From 12 March 2014, the Australian Privacy Principles (APP’s) replaced the National Privacy Principles and Information Privacy Principles and were inserted into the Privacy Act 1988 (“the Act”) at schedule 1. These principles apply to private sector organisations who deal with information relating to individuals. This legislation is designed to protect personal information about individuals and sets in place a framework and guidelines about how to deal with this information. APP 1.3 requires an APP entity to have a clearly expressed and up-to-date APP privacy policy describing how it manages personal information. Further in February 2018, the Notifiable Data Breaches (“NDB”) Scheme was introduced under Part IIIC of the Act. The NDB establishes requirements and compliance mechanisms for entities in responding to data breaches.
As at 25 May 2018, the EU General Data Protection Regulation (“GDPR”) was introduced providing increased transparency for data protection for all businesses transferring data to the Europe Union. While the GDPR and the APP share some similarities, Inarc Interior Design Pty Ltd is providing robust privacy policies and procedures for its staff and clients. This includes ensuring that it conforms to all required APP’s including the provision of a clearly expressed and readily available Privacy Policy. This is completed by the provision of this Privacy Policy.
An APP privacy policy is a key tool for meeting APP 1’s requirements.
To assist with this compliance, Inarc Interior Design Pty Ltd ensures that all of its staff members adhere to these policies and procedures. Any breaches of these policies and procedures must be reported to the relevant staff member’s manager or supervisor immediately so that any appropriate measures can be taken to mitigate any issues surrounding an identified breach.
Every staff member of Inarc Interior Design Pty Ltd who handles personal information is required to have an understanding of the Australian Privacy Principles (APP’s), the Act and the GDPR, where necessary. Where a more detailed knowledge of Inarc Interior Design Pty Ltd’s rights and responsibilities is required, the Privacy Officer will be able to provide assistance.
All staff are encouraged to discuss privacy issues with the nominated Privacy Officer.
Review
Formal review of this privacy policy shall be undertaken on a 6 monthly basis with the details of this review recorded by the Privacy Officer.
Upon the implementation of the GDPR on 25 May 2018, Inarc Interior Design Pty Ltd has updated the way they use and collect personal data from residents in the EU. This involves, identifying Inarc Interior Design Pty Ltd’s data protection officer (“Privacy Officer”), how clients can contact the Privacy Officer and identifying the process of transferring client’s personal information. Further, the implementation of cookies notices on Inarc Interior Design Pty Ltd’s website has been activated to ensure Inarc Interior Design Pty Ltd’s clients have adequate protection in providing consent to Inarc Interior Design Pty Ltd in withholding their personal data.
Inarc Interior Design Pty Ltd collects personal information for a variety of reasons. This personal information will be collected in the normal course of business and will relate to Goods and/or Services that are provided by Inarc Interior Design Pty Ltd to clients. This information collected will be done so in the course of business where the client is a customer of Inarc Interior Design Pty Ltd or when the client acts as a guarantor for another person or company that is a client of Inarc Interior Design Pty Ltd. Inarc Interior Design Pty Ltd will not collect information that is not relevant or sensitive in nature unless it is required in the normal course of business.
The personal information that is collected may include, but will not be limited to the following;
1/ Full name
2/ Address
3/ Date of birth
4/ Credit references if applicable
5/ Publicly available information which relate to the clients activities in Australia
6/ Any information recorded in the National Personal Insolvency Index
7/ Driver’s licence details
8/ Medical insurance details (if applicable)
9/ Electronic contact details including email, Facebook and Twitter details
10/ Next of kin and other contact information where applicable
The client acknowledges that provided the correct Privacy Act disclosures have been made that Inarc Interior Design Pty Ltd may conduct a credit report on the client for the purposes of evaluating the credit worthiness of the client.
Inarc Interior Design Pty Ltd ensures that all personal information is held in a secure manner. Where applicable and to the best of Inarc Interior Design Pty Ltd’s knowledge all computers or servers have the required security protections in place to safeguard and protect any personal information that is held by Inarc Interior Design Pty Ltd.
We use cookies on our website. Cookies are small files which are stored on your computer. They are designed to hold a modest amount of data (including personal information) specific to a particular client and website and can be accessed either by the web server or the client’s computer. In so far as those cookies are not strictly necessary for the provision of Inarc Interior Design Pty Ltd’s services, we will ask you to consent to our use of cookies when you first visit our website.
In the event that you utilise our website for the purpose of purchases/orders, Inarc Interior Design Pty Ltd agrees to display reference to cookies and /or similar tracking technologies, such as pixels and web beacons (if applicable), and requests consent for Inarc Interior Design Pty Ltd collecting your personal information which may include:
If you consent to Inarc Interior Design Pty Ltd’s use of cookies on our website and later wish to withdraw your consent, you may manage and control Inarc Interior Design Pty Ltd’s privacy controls through your browser, including removing cookies by deleting them from your browser history when you leave the site.
Inarc Interior Design Pty Ltd also regularly conducts internal risk management reviews to ensure that its infrastructure (to the best of its knowledge) is secure, and any identifiable risks have been mitigated as much as they can be in the normal course of business.
In accordance with the NDB Inarc Interior Design Pty Ltd is aware of its responsibilities to notify its clients in the event of a potential data breach that may cause serious harm to clients. Further, in the event the client is located in the Europe Union (“EU”), Inarc Interior Design Pty Ltd acknowledges that any potential data breaches will be safeguarded by the provisions of the GDPR.
Inarc Interior Design Pty Ltd will collect and process personal information in the normal course of business. This personal information may be collected and processed, but is not limited to, any of the following methods;
1/ Credit applications forms
2/ Work authorisation forms, quote forms or any other business documentation
3/ Publicly available databases that hold information
4/ Websites that detail information such as Sensis, Facebook, Google etc
5/ By verbally asking you for information as part of normal business practices
Where relevant to data processing as per the GDPR, and in particular where Inarc Interior Design Pty Ltd uses new technologies, and takes into account the nature, scope, context and purposes of processing and considers that the data processing is likely to result in a high risk to the rights and freedoms of natural persons, the Privacy Officer shall, prior to the processing of personal information, carry out an assessment of impact of the envisaged processing operations by way of a protection impact assessment. The data protection assessment will be required in instances whereby:
The assessment shall be carried out in accordance with Article 35 (7) of the GDPR and carry out reviews of such data protection impact assessments when there is any change of the risk associated with the processing of personal information.
As a client of Inarc Interior Design Pty Ltd and agreeing to Inarc Interior Design Pty Ltd’s Terms and Conditions of Trade, which includes Inarc Interior Design Pty Ltd’s privacy statement you hereby agree and consent to the provisions of this Privacy Policy, including but not limited to the collection, processing, use and disclosure of your personal information. In the event that you withdraw your agreement and consent to any of the above use, processing collection and disclosure, then Inarc Interior Design Pty Ltd warrants that any request by you to withdraw your consent or agreement shall be deemed as confirmation by you to cease any and/or all collection use, processing and disclosure of your personal information. You may make a request to withdraw your consent at anytime by telephone and/or by email to the following contact details;
The Privacy Officer
Inarc Interior Design Pty Ltd
Adelaide, South Australia
Inarc Interior Design Pty Ltd will ensure that any Information that is to be obtained from you is done so verbally or using Inarc Interior Design Pty Ltd’s prescribed forms which;
Authorise Inarc Interior Design Pty Ltd:
It is the responsibility of Inarc Interior Design Pty Ltd to ensure that any personal information obtained is as accurate and up to date as possible and information is only collected by lawful means in accordance with the Act and relevantly, in accordance with the GDPR.
Disclosure to Third Parties
Inarc Interior Design Pty Ltd will not pass on your personal information to third parties without first obtaining your consent.
In accordance with the Act, including the GDPR (where relevant), Personal Information can only be used by Inarc Interior Design Pty Ltd for the following purposes:
1/ Access a credit reporter’s database for the following purposes:
2/ Check trade references noted on the prescribed form for the following purposes:
3/ Market Inarc Interior Design Pty Ltd’s products and services.
4/ Any other day to day business purposes such as complying with ATO requirements, managing accounting returns or legal matters.
Relationship with Credit Reporter – In the event that notification of a default has been reported to a Credit Reporter and your credit file has been updated (including any changes to the balance outstanding or contact details), then the Credit Reporter shall be notified as soon as practical of any such changes.
Inarc Interior Design Pty Ltd will only gather information for its particular purpose (primary purpose). In accordance with the Act, including the GDPR (where relevant), Inarc Interior Design Pty Ltd will not disclose this information for any other purpose unless this has been agreed to by both parties.
You shall have the right to request from Inarc Interior Design Pty Ltd a copy of all the information about you that is retained by Inarc Interior Design Pty Ltd. You also have the right to request (by telephone and/or by email) that Inarc Interior Design Pty Ltd correct any information that is incorrect, outdated or inaccurate.
Any requests to receive your personal information or to correct personal information should be directed to the following contact details;
The Privacy Officer
Inarc Interior Design Pty Ltd
Adelaide, South Australia
Inarc Interior Design Pty Ltd will destroy personal information upon your request (by telephone and/or by email) or when the personal information is no longer required. The exception to this is if the personal information is required in order for Inarc Interior Design Pty Ltd to fulfil their performance of services or is required to be maintained and/or stored in accordance with the law.