us.
We will only collect your personal information from third parties if it is unreasonable or impractical to collect the necessary information directly from you or if we are otherwise permitted to do so.
We may also collect anonymous information about any device that you use to access our website or the Fourth Line service, directly or via third party service providers (such as Google, LinkedIn etc) who provide analytical information to us.
How do we handle sensitive information?
The Privacy Act defines ‘sensitive information’ as information relating to a person’s racial or ethnic origin, political opinions, membership of a political association, religion, philosophical beliefs, trade union or other professional or trade association membership, sexual orientation or practices, criminal record, or health information, genetic information or biometric information about an individual.
Occasionally, it may be necessary for us to collect sensitive information about you. If you or third parties provide us with sensitive information, we will as a matter of policy only use and disclose the information for the purpose for which it was provided or another directly related purpose, unless you agree otherwise, or where required by law.
Where practical and reasonable, we will only collect sensitive information with your consent.
Why do we collect personal information?
We are committed to providing quality customer service to our clients and to operate our business within statutory requirements and comply with our legal obligations.
We collect and hold personal information in order to operate our business efficiently as well as to provide and market products and/or services for the benefit of our customers.
We collect, hold and use your personal information:
- to identify you, conduct appropriate checks and communicate with you
- to enable the us to provide goods and services (including the Fourth Line services) to our customers
- to assess any request you make for the supply of goods and services by establishing your financial position and credit status (if relevant)
- to arrange for goods and services to be supplied to you by third parties where appropriate
- to collect debts
- to manage, train and develop our employees and representatives
- to set up, administer and manage our products and services
- to maintain records for accounting and administration purposes
- to analyse customer needs and develop customer strategies
- to identify customer preferences and develop or products and services to satisfy customer preferences
- to help us to manage and enhance the goods and services we purchase from our suppliers
- to develop and inform you about the goods and services that we consider may be of interest, unless you advise us not to do so
- to protect you and us from fraud
- to assess whether to provide commercial credit to you or accept you as a guarantor of commercial credit provided by us
- for business support purposes including maintenance, backup and audit
- for statistical and research purposes
- to comply with our statutory and legal obligations, and
- to respond to any queries or complaints you may have.
When do we disclose your personal information?
We may disclose your personal information to our related entities, to other parties where it is necessary to enable us to provide a product or service, to other third parties or where otherwise permitted by law. We may disclose your personal information to such entities for the purposes set out above.
We may disclose your personal information to:
- other companies related to us
- nominated representatives and credit reporting bodies
- debt collectors
- other companies or individuals who assist us in providing products and services to customers
- service providers and advisors who provide services to us or perform functions on our behalf
- government and regulatory authorities and other organisations as required or authorised by law (such as the Police)
- financial institutions for payment processing, and• referees or guarantors whose details you have provided to us.
To manage and provide cost effective services, we may outsource various tasks to contracted service providers, including:
- information technology service providers, including our web hosting service providers and public profile information providers
- marketing and communications agencies
- call centres and call training centres
- mailing houses, freight and courier services• printers and distributors of direct marketing material, and
- external business advisors (such as auditors, lawyers and debt collectors).
In the case of contracted service providers, we may disclose personal information to the contracted service provider and the contracted service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services.
Organisations providing professional services to us are required to keep those dealings and any personal information provided by us confidential, unless they are required to disclose such information by a law or an order of a court or tribunal.
We may disclose your personal information to our third-party service providers for them to help us provide services to you. We will only disclose relevant information to third party service providers located overseas, in countries including the United States, Asia and Europe. All other kinds of personal information will not be disclosed to recipients who may access or store it overseas.
Job applicants and employees
The Privacy Act provides an exemption for employee records. That is information about an individual if that information directly relates to the act or practice of a current or former employment relationship between the employer and the individual. That exemption may apply in relation to the information held by us about our employees.
Any personal information provided to us in connection with job applications may be used to consider the applicant for current and future employment and may be disclosed to our third-party advisors to assist us in the selection and recruitment process.
How long do we keep personal information?
We will take reasonable steps to destroy or permanently de-identify personal information that is no longer needed for any purpose for which it may be used or disclosed under the Privacy Act.
Use of Commonwealth government identifiers
We will not use Commonwealth government identifiers as our own identifier of individuals. We will only use or disclose identifiers in the circumstances permitted by the Privacy Act.
Marketing and Customer Satisfaction Surveys
From time to time, we may survey our customers on a range of issues, including their satisfaction with the Fourth Line service and changes that they would like to see made to the Fourth Line service. These surveys help us to improve our products and services and tailor the way that we do business with you.
We may also use your personal information to send you information about our products and services, including special offers.
You consent to us using your personal information for contacting you to conduct surveys and sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of mail, email, SMS, telephone calls and facsimile. You can contact us using the contact details specified in Enquiries below if you do not want to be contacted for surveys and/or receive marketing information from us. If you opt out you will still receive technical and safety-related messages from us.
We will not send you any commercial electronic messages such as SMS or email unless this is permitted by the Spam Act 2003 (Cth) (for example, if we have your express or inferred consent to do so). Any commercial electronic message that we send will identify us as the sender and will include our contact details. If you do not wish to receive commercial electronic messages from us, please let us know (see Enquiries below)).
We will not call you on a number listed on the Do Not Call Register if this is prohibited under the Do Not Call Register Act 2006 (Cth) and related instruments (for example, if we do not have your express or inferred consent to do so). If you do not wish us to call you on a particular number, please let us know (see Enquiries below).
Ensuring personal information is up to date
We rely on the personal information we hold in conducting our business. We take reasonable steps to ensure that the personal information we hold is accurate, complete and up to date. You can help by letting us know about any changes to your personal information, such as your email address and telephone number.
How do we manage data security?
We hold personal information in paper form, in electronic form on computer systems, in audio recordings and in video recordings (e.g. security surveillance).
We take reasonable steps to protect the security of your personal information by ensuring that it is protected from misuse, loss or interference and from unauthorised access, modification or disclosure. We maintain strict standards and security procedures to prevent unauthorised access to information about you whether it is in an electronic or paper format, and to ensure the correct use of this information.
Steps taken to protect personal information include:
- external and internal premises security
- restricted access to staff who need the personal information to perform their day-to-day functions
- conducting training to ensure that staff are aware that they must only access, use and disclose personal information for appropriate purposes, and
- maintaining technology products to prevent unauthorised computer access, including identifiers and passwords, security software, and firewalls.
You can access and seek correction of your personal information
Under the Privacy Act, you are entitled to access the personal information that we hold about you (in a manner you request, if this is reasonable and practicable). You can request access to such personal information by contacting us using the details below (see Enquiries).
If we cannot provide access to your information, we will generally provide you with the reasons why and the mechanisms available to complain about that refusal. Depending on the nature of the request, we may charge for providing access to this information, however such charge will not be excessive.
If the personal information we hold about you is inaccurate, incomplete, not up-to-date or irrelevant, you may request that we correct the information by contacting us via the methods set out below.
If the personal information we hold about you is not accurate, complete, up-to-date and relevant, we will take reasonable steps to correct the information so that it is accurate, complete, up-to-date and relevant. If we cannot take reasonable steps to correct the information because such correction is not technically possible or would be impracticable for us to perform, we may be unable to continue to provide services to you. In these cases, we will provide reasons for denial of your correction request.
If we refuse to correct your personal information you have the right to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will take such steps as are reasonable in the circumstances to associate that statement with all records containing the relevant information.
It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.
How to make a complaint and how we deal with complaints
It would assist us to respond to your complaint promptly if it is made in writing. Please include as much information as possible about your complaint and about the parties involved in the alleged breach.
If you feel that we have not satisfactorily addressed your complaint, you may also make a complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au or by writing to GPO Box 5218 Sydney NSW 2001.
Post: Fourth Line Pty Limited, Level 1, 1180 High Street, Armidale, VIC, 3143