Privacy Policy
Integrity Governance (a trading name of Gnarwarre Group of Companies – ABN 94105967035) respects privacy and is committed to complying with the National Privacy Principles (NPPS).
The NPPS are contained in the Privacy Act 1988 (the Privacy Act) and from 14th March 2014, govern how organisations handle personal information.
Integrity Governance’s privacy policy is divided into the following sections:
- How does Integrity Governance collect personal information?
- What personal information does Integrity Governance collect?
- How is personal information used?
- Will personal information be given to anyone else?
- Access and correction
- Is personal information held safely?
- Business contact personal information
- Online privacy issues
- Contacting Integrity Governance
- Changes to this privacy policy
1. How does Integrity Governance collect personal information?
Integrity Governance is a professional organisation that promotes good corporate governance and compliance. The services Integrity Governance offers include:
- Board reviews and development plans;
- Professional development (for example, through training, mentoring and support);
- Technical and professional support; and
- Confidential consultancy in all aspects of corporate governance except the recruitment of directors.
For the purpose of our privacy policy, these are referred to as “our services”.
Integrity Governance collects personal information in a number of different ways:
- We collect personal information for our clients through surveys as part of the board and individual director reviews. Personal information from non-clients who request information is collected through registration forms. Integrity Governance also collects personal information from online forms on our website at www.integritygovernance.com.
- Occasionally we may “rent” lists of names and contact details so that we can use that personal information to promote our services.
This privacy policy focuses on how we handle the personal information about our clients and individuals who may be interested in our services. Integrity Governance also may handle information about people who do not fall within these categories. These people are our “business contacts” (e.g. our suppliers). How we handle the personal information of our business contacts is discussed in section 7.
2. What personal information does Integrity Governance collect?
If you utilise our online services, we will ask you to provide your business contact details. This includes details of your position, your Company, board and contact details.
We may ask for some of this information when you register to receive information from Integrity Governance. We may collect additional personal information about your educational and professional qualifications. This may be collected online.
As explained in section 3 below, the reason we collect this information is so that we can provide you with tailored services, manage our relationship with you, communicate with you effectively and identify which of our services will best meet your needs.
We may also collect personal information by “renting” lists. If we do so, when we use that personal information, we will offer people on the list an opportunity to be removed from our mailing list, or to “opt out” from receiving further promotional or educational material. Our use of personal information collected in the other ways outlined above is discussed in section 3 of this policy.
3. How is personal information used?
The personal information collected from you by Integrity Governance is used to:
- Provide you with our services. This includes the use of personal information for enabling you to participate in one of our reviews of a board or individual director; and/or
- Notify you about services and promotions offered by us. We do not, as a matter of policy, send any unsolicited communication to directors or executives that participate or benefit from our board services.
Integrity Governance will never use personal information about you to provide you with information about products, services and promotions offered by any company apart from Integrity Governance. Integrity Governance contact details are detailed in section 9.
4. Will personal information be given to anyone else?
In the circumstances described below, personal information may be disclosed outside Integrity Governance.
a. Outsourcing
Personal information collected by Integrity Governance may be disclosed to third parties to whom Integrity Governance contracts out specialised functions (including mailing houses, printing companies and conference organisers).
Integrity Governance does not disclose personal information to any party outside of Integrity Governance without the permission of our clients. Integrity Governance usually enters a contractual arrangement with a secure mailing house, and it will be that third party’s contractual obligation to mail out information about any relevant products, services or promotions.
In the rare event that Integrity Governance does disclose personal information to third party contractors under outsourcing or contracting arrangements, we take steps to ensure that those contractors:
- comply with the NPPS when they handle your personal information (regardless of whether they are a small business, and would otherwise be exempt from the new privacy laws); and
- are authorised only to use personal information provide the services or to perform the functions required by Integrity Governance.
b. Disclosures required by law
The only other time Integrity Governance would make disclosures of personal information is if it is required to do so by law, as part of a regulatory deposition or inquiry, or if the disclosure is permitted under the Privacy Act.
Integrity Governance does not sell, rent or trade personal information to or with third parties.
5. Access and correction
Under the Privacy Act, you have a right to seek access to the information which Integrity Governance holds about you (although there are some exceptions to this). You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date.
If you wish to exercise your right under the Privacy Act to seek access to the personal information that Integrity Governance holds about you, we ask that you contact Integrity Governance’s privacy officer (details at section 9 below) who will explain how Integrity Governance will handle your access request.
We will assume (unless you tell us otherwise) that your request relates to our current records about you. These current records will include personal information about you which is included in our databases and in paper files, and which may be used by Integrity Governance on a day to day basis.
To provide you with access to “current” personal information, Integrity Governance would ordinarily provide you with a print-out of the relevant personal information from our databases, or with photocopies of records which are held only on paper files.
If personal information about you (for example, your name & address details) is duplicated across different databases, we will generally provide you with one extract or printout of this information, rather than multiple extracts. Integrity Governance will not normally charge you for the cost of providing this type of access to these records.
For legal and administrative reasons, Integrity Governance may also store records containing your personal information in its archives. In some circumstances, you may seek access to records held by Integrity Governance which are not current records, but if you do so, we may charge you for the cost of providing access.
If you are of the view that personal information about you is not accurate, complete or up to date, please provide Integrity Governance’s privacy officer with your request for correction (contact details are set out in section 9 below). While our policy is to respond to any requests for correction in a timely way, we may be legally obliged to seek the permission of current or former clients to provide information to third parties who are no longer associated with our current or former clients (e.g. a former director of a company would fall into this category).
6. Is personal information stored safely?
Integrity Governance takes steps to ensure the security of personal information held by it from such risks as loss or unauthorised access, destruction, use, modification or disclosure. Integrity Governance does not permit access to any individual data except for the Chairman and authorised public representatives of your board and your authorised personnel. It is a condition of employment that Integrity Governance employees and associates maintain the confidentiality of personal information.
7. Non customer information
Sometimes Integrity Governance needs to collect personal information about individuals (e.g. Company Secretary) who are not members of the board, or who are not people to whom we currently provide our professional services. This will usually arise where we are asked to provide additional governance information and insight to individuals or where our clients have sought input from contributors that may be outside the client’s organisation. Our policy is only to use personal information collected from non-clients for the business purpose for which it was collected.
8. Online privacy issues
Integrity Governance will apply this policy to all personal information it handles, whether collected online or otherwise.
To the extent that this privacy policy applies to online privacy issues, it is to be read as forming part of the terms of use for our website. Section 8 is intended to provide more information about privacy for the users of our website.
a. Online collection of personal and non-personal information
As outlined in section 1 of this privacy policy, we collect personal information through our website.
Our website also collects other information which may or may not be personal information. For each visitor to our website, our server automatically recognises and stores your “address” (e.g. your domain name or internet protocol address), the type of your internet browser, the address of the site which “referred” you to our website and click stream data.
In addition, our website uses cookies to track usage of our web site. Most web browsers are set by default to accept cookies. However, if you do not wish to receive cookies you may set your browser to either prompt or refuse cookies. Please note that rejecting cookies may mean that not all the functions on the website are available to you.
We use cookies for tracking the statistics and performance of our website. This allows us to better understand our users and improve our website. This tracking is conducted in such a way to ensure the anonymity of visitors – in this context the cookie may identify your computer – but it should not identify you.
b. Links to other websites
Sometimes our website contains links to third party websites, for your convenience and information. When you access a non-Integrity Governance website, please understand that Integrity Governance is not responsible for the privacy practices of cyber security of that site. We suggest that you review the privacy policies of each site you visit and maintain vigilance about cyber security risks.
9. Contacting Integrity Governance
If you have any questions or comments about this privacy policy, or if you wish to complain about how we have handled personal information about you, please contact Integrity Governance’s privacy officer:
By telephone
1300 794 049 (Australia)
+61 (3) 5266 1899 (international)
+44 845 805 4749 (United Kingdom)
By email
[email protected]
By letter
Integrity Governance
GPO Box 6288
Highton VIC 3216
Australia
10. Changes to this Privacy Policy
This privacy policy may change from time to time.