Rostron Carlyle treats the handling of your personal information very seriously. To that end, Rostron Carlyle has systems and procedures in place to protect your privacy in relation to the handling of your personal information.
Rostron Carlyle abides by the National Privacy Principles, which provide a scheme in relation to the collection, disclosure, use and storage of personal information. Rostron Carlyle’s objective is to handle information responsibly and provide you with some control over the way information about you is handled.
1. Collection of Personal Information
Personal information is information or opinion from which an individual’s identity may be ascertained. The nature of personal information collected by Rostron Carlyle generally comprises an individual’s name and contact details (including address, phone, fax and e-mail). Such personal information is collected for the purposes of arranging, conducting and promoting Rostron Carlyle’s business activities.
Rostron Carlyle does not collect personal information unless it is necessary for Rostron Carlyle to perform one or more of its functions and business activities. On occasion, some of this personal information may be sensitive and Rostron Carlyle will only collect it with your consent or when required to by law.
Rostron Carlyle will destroy personal information when it is no longer required for such functions and business activities.
Rostron Carlyle will generally collect personal information from you directly. For example, Rostron Carlyle may collect personal information via telephone or letter, or when you attend a function or event, provide a resume or enter an agreement.
2. Use & Disclosure of Personal Information
Personal information provided to Rostron Carlyle may be shared with related companies within Rostron Carlyle, where it will be kept strictly confidential and will only be disclosed on a need to know basis.
Rostron Carlyle will use and disclose your personal information for the purpose for which the personal information was initially collected.
Rostron Carlyle may also use that personal information for a purpose related to the initial purpose of collection if that other purpose would be within your reasonable expectations. Related purposes might include internal auditing and administration, adding your name to a contact list, guest list or invitation list or helping us to identify production and broadcast business activities or investment opportunities which may be of benefit or interest to you.
Rostron Carlyle will not use or disclose your personal information for any other purposes without first obtaining your express or implied consent. Rostron Carlyle may however be required to disclose your personal information without your consent if the disclosure is:
- required or authorised by law;
- required in order to investigate an unlawful activity;
- required by an enforcement body for investigative activities; or
- necessary to prevent a serious and imminent threat to a person’s life, health or safety, or to public health or safety.
Generally, Rostron Carlyle will retain your personal information within Australia and not use or disclose it overseas. However, on some occasions the information may need to be transferred overseas in order to perform one of Rostron Carlyle’s functions or activities. In these circumstances, Rostron Carlyle will either obtain your express or implied consent or will use its best endeavours to ensure that your personal information will receive protection similar to that which it would have if the information were in Australia.
As like most business organisations, Rostron Carlyle relies on third party suppliers who are contracted to conduct specialised activities such as insurance broking, supply of equipment, business services, security services and travel and hospitality services. While personal information may be provided to these suppliers in order to enable them to perform the agreed tasks, Rostron Carlyle will make every effort to ensure that the supplier handles the personal information in accordance with the National Privacy Principles and confidentiality principles. Rostron Carlyle will require all such suppliers to provide privacy undertakings and enter confidentiality agreements.
3. Direct marketing
From time to time Rostron Carlyle may use your personal information to identify business activities or investment opportunities which may be of interest to you.
If you do not wish to receive direct marketing information, please let Rostron Carlyle know. Rostron Carlyle will take immediate steps to ensure that you do not receive any direct marketing information in future.
4. Personal Information Quality
Rostron Carlyle’s objective is to ensure that all personal information collected by us is accurate, complete and up-to-date. To assist Rostron Carlyle in achieving its objective, please contact us if any of your details change. Further, if you believe that the information Rostron Carlyle holds is not accurate, complete or up-to-date, please contact us in order to have the information corrected.
5. Personal Information Security
Rostron Carlyle is committed to keeping your personal information secure, and we will take all reasonable precautions to protect your personal information from unauthorised access, loss, misuse or alteration.
Your personal information may be stored in hard copy documents, or electronically on Rostron Carlyle’s software or systems.
Rostron Carlyle maintains physical security over its paper and electronic data stores, such as locks and security systems. Rostron Carlyle also maintains computer and network security using passwords to control and restrict access to authorised staff for approved purposes. Where information is particularly sensitive, the information is overwritten and then manually deleted.
6. Access to Personal Information
You may request access to the personal information Rostron Carlyle holds about you.
The procedure for gaining access is as follows:
- All requests for access to your personal information must be made in writing and addressed to the Privacy Officer
- You must provide as much detail as possible regarding the business entity, department or person to whom you believe your personal information has been provided, and when. This will allow Rostron Carlyle to process your request faster
- Rostron Carlyle will acknowledge your request within 14 days, and access will usually be granted within 14 days, or if it is more complicated, 30 days. Rostron Carlyle will inform you if this timeframe is not achievable
- You will be asked to verify your identity
- A fee may apply to such access in the event that a request for access is onerous or time consuming. Such a fee will cover staff costs involved in locating and collating information, and reproduction costs
- Depending on the circumstances, you may be forwarded the information by mail or email, or you may be required to personally inspect your records at the appropriate place
- You will be given the opportunity to correct any personal information which is no longer accurate
In some circumstances, Rostron Carlyle may not be in a position to provide access. Such circumstances include where:
- access would create a serious threat to safety
- providing access will have an unreasonable impact upon the privacy of other individuals
- denying access is required or authorised by law
- the request is frivolous
- legal proceedings are underway
- negotiations may be prejudiced by such access
- access would reveal a commercially sensitive decision making process
- If Rostron Carlyle denies access to your personal information, it will provide you with reasons in writing.
7. Changes To This Policy
Rostron Carlyle may change this Policy from time to time for any reason and will update the Policy accordingly.
If you believe that your privacy has been infringed you are entitled to complain. All complaints should initially be in writing and directed to the Privacy Officer. Rostron Carlyle will respond to your complaint as soon as possible, within 14 working days, to let you know who is responsible for managing your query. Rostron Carlyle will try to resolve the complaint within 30 working days. When this is not possible Rostron Carlyle will contact you to provide an estimate of how long it will take to handle the complaint.