Shelfcom (S.A.) Pty. Ltd. (A.C.N. 008 160 441) trading as Shelfcom is bound by the Australian Privacy Principles (the APPs) as set out in the Privacy Act 1988.
Shelfcom takes its obligations under the Privacy Act seriously, and has adopted internal policies and procedures to ensure that personal information collected, stored, used and disclosed is dealt with in accordance with the APPs.
Why we need to collect personal information
Shelfcom may need to collect personal information about you and others including names, addresses, phone numbers and other contact details. We may also collect details of the age, sex and other personal information about you or others.
This personal information is collected so we can:
If we are not provided with all the personal information we request, we may be unable to act for, or do business, with you or others.
Where possible, we will collect personal information directly from the individual concerned. An individual's representatives may, however, hold personal information (eg financial or bank account details or a credit reference) that we may need to access for particular dealings, legal proceedings or other purposes.
Where we are at liberty to do so, we will use our best endeavours to seek an individual's consent before obtaining their personal information from third parties.
Shelfcom may collect personal information when:
The personal information of our clients, or their representatives, will usually be recorded or updated on our computer database. Otherwise, personal information will be kept on the file involving the matter in which the individual concerned is involved or for whom the personal information was collected.
Any additional purpose for the collection (not included in this policy) will be identified when we collect the personal information, or as soon as practicable afterwards.
Collection of sensitive information
Under the APPs, Shelfcom is entitled to collect sensitive information about you, or others, for a number of reasons, including where the collection is necessary for the establishment, exercise or defence of a legal or equitable claim.
Where Shelfcom is required to, and it is practicable to do so, we will seek your consent before collecting your sensitive information and inform you of the purpose at the same time.
Shelfcom will use personal information:
To whom does Shelfcom disclose personal information?
Except where indicated above, Shelfcom will not disclose personal information to a third party unless:
Promotional and marketing activities
Shelfcom may use personal information to advise the individual concerned of new services and marketing initiatives we believe may be of interest to him or her, including newsletters, invitations to seminars and business functions and general information about Shelfcom.
Those who prefer not to receive information about our services or seminars can contact Shelfcom's Manager to be removed from the relevant circulation list. Contact details for our Manager appear at the end of this policy.
Shelfcom never discloses personal information to a third party for the purpose of allowing them to direct market their products or services to an individual unless the individual has expressly consented to this disclosure.
Shelfcom may require written confirmation of a request to be removed from our circulation list, for example where legislation requires us to provide particular communication to the individual concerned.
How do we keep your personal information secure?
The protection of personal information is a priority for Shelfcom.
We are committed to maintaining:
Correcting and updating your information
Shelfcom asks you to tell us of any changes to the personal information we hold about you. Notification can be made at any time to update personal information, or to be told that the personal information we hold about you is inaccurate or incomplete. We will take reasonable steps to correct the information in the manner requested.
If we consider the personal information we retain does not require amendment, we will annotate the request on our files.
Access to personal information
Shelfcom will generally allow an individual, on request, access to any personal information we hold about him or her - subject to any restrictions on access (see below). We will endeavour to give the individual concerned access in a form and manner that suits his or her needs.
To request access, please contact our Manager. Contact details for the Manager appear at the end of this policy.
Restrictions on access
Shelfcom is entitled to restrict access to personal information in accordance with the APPs.
You may not be allowed access to personal information we hold where access would reveal evaluative information generated by Shelfcom in connection with a commercially sensitive decision making process. Shelfcom may, instead, give you an explanation for the decision rather than direct access to the information.
If you have given you such an explanation and you believe that direct access to the evaluative information is necessary to provide a reasonable explanation of the reasons for the decision, we will, at your request review the decision. Personnel other than the original decision maker will conduct the review.
Wherever direct access by you is impractical or inappropriate we should consider together whether the use of a mutually agreed intermediary would allow sufficient access to meet both our needs and concerns.
Other instances where it may not be appropriate to provide you with access to the personal information we hold include:
Transferring information overseas
Shelfcom may transfer personal information overseas, if necessary, for the conduct of a legal matter, or for a business transaction or other dealing. Otherwise, we will not transfer personal information outside Australia unless:
Changes to our policy
Shelfcom is committed to constantly improving our procedures so that personal information is treated appropriately. If you feel that we have failed to deal with your personal information in accordance with the APPs, or this policy, please speak with us so we have an opportunity to resolve the issue to your satisfaction.
The person to contact regarding this is our Manager. Contact details of the Manager appear at the end of this policy.
Our Manager will manage the following processes for us:
If this process does not result in an outcome that is satisfactory to you, you may contact the Office of the Australian Information Commissioner on 1300 363 992.
Shelfcom will work together with the Australian Information Commissioner's office to resolve the issues between us.
Further information relating to privacy and your rights can be obtained from the website of the Office of the Australian Information Commissioner http://www.oaic.gov.au/
Contact person at Shelfcom
If you wish to access any personal information we hold about you, or have a query about this policy, please contact our Manager.
Level 6, 89 Pirie Street
Adelaide SA 5000
Phone: 08 8231 6661