The last review of this policy was conducted in January 2020.
SCOPE OF POLICY
This policy applies to all employees of AVID Property Group Holdings Pty Ltd (AVID) and its subsidiaries (collectively, the “Group”) and applicants for positions at AVID.
In addition to our general personal information management practices, section 5 of this Policy covers the way in which an individual’s personal information is treated when they access and interact with the AVID website at www.avid.com.au.
Acts and practices of employers that are directly related to both employee records and an employment relationship are exempted from the Privacy Act and are not covered by this Policy.
COLLECTION OF PERSONAL INFORMATION
Personal information is information or an opinion that can identify an individual or from which the identity of the individual can be reasonably ascertained. Types of Personal Information include:
- Information that identifies the individual (for example, name, gender, address, contact details, date of birth, photographic or video images);
- Other personal information that is contained in communications between you and AVID;
- Information about the individual that is required or authorised by law; and
- The individual’s opinion about AVID.
When AVID provides you with services, we may need to collect certain information from you. The type of personal information which we collect will depend upon the dealings which you may have with AVID.
AVID may collect and hold personal information about individuals who:
- purchase, or express an interest to purchase, AVID Land or an AVID apartment (for example, when entering into a sale and purchase agreement, or when responding to requests for information about a AVID home or apartment);
- apply for open vacancies, or who fill in an expression of interest for a position at AVID – including collecting details of your employment history, and other information provided as part of AVID’s recruitment process;
- seek employment with AVID or are AVID employees (for example, when conducting background checks for the purposes of employment);
- register or subscribe to join AVID programs, newsletters or competitions;
- use AVID’s websites, social media and other online services;
- use mobile applications developed by AVID;
- may otherwise come into contact with AVID;
AVID only collects personal information which is reasonably necessary for its dealings with the relevant individual.
We collect personal information provided by you or your authorised intermediaries which is reasonably necessary to:
- provide you with quality products and services;
- do all things necessary to administer, manage, develop and protect those products and services;
- consider applications and approaches which you make to us;
- maintain your contact details; and
- consider you for employment opportunities with AVID.
Consequences if information not provided
When we ask you to provide us with personal information, if you do not provide us with that information or if that information is incomplete or inaccurate, it may:
- prevent us from providing our products and services to you;
- limit our ability to provide you with the level of service which you would normally expect from us;
- prevent us from being able to contact you.
We do not generally collect sensitive information about you. Sensitive information includes information or opinion relating to:
- racial or ethnic origin;
- political opinions;
- membership of a political association;
- religious beliefs or affiliations;
- philosophical beliefs;
- sexual preferences or practices;
- criminal convictions;
- membership of a professional or trade association; or
- health information.
If we do collect sensitive information about an individual, we will only do so with the consent of that individual or otherwise in accordance with the law.
Indirect collection of information
We generally try to collect personal information directly from you or through your authorised intermediaries.
USE AND DISCLOSURE OF PERSONAL INFORMATION
Personal information which is collected by AVID is generally only used and disclosed for:
- the main purpose for which the information was collected; or
- related purposes, which would be within your reasonable expectations.
We may otherwise use or disclose your personal information where the use or disclosure is required or authorised by law (for example, disclosure to government regulatory and law enforcement agencies) or in emergency situations.
If AVID wishes to use or disclose your personal information in other circumstances, we will seek your consent to do so.
Members of AVID may share an individual’s personal information with related entities. In this case, the information may only be used or disclosed by the related entity for the main purpose for which it was collected, for purposes related to the main purpose, where required or authorised by law, or for other purposes if the individual has consented.
AVID does not sell personal information to companies outside AVID.
The Spam Act 2003 (Cth) restricts the circumstances in which AVID can send you commercial electronic messages (including email and SMS text messages). AVID may send other advertising material to you where the advertising material is related to the purpose for which the personal information was collected. If you no longer wish to receive such promotional information from AVID, you may advise us in writing. Commercial electronic messages from AVID will include information about how to contact us and unsubscribe if required. AVID’s records would normally be amended within 30 days or as otherwise required by the Spam Act. Details of how to contact us are set out below.
SECURITY OF PERSONAL INFORMATION
- AVID will take reasonable steps to protect personal information that it holds from unauthorised access and disclosure, modification, misuse, interference and loss. AVID 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. AVID’s employees are required to maintain the confidentiality of any personal information held. This protection applies in relation to information stored in both electronic and hard copy form.
- AVID will destroy or permanently de-identify any personal information collected which is no longer required. External organisations which provide support services to AVID are also required to appropriately safeguard the security of the personal information which we provide to them.
- AVID has an ongoing obligation to take reasonable steps to handle personal information we hold about in accordance with the Notifiable Data Breach Regime within the Privacy Act 1988 (Cth) as amended. If there is a suspected or known data breach, AVID’s first step is to contain the breach were possible. This will require steps to immediately limit further access or distribution of the affected personal information. The steps to be taken are set out in the Data Breach Policy and Response Plan.
- AVID may use servers owned by a third-party hosting provider(s) and/or third party software. AVID requires its services providers to maintain appropriate organisational and technical measures to protect the security of your personal information. Unfortunately, despite all these measures, no data transmission over the internet or security procedures can be guaranteed to be 100% secure. AVID cannot guarantee the security of any information you transmit to us, and in providing it to us you do so at your own risk.
ACCESSING AND UPDATING PERSONAL INFORMATION
You may request access to your personal information or request us to correct information which we hold about you. To make a request, please put your request in writing using the contact details below. We may require proof of your identification before we can provide you with access to your personal information.
In normal circumstances we will give you full access to the personal information which we hold about you. However, in some circumstances, we may not be permitted by law to provide an individual with access to or to correct their personal information. If this is the case, you will be provided with the reason(s) for our decision.
We will normally provide access without charge unless you request access to a large volume of personal information or we have to access our archived records to obtain the information. In these circumstances, we may impose a fee to recover our reasonable costs.
This section outlines the way we handle personal information which we collect when an individual uses the AVID website or our project websites.
We outsource the development, maintenance and hosting of the website to third party service providers. We may disclose personal information about an individual to our third party service providers so that they can effectively provide these services.
1. Collection of personal information
An individual may visit the AVID websites without providing us with any personal information. However, we may collect personal information about an individual accessing the website if they use the ‘Contact us’ section of the website or where an individual applies for open vacancies or submits an expression of interest for a position at AVID.
A cookie is a small data file that contains information about your visit to a website. This information is provided by your computer during your first visit to a web server.
The server records this information in a text file and stores this file on your hard drive. When you visit the same website again, the server looks for the cookie and structures itself based on the information provided. Cookies are necessary to allow the AVID website and the user’s computer to interact effectively and enhance security. Cookies can record information about the user’s visit to assist AVID in better understanding the needs of the user. For example, user traffic data may be collected and used to infer the website user’s demographic using various web analytic technologies. AVID sometimes also use performance tracking technology (such as conversion tags) to help AVID to track user behaviour on its websites. Such user traffic and performance tracking data is non-personally identifying and is collected on an aggregate level to report statistics to assist AVID to improve the quality and relevancy of its service.
Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to warn you before accepting cookies. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie.
We may, from time to time, include links in the website to the websites of other organisations which may be of interest to you. We are not responsible for the privacy practices of these websites.
4. Website security
As with any internet transaction, the transmission of data over the internet is not completely secure. While we take reasonable steps to protect all the personal information in our possession that we have collected via the website in accordance with our general personal information management practices, we cannot guarantee the security of all data submitted to us over the internet.
AVID Property Group
Level 5, 7 Macquarie Pl
Sydney NSW 2000
Phone: (02) 8316 7700
You may also contact the Office of the Australian Information Commissioner as follows:
Phone 1300 363 992
Address GPO Box 5218 Sydney, NSW 2001
If you wish to make a privacy complaint, you may contact the Privacy Officer using the contact details above. You will need to provide us with sufficient details regarding your complaint, as well as any supporting evidence and/or information.
The Privacy Officer will investigate the issue and determine the steps we will undertake to resolve your complaint. We will contact you if we require any additional information and will notify you in writing of the determination of our Privacy Officer.
If you feel that we have not adequately dealt with your complaint, you may contact the Australian Privacy Commissioner via www.oaic.gov.au.
CHANGES TO THIS POLICY