We recognise that the privacy of your personal information is important to you. It’s also important to us that you have confidence in us to handle your personal information responsibly.
Carrick Aland is committed to protecting the privacy of the personal information it collects and receives. Carrick Aland is bound by the Australian Privacy Principles (AAP) contained in the Privacy Act 1988 (the Privacy Act).
- The kinds of personal information that Carrick Aland collects and holds;
- How Carrick Aland collects and holds your personal information;
- Why Carrick Aland collects, holds, uses and discloses your personal information;
- How you may access and seek the correction of your personal information as held be Carrick Aland; and
- How you may complain about a breach of Carrick Aland (if any) that Carrick Aland are bound by, and how Carrick Aland deal with such a complaint.
- Your Personal Information
Carrick Aland only collects personal information (being information that identifies or could reasonably identify an individual) where Carrick Aland considers it to be reasonably necessary for Carrick Aland’ functions and activities.
Carrick Aland collects personal information to service the needs of its clients and to carry out its professional association duties including in circumstances when:
- using Carrick Aland services;
- collecting client survey form information;
- recording complaints;
- facilitating use of Carrick Aland’ services; and/or
- addressing requests for information about Carrick Aland.
The types of information Carrick Aland collects includes:
- name, age, gender and address details;
- educational qualifications;
- work history, current employment and position;
- contact details (including postal address, phone, fax and e-mail);
- views and opinions; and
- responses to forms and surveys (if any)
- Your Sensitive Information
Sensitive information is information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record.
It is Carrick Aland’ policy to only collect your sensitive information where it is reasonably necessary for Carrick Aland’ functions or activities and either you have consented or Carrick Aland are required or authorised under law to do so.
- How Carrick Aland collects your Personal Information
Carrick Aland will solicit your personal information by lawful and fair means directly from you unless it is unreasonable or impracticable to do so.
Carrick Aland will collect directly personal information:
- by email;
- over the telephone;
- by written correspondence (such as letters, faxes);
- on hard copy forms (including registration forms, competition entry forms and surveys);
- in person; or
- through the Carrick Aland website;
- at seminars and functions (if you fill out an assessment form or leave your business card);
- during exams or assignments for Carrick Aland programs;
- electronic systems such as applications.
Carrick Aland may collect your personal information from third parties including:
- your legal representative;
- educational providers that assist Carrick Aland programs;
- direct marketing database providers;
- the Australian Tax Office (ATO);
- the Australian Securities and Investment Commission (ASIC);
- professional indemnity Insurance providers; and
- public sources (phone directories, client lists, professional and trade associations, ASIC, bankruptcy or court registry searches).
- Unsolicited Personal Information
Unsolicited personal information is personal information Carrick Aland receives that Carrick Aland has taken no active steps to collect (such as a job application sent to Carrick Aland by an individual on their own initiative, rather than in response to an advertisement).
Carrick Aland may keep records of unsolicited personal information if the information is reasonably necessary for one or more of Carrick Aland functions or activities. If not, it is Carrick Aland’ policy to destroy the unsolicited information or ensure that the information is de-identified, provided it is lawful and reasonable to do so.
- Using your Personal Information
The main purpose for which Carrick Aland collects, holds, uses and discloses personal information are to provide services and benefits to clients, and to maintain, extend and grow Carrick Aland’ client base.
Carrick Aland collects information to service your professional requirements. Carrick Aland can use your information to:
- process client’s details for files;
- inform clients of services offered by Carrick Aland;
- understand Carrick Aland client’s needs and requirements;
- manage and run the Carrick Aland website;
- providing you with information about Carrick Aland services including programs;
- delivering or enhancing Carrick Aland services;
- help Carrick Aland maximise the benefits Carrick Aland provides to client or to assist Carrick Aland in complying with its organisational object, charter or mandate;
- maintain contact with you about Carrick Aland services;
- report back to you about Carrick Aland work or encourage you to learn about what Carrick Aland does; and
- any other purpose directly related to Carrick Aland work and for which you have provided consent (where it is reasonably required by law).
The Carrick Aland website requires subscriptions or registrations to use certain services, functions or consent. You will know what information is being collected via these processes when you complete the relevant forms and provide the required details prior to submitting the application. Carrick Aland will collect data relating to any transactions you carry out through the Carrick Aland website and the fulfilment of your order.
Carrick Aland may also use your data to monitor for any authorised use of the Carrick Aland’ website, content or subscription to Carrick Aland’ services.
- Purpose of Collection
If Carrick Aland collects personal information for a purpose (the primary purpose), Carrick Aland will not use or disclose the information for any other purpose (the secondary purpose) unless:
- you would have consented to the use or disclosure of your personal information; or
- in relation to the use or disclosure of your personal information:
- you would reasonably expect Carrick Aland to use or disclose your information for the secondary purpose and the secondary purpose is directly related to the primary purpose (sensitive information) or related to the primary (not sensitive information);
- use or disclosure is required or authorised under Australian law or a court/tribunal;
- a permitted situation exists in relation to Carrick Aland’ use or disclosure of the information;
- a permitted health situation exists in relation to use or disclosure of the information; or
- Carrick Aland reasonably believes that the use or disclosure of the information; is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
If Carrick Aland uses or discloses your personal information because Carrick Aland reasonably believes that the use or disclosure of your information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, and enforcement body, Carrick Aland will make a written note of the use or disclosure.
- Do you have to provide Personal Information
You can refuse to provide personal information. However a refusal may mean that the service you requested is not provided.
- Sharing your Personal Information
Carrick Aland may use and disclose personal information for related purposes to third parties. Types of organisations to whom Carrick Aland may disclose your personal information includes:
- government bodies such as ATO, ASIC, Australian Prudential Regulatory Authority and the police or courts (as required by law);
- professional or government organisations; and
- Carrick Aland’ contracted service providers including:
- information technology service providers;
- planning research and development providers;
- publishers or Carrick Aland’ newsletters, student handbooks and course material;
- conference organisers;
- marketing and communications agencies;
- call centres and call training centres;
- mailing houses, freight and courier services;
- printers and distributors of marketing material; and
- external advisers (recruiters, auditors and lawyers).
Carrick Aland does not provide, rent, sell or exchange your personal information to third parties without your prior approval.
- Government Identifiers
Carrick Aland does not adopt, use or disclose government related identifiers (such as a Medicare number or driver’s license number) as Carrick Aland’ own identifier for you unless:
- it’s required / authorised by law or court / tribunal order;
- it’s reasonably necessary for Carrick Aland to verify your identity;
- it’s reasonably necessary to fulfil Carrick Aland’ obligations; or
- Carrick Aland reasonably believes it is reasonably necessary for one or more enforcement related activities.
To improve Carrick Aland’ services, Carrick Aland sometimes collects de-identified information from web users. Although the information collected does not identify an individual, it does provide Carrick Aland with useful statistics that permits Carrick Aland to analyse and improve its web services.
When you visit the Carrick Aland website, a record of your visit is logged and the following data is supplied by your browser:
- your IP address and / or domain name;
- your operating system (type of browser & platform);
- the date, time and length of your visit; and
- the resources you accessed or downloaded.
Carrick Aland uses information to customise information for website visitors and to collect aggregated data for the purposes of analysis, quality control, administering and improving the website. It is not used for any other purpose.
Aggregated data may be shared with third parties. You can stop your browser from accepting new cookies or disable cookies altogether by changing your browser preferences.
- Links to Other Websites
- Direct Marketing
If Carrick Aland holds your personal information, Carrick Aland may use or disclose that personal information (other than sensitive information) for direct marketing if:
- Carrick Aland collected the information from you; and
- you would reasonably expect Carrick Aland to use or disclose the information for that purpose; and
- Carrick Aland provided you with a simple way to opt out of receiving direct marketing from Carrick Aland; and
- you have not made such an opt out request to Carrick Aland.
- Carrick Aland may also use or disclose your personal information (other than sensitive information) for direct marketing if:
- Carrick Aland collected the information from you and you would not reasonably expect Carrick Aland to use or disclose the information for that purpose or someone other than you; and
- you have consented to the use or disclosure of the information for that purpose; or
- it is impracticable to obtain that consent; and
- Carrick Aland provided you with a simple way to opt out of receiving direct marketing from Carrick Aland; and
- in each direct marketing communication with you:
- Carrick Aland included a prominent statement that you can request to opt out; or
- Carrick Aland otherwise draw your attention to the fact that you can request to opt out; and
- you have not made such a request Carrick Aland.
Carrick Aland can use or disclose your sensitive information for the purpose of direct marketing if you have consented to the use or disclosure of that information for direct marketing.
Carrick Aland may also use or disclose your personal information for direct marketing if:
- Carrick Aland are a contracted service provider for a Commonwealth contract; and
- Carrick Aland collected your information in order to meet an obligation under that contract; and
- the use or disclosure is necessary to meet (directly or indirectly) such an obligation.
If Carrick Aland has collected the personal information that Carrick Aland used to send you direct marketing material from a third party, you can ask Carrick Aland to notify you of its source of information. It is Carrick Aland’ policy is to do so unless it is unreasonable or impracticable.
- How to Opt Out of Direct Marketing
If Carrick Aland uses or discloses your personal information for the purpose of direct marketing, you may request not to receive direct marketing communications from Carrick Aland.
If Carrick Aland uses or discloses your personal information for the purpose of facilitating direct marketing by other organisations, you may request that the Carrick Aland does not use or disclose your information for this purpose.
Carrick Aland with give effect to your request not to receive direct marketing from Carrick Aland or an entity facilitated by Carrick Aland free of charge within a reasonable time after the request is made.
- Collection Notices
At or before the time of collection of personal information from you, or as soon as practicable afterwards, Carrick Aland will take reasonable steps to notify you or to otherwise ensure that you are aware of:
Carrick Aland’ contact details;
- the fact that Carrick Aland collects, or has collected, your information and the circumstances of that collection (if collected from someone other than you);
- if the collection is required or authorised by law or a court / tribunal order;
- why the personal information was collected by Carrick Aland;
- the consequences to you if Carrick Aland does not collect all or some of your personal information;
- any other entity, body or person, or the types of any other entities, bodies or persons, to which Carrick Aland usually disclose personal information; and
- you may access personal information held by Carrick Aland and seek correction of the information;
- you may complain about a breach of the APP, or a registered APP code (if any) that Carrick Aland is bound by and how Carrick Aland will deal with a complaint.
Carrick Aland will generally include these matters in a collection notice. For example, where personal information is collected on a paper or website from, Carrick Aland will include a collection notice, or a clear link to it, on the form.
- Protecting your Personal Information
Carrick Aland stores information in different ways, including paper and electronic form. Carrick Aland takes reasonable steps to protect it from misuse, interference, loss, unauthorised access, modification or disclosure including:
- secure password protection database for storage;
- confidentiality requirements of staff;
- security measures for access to Carrick Aland’ systems including firewalls;
- servers kept as a secure location with limited access;
- document storage security requirements;
- access granted only those verified to receive person information;
- access control for Carrick Aland’ building;
- limited the provision of personal information to third parties and subject to guarantees about use; and
- Carrick Aland’ staff are trained to deal with the information.
Carrick Aland cannot guarantee that person information will be protected against unauthorized access or misuse and Carrick Aland does not accept any liability for the improper actions of unauthorised third parties.
Carrick Aland will retain your personal information for as long as necessary to fulfil Carrick Aland’ obligations to you, to protect Carrick Aland’ legal interests, to comply with an Australian law or as otherwise stated to you when Carrick Aland collected your personal information.
Once Carrick Aland is no longer required to retain your personal information, Carrick Aland will take reasonable steps to destroy your personal information or to ensure that your personal information is de-identified.
- Disclosing your Personal Information Overseas
Carrick Aland will not disclose your personal information to an overseas third party such as overseas facilities or contractors to process or back-up information or to provide other services. Carrick Aland does not store your personal information on servers based overseas or in the “cloud” or other types of networks or electronic storage.
You have the option of not identifying yourself or using a pseudonym when dealing with Carrick Aland provided that it is lawful and practicable.
Carrick Aland will try to accommodate a request for anonymity if possible. However, your right to anonymity does not apply in relation to a matter if:
- Carrick Aland is required or authorised by or by law or a court/tribunal order to deal with individuals who have identified themselves; or
- It is impracticable for Carrick Aland to deal with individuals who have not identified themselves.
It is Carrick Aland’ policy to enable you to access Carrick Aland’ website and make general phone queries with out having to identify yourself and to enable you to respond to Carrick Aland’ surveys anonymously.
In some cases however, if you don’t provide Carrick Aland with you personal information when requested, Carrick Aland may not be able to respond to your request or provide you with service.
- Accessing your Personal Information
You have the right, upon request, to access any of Carrick Aland’ records containing your personal information.
To request access to your personal information please contact Carrick Aland’ privacy officer.
Carrick Aland will respond to your request to access your personal information within a reasonable period of time.
On the basis that it is reasonable and practicable to do so, Carrick Aland will give you access to the information requested.
If Carrick Aland refuses your request to access personal information, Carrick Aland will provide a written notice setting out the reasons for the refusal and how you can complain about the refusal.
Reasons for a refusal may include if it:
- poses a serious threat to life, health or safety;
- would have an unreasonable impact on the privacy of others;
- is frivolous or vexatious;
- relates to legal proceedings;
- would reveal Carrick Aland’ intentions or prejudice any negotiations;
- would be unlawful;
- is required or authorised by law or court/tribunal order;
- would be likely to prejudice one or more enforcement related activities; or
- relates to commercially sensitive decisions making process.
When you make a request to access personal information, Carrick Aland will require you to provide some form of identification (such as driver’s license or passport) so Carrick Aland can verify that you are the person to whom the information relates.
- Help Carrick Aland keep your Personal Information Accurate
Carrick Aland will take reasonable steps to ensure Carrick Aland’ records of personal information are accurate, up to date and complete.
However, the accuracy of information depends to a large extent on the information you provide. If you do not give Carrick Aland all the personal information Carrick Aland may require, or the personal information provided is inaccurate or incomplete, then the products, services and information Carrick Aland provide may be affected.
If you think there is something wrong with the information Carrick Aland holds about you please contact Carrick Aland’ privacy officer to:
- let Carrick Aland know if there are any errors; and
- keep Carrick Aland up-to-date with any changes,
and Carrick Aland will try to correct your personal information.
Carrick Aland will respond to your request to correct your personal information free of charge and in a reasonable period of time. If Carrick Aland refuses your request, Carrick Aland will provide you with a written notice setting out the:
- reasons for the refusal; and
- mechanisms available to complain about the refusal.
If Carrick Aland refuses to correct your personal information, you may request that Carrick Aland associate your information with a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. Carrick Aland will take reasonable steps to make the statement visible to users of your personal information.
- Dealing with SPAM
Carrick Aland will not send you any commercial electronic messages (SMS or emails) unless it is permitted by the SPAM Act (for example, Carrick Aland has your express or inferred consent). Any commercial electronic message that Carrick Aland sends will identify Carrick Aland as the sender and will include relevant contact details and an unsubscribe facility.
If you do not wish to receive commercial electronic messages from Carrick Aland, please contact the privacy officer.
- Do not call Register
Carrick Aland will not call you on a number listed on the Do Not Call Register unless it is permitted under the Do Not Call Act ad related instruments (for example, If Carrick Aland has your express or inferred consent to do so).
If you do not wish Carrick Aland to call you on a particular number, please contact the privacy officer.
- Resolving you Privacy Issues
If you have any issues you wish to discuss with Carrick Aland or if you’re concerned about how Carrick Aland has collected or managed your personal information please contact the privacy officer.
For information about privacy or if your concerns are not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.
- Carrick Aland Privacy Officer
Carrick Aland’ privacy officer can be contacted at:
Name: Noel Brownsey
Telephone: 07 4669 9800
Fax: 07 4669 9899
Post: Carrick Aland, 27 New Street, Dalby Qld 4405
Last Updated: July 2014