National Protective Services has adopted the National Privacy Principles contained in the Privacy Amendment (Private Sector) Act 2000, to govern the ways in which it collects, uses and disposes of personal information that comes into its possession.
Collection of Data
National Protective Services will only collect personal information that is needed for it to operate its business activities effectively. National Protective Services will always endeavor to obtain personal information directly from the individual concerned. When this is impracticable or not reasonable, it will collect personal information fairly and by lawful means and without being unreasonably intrusive. In collecting personal information the company will take reasonable steps to ensure the individual knows that it is National Protective Services that is collecting the information; why the information is being collected; who will receive the information in normal circumstances; any legal requirements governing the information; how the individual can access the information held on them by National Protective Services; and what the consequences would be if the individual did not provide the information sought.
Use and Disclosure
National Protective Services will only use or disclose personal information for the purpose(s) originally explained when the information was collected and for any related purpose that would reasonably be expected by both the individual concerned and National Protective Services. For example, National Protective Services would also use the name and address of a customer who requested the installation of a monitored alarm for invoicing purposes and to advise the person concerned of new or changed products and services available from National Protective Services.
If National Protective Services uses personal information it holds for direct marketing of its products or services, it will always provide the individual the opportunity at the point of first contact and at any time afterwards at the individuals request to decline receipt of any further marketing information. Otherwise, National Protective Services will neither use nor disclose personal information without the person’s consent, unless:
- Required for health or other emergency reasons
- To investigate suspected fraud or unlawful activity
- It is required or authorised by law
- It is required for law enforcement
National Protective Services will take reasonable steps to ensure that the personal information it uses is accurate, complete and up-to-date.
National Protective Services will take reasonable steps to protect all personal information in its possession, to ensure integrity of the information and that it is only accessed by those people whom National Protective Services authorises to do so. Personal information that is no longer needed by National Protective Services nor required to be held by law will be destroyed by secure means, or modified so that the data cannot be traced back to the person concerned.
National Protective Services will place this policy on its website and will have copies available in each of its major office locations to be provided to people on request.
Access and Correction
A person on whom National Protective Services holds personal information may apply in writing to:
Chief Executive Officer
National Protective Services Pty Ltd
P O BOX 453, South Melbourne VIC 3205
to view the personal information held on them. National Protective Services will take reasonable steps to confirm the identity of the person making the request and will respond within 14 days of receiving the request. However, where the request is more complex or time consuming to comply with, National Protective Services will provide access to the information requested within 28 days.
National Protective Services reserves the right to deny access to personal information if providing access:
- could pose a possible threat to life or health
- could cause an unreasonable impact on the privacy of others
- would be in response to a frivolous or vexatious request
- relates to existing or anticipated legal proceedings which could be prejudiced as a result
- relates to existing or anticipated commercial negotiations involving National Protective Services, and National Protective Services’ legitimate commercial interests could be prejudiced as a result is in any way unlawful
- could in any way prejudice law enforcement or security
- could prejudice the prevention, detection or investigation of seriously improper conduct, either within or external to National Protective Services’ operations.
Should giving access to personal information involve revealing evaluative information generated within National Protective Services in connection with a commercially sensitive decision making process, National Protective Services reserves the right to give the individual an explanation for the decision made rather than direct access to the relevant information.
Where there is disagreement about direct access or where direct access to personal information is impractical or inappropriate, National Protective Services will discuss the possible use of a mutually acceptable intermediary.
If an individual advises National Protective Services that personal information held on them is inaccurate, incomplete or not up to date, National Protective Services will take reasonable steps to update the information accordingly. Should there be a disagreement between National Protective Services and the individual about whether the personal information is complete or up-to-date and the individual requests, National Protective Services will take reasonable steps to associate a statement from the individual that the information is not correct with the relevant record(s) held by National Protective Services.
National Protective Services reserves the right to levy a reasonable charge to meet the costs of providing access to personal information, although there will be no charge for the act of making the request for access.
National Protective Services will always provide reason(s) should it deny access to or correction of personal information it holds.
National Protective Services will not use an identifier assigned to an individual by a Government Agency as its own identifier; nor will it provide such an identifier to a third party without the individuals consent, unless:
- disclosure is necessary for National Protective Services to fulfill its obligations to the Agency
- it is required for health or other emergency reasons
- it is required to investigate suspected fraud or unlawful activity
- it is required or authorised by law
- it is required for law enforcement
Where lawful and practical, National Protective Services will give individuals the option of not identifying themselves when dealing with the company.
Trans Border Data Flows
National Protective Services will not transfer personal information outside Australia without the consent of the individual unless: National Protective Services reasonably believes that the recipient of the information is subject to a law, binding scheme or contract providing substantially similar protection of personal information as provided for under Australia’s National Privacy Principles. The transfer is necessary for the performance of a contract between National Protective Services and the individual, or for the implementation of pre-contractual measures taken in response to the individual’s request The transfer is necessary for the performance or conclusion of a contract between National Protective Services and a third party that is in the interests of the individual concerned The transfer is for the benefit of the individual; it is impractical to obtain the individual’s consent and, if it was, the individual would be likely to give it. National Protective Services has taken reasonable steps to satisfy itself that the recipient of the information will manage the information consistent with this policy.
National Protective Services will not, without the consent of the individual, collect information concerning that individual’s racial or ethnic origins; political opinions; membership of a political, professional or trade association or trade union; philosophical or religious beliefs or affiliations; sexual preferences or practices or health information unless:
- It is required by law
- It will prevent or lessen life or health threatening situations and it is not possible or practical to gain the individuals consent
- The collection is necessary in relation to a legal or equitable claim
People wishing to complain about any aspect of National Protective Services’ management of their personal information may either write to the:
1. Chief Executive Officer
National Protective Services Pty Ltd,
PO Box 453, South Melbourne VIC 3205
2. Contact us by email on firstname.lastname@example.org
To help National Protective Services complete a quick and effective investigation, this should include as much detail as the complainant has available that will help the Chief Executive Officer to identify to which part of the National Protective Services organisation their complaint relates.
The Managing Director will maintain a record of all complaints received, including:
- The name and contact details of the complainant
- The date the complaint was received
- The nature of the complaint and the National Protective Services business unit involved
- Details of the person(s) investigating the complaint
- The outcome of the investigations
- The dates and details of all contacts made with the complainant
These records will be held in a secure manner by the Chief Executive Officer, and will only be accessible to Senior Executives of National Protective Services Pty Ltd or of the subsidiary company or operating business unit to which the complaint relates. Otherwise, they will only be made available, if required or authorised by law or to assist with any investigations carried out by the office of the Federal Privacy Commissioner.
The Chief Executive Officer will also be responsible for investigating privacy complaints or operating business unit concerned. The latter will be responsible for advising the Chief Executive Officer of National Protective Services Pty Ltd of the progress of their investigations and for providing a final report to the complainant with a copy to the Chief Executive Officer.
All complaints will be acknowledged within seven working days and a full response given within 28 days. Where it is not possible to complete the investigation of a complaint within 28 days, the complainant will be contacted once twenty eight days have elapsed with an estimate of when the investigation will be completed.