This statement sets out Aspiron Consulting Group's privacy policy and the practices that will be followed to respect the privacy of individuals who deal with Aspiron Consulting Group. This statement is provided in accordance with the Privacy Amendment (Private Sector) Act 2000 (Cth) and the National Privacy Principles ("NPP's") which are set out in that Act.
Collection of information
The type of information collected by Aspiron Consulting Group regarding individuals generally includes the following:
names
addresses (including e-mail addresses)
telephone and facsimile numbers
date of birth
occupation, gender, education
details about next of kin including spouse and children's names
financial details
credit card details
membership of professional associations
social interests.
The information held by Aspiron Consulting Group may come from a number of sources including:
potential employees
independent contractors
existing and new contacts and clients of the firm
other sources
Collecting your information using this website
At Aspiron Consulting Group, we have focused on implementing fair information practices that are designed to protect your privacy. We are also keen to understand better what our visitors most appreciate on our site, and the sections and pages they deem of most interest. This will allow us to gear aspiron.com.au to the preference of our general audience.
To this effect, Aspiron Consulting Group may from time to time use certain software to measure and analyse visitor information related to www.aspiron.com.au. For that purpose, we collect web traffic data and data related to your browser type and PC - on the basis of your IP Address. We will not use that data to identify you personally.
Cookies are also used in this context. "Cookies" is a name for a technology that allows our site to store tokens of information in your browser, to give your browser an identifier used only by our site while you are on our site, but not to identify you. Cookies help us track traffic patterns in the aggregate so that we know what areas of our site users like and don't like based on traffic to those areas. Cookies are not used to determine or track the identity of any user on aspiron.com.au. If you do not want to receive a cookie from aspiron.com.au or any other site, you have the option of setting your browser to notify you when you receive a cookie allowing you to determine whether to accept it or not. Refer to your browser manual for instructions.
If you have any questions or concerns regarding to our measurement activities and how they impact your privacy while using aspiron.com.au, please contact us via enquires@aspiron.com.au
Some information Aspiron Consulting Group holds may be "Sensitive Information"
Sensitive Information is information or an opinion about an individual's:
race or ethnic origin; or
political opinion; or
membership of a political association or religious beliefs, or
memberships of affiliations or philosophical beliefs; or
membership of a professional or trade association or a trade union; or
sexual preferences or practices; or
criminal record.
Sensitive information also includes health information about an individual. Aspiron Consulting Group will only collect sensitive information with the individual's consent.
Aspiron Consulting Group will not collect personal information unless the information is necessary for one or more of its functions or activities. Aspiron Consulting Group will collect the personal information only by lawful and fair means and not in an unreasonably intrusive way. Whenever Aspiron Consulting Group collects personal information about an individual, Aspiron Consulting Group will take reasonable steps to ensure that the individual is aware of:
the identity of Aspiron Consulting Group
the fact that he or she is able to gain access to the information
the purpose for which the information is collected
the organisations to which Aspiron Consulting Group usually discloses information of that kind
any law that requires the particular information to be collected
the main consequences (if any) for the individual if all or part of the information is not provided.
If it is reasonable and practical to do so, Aspiron Consulting Group will collect personal information about an individual only from that individual. If however this information is collected from someone else, Aspiron Consulting Group will act reasonably to ensure the individual is or has been made aware of the matters listed above, unless certain exemptions apply.
The purposes for which Aspiron Consulting Group uses this information
The purposes for which Aspiron Consulting Group uses the personal information referred to above include the following:
to consider potential employee's applications for employment by the firm
to open and administer client accounts
to provide professional services to clients
to administer independent contractors of the firm
for marketing and sales initiatives such as Aspiron Consulting Group publications
for marketing and sales of Aspiron Consulting Group events and business programs.
Use and disclosure
As a general rule, Aspiron Consulting Group will not use or disclose personal
information about an individual other than for its primary purpose of collection, unless:
the individual has consented to the use or disclosure; or
Aspiron Consulting Group has reason to suspect that unlawful activity has been, or may be engaged in, and uses or discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities; or the use or disclosure is required or authorised by or under law; or
Aspiron Consulting Group reasonably believes that the use or disclosure is reasonably necessary for a specified purpose by or on behalf of an enforcement body.
Aspiron Consulting Group will use the information for our own direct marketing purposes only where:
it is impractical for Aspiron Consulting Group to seek the individual's consent before that particular use
Aspiron Consulting Group will not charge the individual for giving effect to a request not to receive direct marketing communications
the individual has not made a request not to receive direct marketing communications in each direct marketing communication with the individual, Aspiron Consulting Group draws to the individual's attention, or prominently displays a notice, that he or she may express a wish not to receive any further direct marketing communications; and
each written direct marketing communication by Aspiron Consulting Group with the individual (up to and including the communication that involves the use) sets out Aspiron Consulting Group's business address and telephone number and, if the communication is made by fax or email or other electronic means, a number or address at which Aspiron Consulting Group can be directly contacted electronically.
Data quality
Aspiron Consulting Group will take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up to date.
Data security
Aspiron Consulting Group will take reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure.
Aspiron Consulting Group will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.
Openness
Aspiron Consulting Group has set out in this document its policies on management of personal information and will make this document available to anyone who asks for it.
On request by a person, Aspiron Consulting Group will take reasonable steps to let the person know, generally, what sort of personal information we hold, for what purposes, and how we collect, hold, use and disclose that information.
Access and correction
As a general rule, Aspiron Consulting Group will, on request by an individual, provide them with access to their personal information. Aspiron Consulting Group may however choose not to provide individuals with access to such information. This would include cases where:
providing access would have an unreasonable impact on the privacy of other individuals
the request for access is frivolous or vexatious
the information relates to anticipated or existing legal proceedings and would not be discoverable in those proceedings providing access would reveal the intentions of Aspiron Consulting Group in relation to negotiations with the individual in such a way as to prejudice those negotiations
providing access would be unlawful
providing access would be likely to prejudice an investigation of possible unlawful activity
providing access would be likely to prejudice activities which are carried out by Aspiron Consulting Group on behalf of an enforcement body.
Aspiron Consulting Group may decide to impose a charge upon the individual to cover the cost of verifying a request for information and locating, retrieving, reviewing and copying any material requested.
Identifiers
Aspiron Consulting Group will not adopt a government agency identifier (such as a tax file number or Medicare number) as its identifier of an individual.
Anonymity
Wherever it is lawful and practical, Aspiron Consulting Group will allow individuals the option of not identifying themselves when entering into transactions with us.
Transborder data flows
Aspiron Consulting Group will only transfer personal information about an individual to a third party who is in a foreign country in specified circumstances.This would include:
where the individual consents to the transfer; or
where Aspiron Consulting Group has taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the NPPs.
How can an individual complain about possible breaches of privacy by Aspiron Consulting Group?
A complaint by an individual regarding an alleged breach of privacy by Aspiron Consulting Group should be forwarded in writing to the following address:
Privacy Compliance Officer
Aspiron Consulting Group
Suite 516, Level 5, 100 Victoria Parade
EAST MELBOURNE VIC 3002
The Privacy Compliance Officer will be made available to investigate and resolve the complaint internally through mediation with the individual.
If the individual is not happy with the resolution of their complaint by the Privacy Complaints Enquiry Officer they may then complain to the Privacy Commissioner or Industry Code adjudicator about the act or practice they consider to be an interference with their privacy. The Commissioner then has the power to investigate the alleged breach by examining witnesses, obtaining documents and directing individuals to attend compulsory conferences. The Privacy Commissioner's determinations in such cases are enforceable by the High Court of Australia.