About this Policy
Version 1.1, December 2019
Tiwi Partners views personal privacy as an important issue and is committed to respecting the privacy and security of personal information provided to or collected by Tiwi Partners.
This policy is written in simple language. Tiwi Partners’ specific legal obligations when collecting and handling your personal information are outlined in the Privacy Act 1988 and in particular in the APPs found in Schedule 1 of the Privacy Act 1988. This policy will be updated when our information handling practices change.
This policy adopts the language of the APPs and a copy of the principles may be obtained from the website of the Office of the Australian Information Commissioner at www.aoic.gov.au.
This policy applies to all Tiwi Partners web pages at www.tiwipartners.com.au and any other related domains. Tiwi Partners reserves the right to update this Policy from time to time.
Tiwi Partners may collect, hold and use personal information in the conduct of its functions and activities.
Collection of Personal Information
Personal information will be collected and used or disclosed by Tiwi Partners for the purposes of conducting its business activities, for pursuing its legitimate interest, for legal or regulatory compliance activities as required by law or good business practice or for the purposes for which the information is provided.
Collection of Sensitive Information
Sensitive Information is defined in the Privacy Act 1988 as information or opinions about such things as an individual’s racial or ethnic origins, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Under the legislation, Sensitive Information will be used by us only:
For the primary purpose for which it was obtained;
For a secondary purpose that is directly related to the primary purpose; and
With your consent; or where required or authorised by law.
Tiwi Partners believes that there is a possibility that, from time to time, through the conduct of their business activities there may be the collection of certain sensitive information about a particular person or persons.
For What Purpose does Tiwi Partners collect, hold, use and disclose your personal information?
The purposes for which Tiwi Partners collect, hold, use and disclose your personal information depend on how and why that information was originally gathered by use from you. We will not collect, hold, use or disclose your personal information other than for the purpose for which it was collected, or for a purpose which is reasonably apparent at the time we collect it.
Your personal information may be collected, held, used or disclosed for various purposes including the following:
Recruitment and employment opportunities;
Promotion of Tiwi Partners’ services, including details of events and seminars;
Performance of its professional services and duties;
Assessing prospective clients and projects, including risk and creditworthiness;
Handling or defending complaints, dispute or claims;
Undertaking research relating to professional services activities;[TR1]
Passing information to Tiwi Partners’ related companies, credit agencies, government agencies and legal and professional service providers where appropriate; and
Compliance with the relevant statutory obligations, including government reporting and specific local law requirements.
Other purpose may include:
Information Technology Service Providers
Tiwi Partners may from time to time utilise external service providers to whom it discloses personal information. These include providers that host the website servers, manage the IT Systems and attend to the installation and maintenance of the technical hardware
To protect any Personal Information we:
Enter into a contract or MOU which requires the service provider to only use or disclose the information for the purposes of the contract or MOU;
Include special privacy requirements in the contract or MOU, where necessary.
Generally there will be no disclosure of information overseas except in a situation where disclosure is required for an ongoing investigation, criminal proceedings or a complaint made against a guest or visitor to the Premises.
Tiwi Partners will take all reasonable steps to ensure that any overseas recipients do not breach any of the obligations imposed under the APP’s in relation to any Personal information that may be disclosed to them.
Where possible, we will allow you to interact with us anonymously or using a pseudonym. However, please be advised that in the interests of maintaining safety and security we may need to very a person’s identity as required by law and accordance with the Privacy Act 1988.
How we hold your Personal Information
Your personal information is not stored or retained for any longer than is required in accordance with Tiwi Partners’ legitimate interest to do so for the period necessary to comply with the relevant legal obligations related to the storage of specific types of records and/or information.
Quality of Personal Information
To ensure that the personal information we collect is accurate, up-to-date and complete, we:
Record information in a consistent format;
Where necessary, confirm the accuracy of information we collect from a third party or a public source;
Promptly add updated or new personal information to existing records;
Security of Personal Information
By accessing www.tiwipartners.com.au or the website of a related entity, you acknowledge that the internet is not a secure environment; however Tiwi Partners takes all reasonable steps to protect the security of personal information collected through the conduct of its business, through:
Regularly assessing the risk of misuse, interference, loss, and unauthorised access, modification or disclosure of that information;
Taking measures to address those risks, for example, we keep a record (audit trail) of when someone has added, changed or deleted personal information held in our electronic databases and regularly check that staff only access those records when they need to;
Conducting regular internal and external audits to assess whether we have adequately complied with or implemented these measures.
We destroy personal information in a secure manner when we no longer need it.
Accessing and Correcting your Personal Information
Under the Privacy Act 1988 you have the right to ask for access to personal information that Tiwi Partners holds about you, and ask that we correct personal information. You can ask for access or correction by contacting us at: email@example.com. If you ask, we must give you access to the information collected or provide a response in writing as to why we are prevented from allowing you access.
If any information collected is incorrect we must take reasonable steps to correct it, unless there is a law that allows or requires us not to.
We will ask you to verify your identity before we give you access to your information or correct it, and we will try to make the process as simple as possible. If we refuse to give you access to, or correct, your personal information, we must notify you in writing setting out the reasons.
If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to.
If we refuse to correct your personal information, you can ask us to associate with it (for example, attach or link) a statement that you believe the information is incorrect and why.
Please make a request to access personal information in writing. We will not charge any fee for your access request, but may charge an administrative fee for allowing you to access the information, under supervision of an authorised staff member.
How to make a Complaint
If you wish to complain to us about how we have handled your personal information you should complain in writing.
If we receive a complaint from you about how we have handled your personal information we will determine what (if any) action we should take to resolve the complaint.
If we decide that a complaint should be investigated further, the complaint will usually be handled by a more senior officer than the officer whose actions you are complaining about.
You will receive confirmation of our receipt of your complaint and we will respond to it with a decision within 30 days.
You may also wish to contact the Office of the Australian Information Commissioner as follows:
Phone: 1300 363 992
Address: GPO Box 5218, Sydney NSW 2001
How to Contact us
If you require further information on how Tiwi Partners handles personal information, please contact us directly firstname.lastname@example.org