26 July 2018
1. PURPOSE OF POLICY
Lotsearch Pty Ltd ABN 89 600 168 018 (Lotsearch) is committed to complying with the Privacy Act 1988 (Commonwealth) (the Act).
Lotsearch collects personal information from a variety of classes of persons as described below.
Persons who place orders for Lotsearch products and services
Lotsearch collects the following personal information directly from you:
• when you place an order for Lotsearch products or services on behalf of the organisation you represent or on your own behalf; and
• when you contact Lotsearch (whether by telephone, email or online) to discuss products and services that Lotsearch has provided to your organisation or to you including requesting further information about a report that Lotsearch has provided and referral to a third party adviser.
The personal information Lotsearch collects about you when you place an order with Lotsearch on behalf of the organisation you represent or contact Lotsearch to discuss a product or service that Lotsearch has provided to your organisation includes: your name; the name of the organisation you represent; the address of the organisation you represent; your job position; your email address; and your telephone number.
The personal information Lotsearch collects about you when you place an order with Lotsearch on your own behalf or contact Lotsearch to discuss a product or service that Lotsearch has provided to you includes: your name; your address; your email address; and your telephone number.
Contractors, suppliers, service providers and job applicants
Lotsearch typically collects and holds the following kinds of personal information about contractors, service providers, suppliers and job applicants:
• name and contact details;
• information contained in resumes;
• educational details, academic and other transcripts, employment history, skills and backgroundchecks;
• references from past employers and referees;
• information collected during the interview or assessment process;
• details of your performance under any contract; and
• personal information required to make payments, such as bank account details.
We may also collect sensitive information contained within the sources set out above, such as membership of a political, professional or trade association or trade union, criminal records and health information.
Visitors to our Website, social media connections and online contacts
The amount and type of information Lotsearch collects from you when you use of our Website or contact us online will depend upon your use of the facilities and services available through our Website or otherwise available online. Generally, the only personal information which Lotsearch will collect about you when you use our Website or contact us online is what you tell us about yourself such as when you complete an online subscription form to our newsletter or other form, when you accept an invitation to attend a seminar or function we host or you send us an email. The kinds of personal information that we may collect in these circumstances include:'
• your name, contact details, employer and job title; and
• sensitive information about you such as dietary requirements or religious affiliations which may affect dietary requirements for use by us when organising seminars or functions.
Lotsearch will also collect personal information from you if you contact Lotsearch via Lotsearch social media channels or via other online means. The information Lotsearch will collect in these circumstances will generally be limited to the information that you provide when contacting Lotsearch.
• the number of page views (or page impressions) that occur on the Website;
• the number of unique visitors to the Website;
• how long these unique visitors (on average) spend on Website when they visit; and
• common entry and exit points into Website.
In person and telephone
Lotsearch will collect personal information about you if you contact Lotsearch in person, for example if you meet a representative of Lotsearch and you give that representative your business card of contact information.
Lotsearch will also collect personal information about you if you telephone Lotsearch for purposes other than placing an order or discussing products and services that Lotsearch has provided, for example, if you would like to discuss the scope of Lotsearch’s products and services or potential business opportunities with Lotsearch.
In most instances we will collect personal information directly from the person to whom the information relates, or the organisation of which that personal is an employee, director or principal.
However, we may also collect personal information about individuals from the following third parties:
• our clients;
• service providers;
• parties to whom you refer us, including previous employers and referees;
• recruitment agencies;
• online searches; and
• social media (such as LinkedIn and Facebook).
When we obtain personal information from third parties to whom you refer us, we will assume and you must ensure that you have made that third party aware that you have referred us to them and of the purposes involved in the collection, use and disclosure of the relevant personal information.
4. PURPOSES OF COLLECTION, HOLDING USE AND DISCLOSURE OF PERSONAL INFORMATION
Lotsearch collects, holds, uses and discloses personal information for the purposes for which it was collected. Lotsearch will also use and disclose your personal information for a secondary purpose that is related to a purpose for which we collected it, where you would reasonably expect Lotsearch to use or disclose your personal information for that secondary purpose.
The purposes for which we collect, hold, use and disclose personal information include:
• providing the products and services that our customers have requested;
• maintaining, managing and developing our relationship with customers and potential customers;
• carrying out product, service and business development and improvement;
• carrying out security and risk management;
• marketing our products and services;
• administering and operating our online subscriptions;
• providing you with information that you have requested;
• organising seminars and other events;
• assessing and considering applications from prospective employees, contractors and service providers;
• developing and managing relationships with our employees, contractors and service providers;
• taking out and managing our insurances; and
• complying with our legal and regulatory obligations (for example where the use or disclosure is authorised or required by or under an Australian law or court/tribunal order).
In addition, if you have contacted Lotsearch about a report or other product or service provided by Lotsearch to your organisation or to you, and you have informed Lotsearch that you would like to be referred to a specialist third party adviser to obtain advice about the report, product or service, you agree that Lotsearch may disclose such personal information as Lotsearch considers necessary to an adviser to allow that adviser to contact you for the purposes of contacting you in relation to the report, product or service.
5. DIRECT MARKETING
If you are a customer or have otherwise expressed interest and provided your contact details to Lotsearch, we may send emails to you with information about developments in our products, services and business and marketing our business (such as invitations to seminars and other events).
Lotsearch may use an "email management system" to automate the management and dispatch of these emails. The system operates by inserting tracking codes in the emails that we send to you. The tracking code allows us to collect personal information about you, such as whether you received and opened an email, and whether you clicked through to any links to our website. The personal information that the email management system collects and holds about you is used by us to:
• ensure that you only receive correspondence that you have informed us that you wish to receive;
• insert your personal information into our communications with you;
• determine whether the information that we send to you is suitable for your interests, information needs and profile;
• ensure that the email address that you have provided us is still operational;
• determine whether emails that we send to you are received by you;
• update a request that you make to us to unsubscribe from a publication that we send to you;
• review the effectiveness and relevance of our emails to you by collecting other statistical information.
If you do not wish for us to send you such emails, please let us know by contacting our Privacy Officer at the details below.
You can also unsubscribe from our email notifications by clicking on the 'Unsubscribe' button at the bottom of our email notifications and following the prompts or by emailing us by clicking the 'Contact Us' button.
6. DISCLOSURES OF PERSONAL INFORMATION TO PERSONS LOCATED OVERSEAS
Lotsearch may disclose personal information to external service providers located overseas so that they can provide us with services in connection with the operation of our business, such as marketing services and data storage.
If you apply to us for employment, and have lived or worked overseas, we may disclose your personal information to overseas recipients for the purposes of gathering information to assess your application. If you have previously worked for us, and provide our details to a prospective employer or recruitment agency located overseas, we may disclose your personal information to that entity to assist them to assess your application.
7. ACCESS TO THE PERSONAL INFORMATION WE KEEP ABOUT YOU
You have a right to request access to the personal information Lotsearch holds about you and to request its correction if it is inaccurate, out of date, incomplete, irrelevant or misleading.
If you wish to access, correct or update any personal information Lotsearch holds about you, please contact our Privacy Officer as set out below. We will respond to all requests for access to or correction of personal information within a reasonable period.
In some cases, in accordance with the Privacy Act, Lotsearch may charge you a fee for access to personal information we hold about you or refuse to give you access to personal information we hold about you.
8. STORAGE AND SECURITY OF PERSONAL INFORMATION
Lotsearch will take reasonable steps to keep any personal information it holds about you secure. However, except to the extent liability cannot be excluded due to the operation of statute, Lotsearch excludes all liability (including in negligence) for the consequences of any unauthorised access to your personal information. Please notify Lotsearch immediately if you become aware of any breach of security.
Lotsearch stores your personal information in hard copy or electronically in its ordinary IT systems and takes a range of measures to protect your personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. These may include cloud servers or the servers of third parties.
Lotsearch implements a range of physical and electronic security measures to protect the personal information that we hold including systems and application access controls implemented to restrict access to information (on a need to know basis).
Our third party data storage providers are required to protect personal information in accordance with applicable laws and take appropriate technical and organisation measures against unauthorised or unlawful use of personal information or its accidental loss, destruction or damage.
9. NOTIFIABLE DATA BREACHES
Lotsearch is confident of its security measures. However, in the event of loss or access or disclosure of your confidential information that is likely to result in serious harm to you, Lotsearch will comply with its obligations under the Privacy Act including notifying you and the Australian Privacy Commissioner as soon as is practicable in the circumstances.
10. COMPLAINTS PROCESS
Lotsearch will take any privacy complaint seriously. Lotsearch will aim to resolve any such complaint in a timely and efficient manner, and our target response time is 30 days. During the resolution process, Lotsearch will require your cooperation by providing information Lotsearch may request. If you are dissatisfied by the resolution process, you may make a formal written complaint to the
Office of the Australian Information Commissioner which is the regulator responsible for privacy in Australia. The Office of the Australian Information Commissioner's contact details are as follows:
Phone: 1300 363 992
Mail: Director of Compliance, Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW 2001
12. CONTACT US