Privacy Policy
Privacy Policy
This Privacy Policy sets out the approach which Greg Johnston Insurance Services will take in relation to the treatment of Personal Information. It includes information on how Greg Johnston Insurance Services collects, uses, discloses and keeps secure, individuals' Personal Information. It also covers how Greg Johnston Insurance Services makes the Personal Information it holds available for access to and correction by the individual.
This policy has been drafted having regard to Greg Johnston Insurance Services's obligations under the Privacy Act
1988 (including the new National Privacy Principles)
(the Privacy Act). This Policy is a public document and has
been prepared in light of National Privacy Principle 5,
Openness.
1. COLLECTION
1.1 Greg Johnston Insurance Services will only collect Personal
Information where the information is necessary for
Greg Johnston Insurance Services to perform one or more of its
functions or activities. In this context, "collect" means
gather, acquire or obtain by any means, information in
circumstances where the individual is identifiable or
identified.
1.2 Greg Johnston Insurance Services collects Personal Information
primarily to supply customers with the products and
services ordered from it and its related companies.
Greg Johnston Insurance Services also collects and uses Personal
Information for secondary purposes including:
i. billing and account management
ii. business planning and product development; and
iii. to provide individuals with information about
promotions, as well as the products and services of
Greg Johnston Insurance Services affiliated companies and other
organisations.
iv. to enhance the online shopping experience by
displaying products and/or services that match the personal
preferences of individuals based on their previous website
browsing history and/or buying activity.
1.3 Greg Johnston Insurance Services will not collect Sensitive
Information from individuals except with consent and only
where it is necessary for Greg Johnston Insurance Services to
collect such information for an activity or function.
1.4 Greg Johnston Insurance Services will not collect Personal
Information secretly or in an underhanded way.
1.5 Greg Johnston Insurance Services will take steps to ensure that
individuals on purchased lists are or have been notified of
the information as outlined at 1.3.
2. USE
2.1 Greg Johnston Insurance Services will obtain an individual's
consent for Use of non-sensitive Personal Information for
Secondary Purposes at the time of collection, unless the
Use is a related Secondary Purpose which would be within
the relevant individual's Reasonable Expectations.
2.2 Greg Johnston Insurance Services Uses Personal Information
primarily for the purposes listed in 1.2 above.
2.3 If Greg Johnston Insurance Services relies on the Direct
Marketing exception to Direct Market to individuals it will
ensure that:
i. the individual is clearly notified of their right to
Opt Out from further Direct Marketing;
ii. there is only one Use of the information before the
Opt Out right is given and this Use applies across all
Greg Johnston Insurance Services’ Related Bodies Corporate (if
the information is shared between those Related Bodies
Corporate);
iii. the individual is given an Opt Out in all further
instances of Direct Marketing if they have not previously
chosen to Opt Out; and
iv. if the individual Opts Out of all Direct Marketing the
Opt Out will be respected by Greg Johnston Insurance Services and
all its Related Bodies Corporate.
2.4 Greg Johnston Insurance Services will not use Sensitive
Information for Direct Marketing.
2.5 Greg Johnston Insurance Services may use Personal Information
to avoid an imminent threat to a person's life or to public
safety. It may also use Personal Information for reasons
related to law enforcement or internal investigations into
unlawful activities.
2.6 R Greg Johnston Insurance Services will not use Personal
Information without taking reasonable steps to ensure that
the information is accurate, complete and up to date.
3. DISCLOSURE
3.1 Greg Johnston Insurance Services may Disclose Personal
Information to related or unrelated third parties if
consent has been obtained from the individual. This will
include obtaining the individual's consent for Disclosures
made under the credit reporting requirements of the Privacy
Act.
3.2 Greg Johnston Insurance Services may Disclose Personal
Information between Related Bodies Corporate. Where
information is Disclosed to such a Related Body Corporate,
that Related Body Corporate is bound by the original
Primary Purpose for which the information was
collected.
3.3 Greg Johnston Insurance Services may Disclose Personal
Information to unrelated third parties to enable
outsourcing of functions (such as billing, customer
relations management and order fulfilment), where that is
Disclosure or Use for a related Secondary Purpose and has
been notified to individuals or where such Disclosure is
within the individual's Reasonable Expectations.
3.4 Greg Johnston Insurance Services will take reasonable steps to
ensure that its contracts with third parties include
requirements for third parties to comply with the Use and
Disclosure requirements of the Privacy Act.
3.5 Greg Johnston Insurance Services may Disclose Personal
Information to law enforcement agencies, government
agencies, courts or external advisers where permitted or
required by law.
3.6 Greg Johnston Insurance Services may Disclose Personal
Information to avoid an imminent threat to a person's life
or to public safety.
3.7 If a Disclosure is not for a Primary Purpose; is not
for a related Secondary Purpose; or upfront consent has not
been obtained, Greg Johnston Insurance Services will not Disclose
Personal Information otherwise than in accordance with the
exceptions set out at 3.1 to 3.6 above.
3.8 Greg Johnston Insurance Services does not generally sell or
share its customer lists on a commercial basis with third
parties but if it did, it would only do so if we had the
appropriate consent of the individual involved. If the
consent provided is conditional, Greg Johnston Insurance Services
will take steps to ensure (by contract) that the use of its
customer list by third parties does not exceed the scope of
the consent.
4. INFORMATION QUALITY
4.1 Greg Johnston Insurance Services will review, on a regular and
ongoing basis, its collection and storage practices to
ascertain how improvements to accuracy can be
achieved.
4.2 Greg Johnston Insurance Services will take steps to destroy or
de-identify Personal Information after as short a time as
possible and after a maximum of seven years from the date
of the last customer interaction, unless the law requires
otherwise.
5. INFORMATION SECURITY
5.1 Greg Johnston Insurance Services requires employees and
contractors to perform their duties in a manner that is
consistent with Greg Johnston Insurance Services ' legal
responsibilities in relation to privacy.
5.2 Greg Johnston Insurance Services will take all reasonable steps
to ensure that paper and electronic records containing
Personal Information are stored in facilities that are only
accessible by people within Greg Johnston Insurance Services who
have a genuine "need to know" as well as "right to know".
5.3 Greg Johnston Insurance Services will review, on a regular and
ongoing basis, its information security practices to
ascertain how ongoing responsibilities can be achieved and
maintained.
6. ACCESS AND CORRECTION
6.1 Greg Johnston Insurance Services will allow its records
containing Personal Information to be accessed by the
individual concerned in accordance with the Privacy
Act.
6.2 Greg Johnston Insurance Services will correct its records
containing Personal Information as soon as practically
possible, at the request of the individual concerned in
accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access
and/or correct their Personal Information should do so by
contacting Greg Johnston Insurance Services Customer Service, as per
the details on the website.
6.4 R Greg Johnston Insurance Services can charge a fee for
processing an access request but will generally not do so
unless the request is complex or is resource
intensive.
7. OPENNESS
7.1 Greg Johnston Insurance Services Customer Service
representatives will be the first point of contact for
inquiries about privacy issues. Individuals wishing to make
an inquiry or complaint regarding privacy, should do so by
contacting Greg Johnston Insurance Services Customer Service, as per
the details on the Greg Johnston Insurance Services website.
7.2 Greg Johnston Insurance Services websites will contain a
prominently displayed privacy statement and will include a
copy of Greg Johnston Insurance Services Privacy Policy.
8. ANONYMOUS TRANSACTIONS
8.1 Greg Johnston Insurance Services will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. Greg Johnston Insurance Services may however request visitors to provide Personal Information voluntarily to Greg Johnston Insurance Services (for example, as part of a competition or questionnaire).
9. GLOSSARY
Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.
Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of Greg Johnston Insurance Services or a Related Body Corporate or those of an independent third party organisation.
Disclosure generally means the release of information outside Greg Johnston Insurance Services, including under a contract to carry out an "outsourced function".
Opt Out means an individual's expressed request not to receive further Direct Marketing.
Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.
Reasonable Expectation means a reasonable individual's expectation that their personal information might be Used or Disclosed for the particular purpose.
Related Body Corporate means that where a body corporate is:
- a holding company of another body corporate;
- a subsidiary of another body corporate; or
- a subsidiary of a holding company of another body corporate, the first mentioned body corporate and the other body corporate are deemed to be related to each other.
Sensitive Information means:
a. information or an opinion about an individual's:
i. racial or ethnic origin; or
ii. political opinions; or
iii. membership of a political association; or
iv. religious beliefs or affiliations; or
v. philosophical beliefs; or
vi. membership of a professional or trade association;
or
vii. membership of a trade union; or
viii. sexual preferences or practices; or
ix. criminal record;
b. Health Information about an individual.
Use means the handling of Personal Information within
Greg Johnston Insurance Services.
Contacting Greg Johnston Insurance Services
If you require further information regarding Greg Johnston Insurance Services's Privacy Policy, you can contact Greg Johnston Insurance Services.
