The purpose of this Policy is to answer the following questions:
1. What personal and financial information does Divide collect?
2. How is personal and financial information collected and stored?
3. How is personal and financial information used?
4. Will personal and financial information be given to anyone else?
5. Collection of other information;
6. Security of personal and financial information;
7. How can you access and correct your personal and financial information?
8. Opting Out.
What personal and financial information does Divide collect?
Personal information is any information, including an opinion, which can be used to identify an individual or linked to an individual. Examples include an individual’s name, address, contact number, email address and private passwords.
Subject to legislative requirements, Divide will only collect personal information relevant to its business or employment relationship with you. Depending upon the service Divide is providing to you, we may ask you to provide us with certain details including, for example, your name and contact information, employment background information, skills, education and information about your use of our services.
The collection of sensitive personal information is restricted by the provisions of the Privacy Act. This means that generally we will not collect any sensitive information about you – for example, personal information relating to your religious views, ethnicity, political opinion, health, criminal record or sexual preference, unless this is necessary to provide you with a specific product or services and you have consented to that collection.
If Divide receives any personal information from you that we did not request, then as soon as practical after Divide becomes aware, and if Divide may lawfully do so, Divide will destroy or de-identify that information and will not keep any record of it.
You are free to ask Divide at any time to delete your personal information from Divide’s database as explained in the “Opting-out” section below.
How is your personal and financial information collected and stored?
If it is reasonable and practicable, we will collect personal information directly from you. How we collect your personal information will depend upon how you interact with us. We may collect it through application forms, service agreements, telephone, email and internet contact, from correspondence with you and in person through meetings with you.
Where Divide collects personal information directly from you, Divide’s policy is to take reasonable steps to notify you of certain matters. Divide will do this at or before the time of collection, or as soon as practicable afterwards. The matters include:
- our identity and how to contact us;
- the purposes for which we are collecting the information;
- whether the collection is required or authorised by or under Australian law or a court or tribunal order;
- the third parties (or types of third parties) to whom we would normally disclose information of that kind;
- whether any of those third parties are located overseas and, if practicable to specify, the countries in which they are located; and
There may be occasions where we need to collect personal information from other parties with or without your direct involvement, for example, publicly available sources of information, market research organisations and/or your employer.
Divide may collect personal information from the following web sites or Company:
- Google Search
Through receiving emails, we may also use third parties to analyse traffic at those websites. Information collected through such analysis is anonymous.
Divide takes reasonable steps to ensure the security of personal information held by it from such risks as loss or unauthorised access, destructions, use, modification or disclosure.
Divide may need to maintain records for a significant period of time. However, when we consider information is no longer required, we will remove any details that identify you or we will securely destroy the record.
How is personal and financial information used?
At the time of engagement with Divide, you agree that we will continue online communication for the purposes of providing you updated information regarding the services we provide. Divide’s policy is to use personal information for the main business purpose for which it was collected. This may include:
- to conduct our business;
- to provide and market our services;
- to communicate with you;
- to comply with our legal obligations;
- to manage our relationship with you; and
- to help us manage and enhance our services.
Will personal and financial information be given to anyone else?
Generally, Divide will not share with, rent, sell or otherwise disclose your personal information to any other company or organisation without your consent. At times, however, it is necessary for us to disclose your personal information to other persons or organisations. However, we will only disclose your personal information where we are allowed to by law and have your express or implied consent, or where we are obliged to by law.
You can give express consent verbally or in writing. Implied consent is where we have reasonably assumed you have given consent from your conduct. For example, consent can be implied when a person continues with a telephone conversation after being informed the telephone conversation may be recorded for training purposes.
Where Divide discloses personal information to organisations that perform specific essential services for us, we limit this disclosure to the information they need to perform that service.
Depending upon the products/services we are providing to you, Divide may disclose personal information to, for example (but not limited to):
- agents, contractors and external service providers of Divide who perform functions on our behalf;
- authorised representatives of Divide;
- regulatory bodies, government agencies and law enforcement bodies;
- agents acting on your behalf, including your employees;
- your employer;
- other companies or individuals who assist us in providing services and;
- anyone else you may authorise us to disclose this information to.
Generally, where reasonably practicable, we require organisations or persons outside of Divide who handle personal information as service providers to Divide to acknowledge the confidentiality of the information, undertake to respect any individual’s right to privacy and comply with the Australia Privacy Principles and this Policy.
Divide does not provide any personal information to third parties located overseas. If it does so, Divide’s policy is to comply with the requirements of the Privacy Act that apply to cross border disclosures of personal information, as well as with any legal requirements applicable in the relevant jurisdiction.
Collection of other information
When you visit Divide’s website, some of the information that is collected about your visit is not personal information, because it does not reveal your identity.
A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies used by Divide may identify individual users who log into our websites.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you.
Security of personal and financial information
Divide will take reasonable steps to keep your personal information confidential and to protect it from misuse, unauthorised access, modification or disclosure. We have implemented and will maintain current standards of technology and operational security to protect your personal information from any such interference.
We hold personal information in a number of ways, including in electronic databases, email contact lists, and in paper files held in drawers and cabinets, locked where appropriate. Paper files may also be archived in boxes and stored offsite in secure facilities. Divide’s policy is to take reasonable steps to:
- make sure that the personal information that Divide collects, uses and discloses is accurate, up to date and complete and (in the case of use and disclosure) relevant; and
- protect the personal information that Divide holds from misuse, interference and loss and from unauthorised access, modification or disclosure.
The steps we take to secure the personal information we hold include security (such as encryption, firewalls, anti-virus software and login and password protection), secure office access, and training and workplace policies.
If you are concerned about sending your information over the internet, you can contact Divide and send information by telephone or post.
You can also help to protect the privacy of your personal information by keeping passwords secret and by ensuring that you log out of the website when you have finished using it. In addition, if you become aware of any security breach, please let us know as soon as possible.
Where you have consented to receiving direct marketing communications from Divide, your consent will remain current until you advise us otherwise. However, you can opt out at any time, in the following ways:
- send a letter to; Divide – Simple Separation, PO Box 1259, Toowong DC, QLD, 4066;
- or send an email to firstname.lastname@example.org ;
- advise us, if you receive a marketing call, that you no longer wish to receive these calls; and
- using social media opt out options from future communications.
Complaints and the complaint process
Divide will endeavour to answer your complaint within 7 working days.
Should further information be required from you, in most cases, we expect that complaints will be investigated and a response provided within 30 days of receipt of such further information. If the matter is more complex and our investigation may take longer, we will write and let you know, including letting you know when we expect to provide our response.
Our response will set out:
- What action, if any, Divide will take to rectify the situation.
If you are unhappy with Divide’s response, you can refer your complaint to the Office of the Australian Information Commissioner.
If you have any questions about privacy-related issues please contact Divide on +61 (07) 3367-5380
Review of policy