PRIVACY POLICY

3 September 2014

The privacy of your personal information is afforded the highest level of importance by the Company. This policy outlines the way we manage personal information that we collect or that is provided to us. It applies to Character Roofing, Character Commercial, First Choice Verandahs and Carports, First Choice Solar, its Directors, Employees and Contractors (the Company, we, us). We are bound by the Privacy Act 1988 (Cth) regarding the manner in which we handle your personal information and how we respond to your requests to access and correct it. This document sets out our information handling procedures and the rights and obligations that both you and we have in relation to your personal information.

What kind of personal information does the Company collect and how does the Company collect it?

The Company generally collects and holds personal information about:

  • Our employees;
  • Contractors who provide services;
  • Our customers;
  • Our suppliers;
  • Our shareholders;
  • Job applicants and
  • Other people who may come into contact with the Company or one of the Company’s businesses.

The type of information we collect varies, depending on the purpose, and may include (but not limited to) your name, address, contact details, organisation, identification, positions held, payment details, credit information and marketing information.

This information may be obtained by way of forms filled out, information provided in person or by telephone, email or online by the individuals themselves, or from a public source or third party (for  example, referees, other companies, your organisation, your representatives and information service providers).

We only hold information about you if it is relevant to providing the services and products that we provide. If you are one of our suppliers, we may collect other information about you that we feel is necessary, such as the nature of the products or services that you supply, quotes that you provide and your direct credit details.

How we hold your information

Depending on the circumstances, we may hold your information in either hardcopy or electronic form, or both.

How do we use personal information and to whom may we disclose it?

In general the Company collects, uses and discloses personal information to:

  • Provide products or services that have been requested;
  • Maintain relationships with suppliers, contractors and other parties;
  • Communicate;
  • Verify your identity and personal information;
  • Maintain and update our records;
  • Provide products or services that have been requested;
  • Maintain relationships with suppliers, contractors and other parties;
  • Provide ongoing information and marketing communications about our products and services to our customers and prospective customers by telephone, email, online and other means as
    permitted by law, unless they opt out; and
  • Comply with legal obligations and protect our lawful interests.

We may not be able to do these things without your personal information. For example, we may not be able to respond to your enquiries or provide you a product or service you have requested.

We may also collect, use and disclose your personal information in connection with:

  • Reasonable information requests from courts, government agencies and lawyers
  • Suspected fraud, misconduct and unlawful activity, and
  • Acquisitions or potential acquisitions of our business.

Depending on the product or service concerned, personal information may be disclosed to:

  • Other divisions or organizations within the Company;
  • Service providers and specialist advisers to the Company who have been contracted to provide the Company with administrative, archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, debt collection, delivery, data processing, data analysis, information broking, research, investigation, website, technology or other services;
  • Insurers, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law;
  • Credit reporting or reference agencies or insurance investigators; or
  • a person authorised by an individual.
  • Generally, we require that organisations outside the Company who handle or obtain personal information as service providers to the Company acknowledge the confidentiality of this information and undertake to comply with the Principles.

How do we handle credit-related personal information?

In the course of our business, we handle personal information from credit reporting bodies (CRBs) and certain other Credit-Related Personal Information as described below (Credit-Related Personal Information) in the context of commercial credit and personal credit arrangements. For example, information about an individual’s consumer credit worthiness may be handled where we provide commercial credit accounts to sole traders, or individuals such as directors provide personal guarantees in relation to commercial credit accounts.

We may collect and hold the following types of Credit-Related Personal Information, both in relation to your arrangements with us and those with third parties such as other credit providers:

  • Name, sex, date of birth, driver’s licence number, employer and most recent addresses;
  • Confirmation of previous information requests about the individual to CRBs made by other providers and credit insurers;
  • Details of previous credit applications, including the amount and type of credit limit;
  • Details of current and previous credit arrangements, including credit providers, start/end dates and certain terms and conditions;
  • Permitted payment default information, including information about related payment arrangements and subsequent repayment;
  • Information about serious credit infringements (e.g. fraud);
  • Information about adverse court judgments and insolvency;
  • Publicly available information about the individual’s credit worthiness;
  • Any credit score or credit risk assessment indicating a CRB’s, credit provider’s or our analysis of the individual’s eligibility for consumer credit; and
  • Any other types of Credit-Related Personal Information about an individual permitted under the Privacy Act.

We may disclose Credit-Related Personal Information to CRBs to assist the CRBs to maintain information about you to provide to other credit providers for credit assessments. We may collect Credit-Related Personal Information from CRBs for purposes including, to the extent permitted by law, to assess your application for credit or to be a guarantor, manage your credit/guarantee, assign debts and collect overdue payments. We may also exchange Credit-Related Personal Information with debt buyers, credit insurers and other credit providers.

The CRBs we use may include:

  • NCI Commercial Collections, Po Box 3315, Rundle Mall SA 5000
  • Dun & Bradstreet, Level 7, 479 St Kilda Road Melbourne VIC 3004
  • Veda, Po Box 964, North Sydney NSW 2059

You have the right to request CRBs not to:

  • Use your Credit-Related Personal Information to determine your eligibility to receive direct marketing from credit providers; and
  • Use or disclose your Credit-Related Personal Information, if you have been or are likely to be a victim of fraud.

Please see other sections of this Privacy Policy for further details about how we collect and hold personal information, disclosures (including to other countries) of personal information, and access, correction and complaint rights and procedures. In some cases, we are subject to further obligations under the Privacy Act regarding Credit-Related Personal Information, and this Privacy Policy is not intended to limit or exclude those obligations. Additional privacy consents and notifications may also apply for our credit-related services.

How we secure your information

We hold all hardcopy and electronic records of personal information in a secure manner to ensure that they are protected from unauthorized access, modification or disclosure. Our staff follow strict information handling procedures and we only permit those staff whose tasks require use of your information to access it. We delete your personal information once it is no longer needed or required to be kept by law by shredding hardcopy records and deleting electronic records.

Your right to lodge a complaint

If you are not satisfied with how we have handled your personal information, you are entitled to lodge a complaint with the Federal Privacy Commissioner. Information regarding how to lodge a complaint is available from the Commissioner’s website at www.privacy.gov.au or by ringing the Commissioner’s information line on 1300 363 992. However, before investigating a complaint, the Commissioner is legally required to be satisfied that you have first expressed your concern to us to afford us an opportunity to resolve the complaint directly, unless it is inappropriate for your to do so. You may lodge a complaint with our Privacy Officer by mail at 2 Railway Tce, Mile End SA 5031. The Company takes your privacy seriously and endeavours to respond promptly and thoroughly to complaints.

Can you check and update the personal information about you that is held by us?

You may obtain access to or correct any personal information which the Company holds about you, unless one of the exceptions in the Principles applies.

To make a request to access of correct information the Company holds about you, please contact us in writing to The Privacy Officer, 2 Railway Tce, Mile End SA 5031. The Company requires you to verify your identity and to specify what information you require. We will provide reasons if we deny any requests for access to or correction of personal information. The Company may charge a fee to cover the cost of providing access including locating, retrieving, reviewing and copying any material requested. Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.

Transfer of your information overseas

We will only transfer your personal information overseas if the transfer is to you, or to one of your authorised representatives, or it is with your express consent. We will not send your information outside of Australia in any other circumstances.

We may need to change our privacy policy from time to time

Due to changing business circumstances, we may need to change our privacy policy from time to time. If we do, we will endeavour to ensure that your overall level of privacy protection is not diminished and will publish the changes on our website. Any actions that we have taken before the change will continue to be regulated by the privacy policy that existed before the changes were made.

Further information

We are happy to provide you with further information regarding your privacy. If you have any queries or requests in this respect, please contact our Privacy Officer by mail: Privacy Officer, 2 Railway Tce, Mile End SA 5031.

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