Privacy Statement and Policy

Shelfcom (SA) Pty Ltd (A.C.N. 008 160 441) ("Shelfcom") observes the ten National Privacy Principles (the NPPs) as set out in the Privacy Act 1988.
Shelfcom takes the 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 NPPs.
The following is our Privacy Policy which sets out how we manage privacy in our organisation.

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:

conduct our business and provide our services in a professional and efficient manner;
provide or offer you or others services or other benefits;
identify our clients, potential clients and their representatives;
identify parties with whom our clients have dealings or who are in some way involved in proceedings involving our clients;
inform you or others of any initiatives we may think will be of interest to you or them;
inform you or others of developments in the law and relevant business markets;
develop and implement initiatives to improve our services.

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:

we are contacted about our services, in person, over the phone or by the internet;
we are instructed to provide services to you or others;
during the course of a dealing or proceedings involving a client;
we negotiate and enter into dealings;
we respond to an enquiry where we consider personal details are required or appropriate to fulfil the query.

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.

Personal information
Shelfcom will use personal information:

to identify individuals and protect them from unauthorised access to their personal information, accounts or services;
to improve our services to you or others;
where reasonably required, to provide services that we are obliged to provide;
to inform you or others of Shelfcom's marketing initiatives;
to inform you or others of developments in the law and relevant business markets;
to derive or aggregate anonymous information from which individuals cannot be identified;
to prevent, or lessen, a threat to a person's life or health;
where disclosure is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim;
for the purpose for which it was collected, or for a related purpose (or a directly related purpose in the case of sensitive information) that the individual concerned would reasonably expect from us;
for other purposes permitted, required or authorised by, or under, law;
for any other purpose where an individual has consented to its use for that purpose.

To whom does Shelfcom disclose personal information?
Except where indicated above, Shelfcom will not disclose personal information to a third party unless:

the disclosure is for the primary purpose for which the information was collected;
the individual concerned has consented to the disclosure;
the third party is our agent, or contractor, in which case we will require them to disclose, and to use, the personal information only for the purpose for which it was disclosed;
the third party is a person involved in a dealing or proposed dealing (including a sale) of all, or part, of our assets and business;
there are reasonable grounds to believe that disclosure is necessary to prevent, or lessen, a threat to your life or health or that of another person;
the disclosure is to a related body corporate;
the disclosure is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim;
the disclosure is permitted, required or authorised by, or under law.

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:

safeguards to protect personal information against unauthorised use, disclosure, access, alteration, destruction and accidental loss. All personal information we hold is dealt with in accordance with the NPP's;
industry standards for the security and protection of information. Personal information is stored securely and access is restricted to authorised personnel only. Our computer systems require access passwords, and these are kept secure by our personnel;
internal policies on management or personal information, and staff training to ensure compliance with these policies. All staff are required to read this Policy and understand their responsibilities in relation to personal information.

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 NPPs.
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:-

providing access that would pose a serious and imminent threat to the life or health of an individual
providing access that would have an unreasonable impact upon the privacy of others
the request for access is frivolous or vexatious
information relating to an anticipated, or existing, legal dispute and disclosure would compromise our position, or the position of others.

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:-

we reasonably believe the recipient of the information is subject to legal obligations that uphold principles for the protection and fair handling of personal information which are substantially similar to the principles contained in this Policy;
we are given consent by the individual concerned to do so expressly or by implication;
we are contractually required to do so;
the transfer is for the benefit of the individual concerned and it is not practicable for Shelfcom to obtain their consent and if they were able to grant consent they would be likely to give it. In this instance, Shelfcom will advise, as soon as practicable, the individual concerned to whom their information has been disclosed.

Changes to our Policy
Shelfcom may update or change this Policy. When this occurs, you will have access to it, and it will be shown on our website. Should you have any suggestions, or concerns, that are not addressed in this Privacy Policy, please contact our Manager. The contact details of the Manager are listed at the end of this Policy.

Complaint resolution
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 NPPs, 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:

listen to your concerns and grievances regarding our handling of personal information;
discuss with you the ways in which we can remedy the situation
put in place an action plan to resolve your complaint and improve our information handling procedures if appropriate.

If this process does not result in an outcome that is satisfactory to you, you may contact the Privacy Commissioner's Office. Shelfcom will work together with the Privacy Commissioner's Office to resole the issues between us.
Contact details for the Privacy Commission's Office are:

Level 8, Piccadilly Tower Postal Address GPO Box 5218
133 Castlereagh Street Sydney NSW 1042
Sydney NSW 2000
Telephone: 1300 363 992 (local call cost anywhere in Australia)
TTY: 1800 620 241
Facsimile: 02 9284 9666
E-mail: privacy@privacy.gov.au

Further information relating to privacy and your rights can be obtained from the website of the Federal Privacy Commissioner. (www.privacy.gov.au)
If you wish to access any personal information we hold about you, or have a query about this Policy, please contact our Manager.

Stacey Case - Manager
Shelfcom
Level 4, 80 King William Street
Adelaide SA 5000
Telephone: 08 8231 6661
Facsimile: 08 8414 3498
E-mail: scase@shelfcom.com.au