PURPOSE OF THE POLICY
Cumberland takes its obligations under the Privacy Act seriously and will take all reasonable steps in order to comply with the Act and protect the privacy of the personal information that we hold. This policy sets out how we intend to do so.
The Policy applies to customers/suppliers/staff/visitors that provide us with their personal information.
CATEGORIES OF PERSONAL INFORMATION THAT CUMBERLAND HOLDS
The nature of the personal information Cumberland collect, and where it comes from, will vary but may include:
- Identify particulars such as: Your name, date of birth, address, occupation, contact details, drivers licence number, references, professional interests.
- Your bank account details and credit card information.
- Information we collect from you for providing our goods and services to you, or when processing an application for you for commercial credit.
- Email and user ID’s.
- Records of your communications with us.
- Information about your transactions with us, such as account balances, payment history and account activity.
- Information we may receive from credit reporting bodies.
Other information that may reasonably identify the person.
WHY WE COLLECT IT?
Cumberland collects uses and discloses the information in accordance with the Collection Statement.
Cumberland primarily collects information for the following purposes:
- To protect the personal information we collect about you from misuse or loss by maintaining physical electronic and procedural. safeguards that meet or exceed applicable law.
- To train people who work for us how to properly handle personal information and restrict access to what is necessary for specific job functions.
- To consider making offers of employment or for employment purposes.
- To provide you (if a client) or your organisation with our products and services.
- To receive services from you or the organisation which employs you.
- To take all reasonable steps to ensure that all unsolicited information is destroyed immediately.
- To keep a record of correspondence if you contact Cumberland.
To allow you the option not to identify yourself when dealing or communicating with us, only where it is practicable.
PURPOSE OF COLLECTING YOUR INFORMATION
Cumberland will only collect personal information for the primary purposes of general business operations. These purposes may include:
- Providing you with our goods and services.
- Assessing and processing an application for commercial credit.
- Evaluating and monitoring credit worthiness.
- Processing receipts and payments, and servicing customer’s account(s).
- Responding to customers’ inquiries about goods and services, applications and accounts, and communicating with you.
- Meeting our legal and regulatory requirements, including consent for registration on the PPSR (Personal Properties Securities Register).
- Billing purposes.
- Marketing and promotion (such as providing individuals with information about our products and promotional notices and offers), and
- Improving our website.
We will, where practicable, only collect the above information from you, and by lawful and fair means.
Where you seek commercial credit or deferred payment, we may also make enquiries with third parties with your consent. This could include persons nominated by you as trade references and your bankers.
DISCLOSURE OF YOUR INFORMATION
Cumberland may disclose your personal information:
- For the primary purposes for which it was collected such as those described above i.e. for our business operations, which includes, assessing, processing and monitoring a credit application form application by you for commercial credit.
- Where you would reasonably expect this.
- Where you have consented.
- For regulatory and compliance purposes.
- To the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend our legal rights.
- For direct marketing by us, but giving you the opportunity to opt out of such direct marketing; Cumberland includes its contact details in any direct marketing to you.
- Cumberland will not disclose your personal information to any credit reporting body.
- Cumberland does not disclose your personal information for any secondary purposes unless your consent has been given or as required by law.
Cumberland will not sell or license any personal information that we collect from you.
Cumberland may need to access staff email for business purposes from time to time.
Cumberland may install spam filters or block access to inappropriate websites not directly related to the business of the company.
Cumberland may allow access to use social media such as blogs, wikis, social networking sites, forums for business related purposes only.
As part of Cumberland’s functions and business activities and to promote the services we provide, we may use personal information that you have provided to us for the purposes of direct marketing. Direct marketing includes, but is not limited to, sending to you and/or contacting you in relation to promotions and information about the company’s products and services. Generally, we will do so where you have expressed your interest to receive such information.
We take reasonable steps to maintain accurate, timely, relevant, complete and appropriate information about our customers, clients, suppliers and website users. Staff, suppliers and customers may access their own personal information held by Cumberland unless there is an exemption under the Privacy Act such as where there is a legal duty of confidentiality or non-disclosure.
Cumberland will provide a formal response to any such request in a reasonable time. If you require access to your personal information please contact the Privacy Officer by email at firstname.lastname@example.org.
If you have any complaints about our privacy practices or wish to make a complaint about how your personal information is managed please contact the Privacy Officer. All complaints will be investigated.
SECURITY & STORAGE
We place a great importance on the security of all information associated with our customers, clients and suppliers. All information held is kept securely and that held electronically is held on secure servers in our facility. Information stored within our computer systems can only be accessed by those entrusted with authority and computer network password sanctions.
We will take all reasonable steps to protect the security of the personal information that we hold. This includes appropriate measures to protect electronic materials and materials stored and generated in hard copy.
CROSS BORDER DISCLOSURE
Any personal information provided to us will not be disclosed to an overseas recipient. If for any reasons disclosure of your personal information to an overseas recipient is required, we will only do so in accordance with requirements under the Privacy Act.
COLLECTING SENSITIVE INFORMATION
We do not contract out data storage or processing functions.
LEGAL REASONS WHY WE COLLECT THE PERSONAL INFORMATION
We collect information which you have provided to us in the course of our business and in order to comply with our legal obligations.
- The Privacy Act (1988)
- Privacy Amendment (Enhancing Privacy Protection) Act 2012
- Privacy Regulation (2013)