CODESAFE PTY LTD – PRIVACY POLICY

Your privacy is important

This statement outlines the policy of CodeSafe Pty Ltd (“CodeSafe”) on how it uses and manages personal information provided to or collected by it.

CodeSafe is bound by, and compliant with, the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (“the Privacy Act”).

CodeSafe may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to CodeSafe’s operations and practices, and to make sure it remains appropriate to the changing CodeSafe environment.

 

What kinds of personal information does CodeSafe collect and how does CodeSafe collect it?

CodeSafe primarily collects and holds personal information about users of the CodeSafe QIN software platform and mobile application (“the Platform/App”).

Personal information means any information about an identified or reasonably identifiable individual.

If you are a user of the Platform/App, CodeSafe may collect your personal information:

  • when you are completing the registration process for the Platform/App;
  • when you are populating your user profile or other electronic forms on the Platform/App;
  • when conducting customer satisfaction and marketing research surveys;
  • in the course of giving you user support; and
  • for other purposes related to the provision of the Platform/App.

In these circumstances, the kinds of personal information that CodeSafe may collect and hold include:

  • your name and email address; and
  • if you choose to provide it:
    • other contact details, such as postal address and telephone number;
    • emergency contact details;
    • medical details; and
    • professional details    such    as    your    level    of    induction,     licences    and qualifications.

In addition, CodeSafe may automatically collect and hold data about users of the Platform/App which could be classified as personal information, such as location data, information about how you use the Platform/App (including the devices and networks you use to access it) and cookies.

CodeSafe may also collect and hold personal information about employees and staff of CodeSafe’s clients (i.e. organisations who use the Platform/App for the purpose of their business). This information generally consists of basic contact details such as the person’s name, role, email address, business postal address and telephone number.

CodeSafe will only collect personal information about an individual directly from that individual, unless it is unreasonable or impracticable to do so.

CodeSafe will only collect personal information which is defined as sensitive information under the Privacy Act:

  • where you consent and the collection is reasonably necessary for CodeSafe’s functions or activities (for example, where you enter medical details into the Platform/App); or
  • where the collection is authorised by

You have the right to seek to deal with us anonymously or using a pseudonym. However, in almost every circumstance it will not be practicable for us to deal with you or provide you with any services – except for responding to the most general enquiries – unless you  identify yourself.

 

How does CodeSafe use and disclose personal information?

CodeSafe collects, holds, uses and discloses personal information:

  • for the primary purpose of providing the Platform/App and associated services to users and clients; and
  • for secondary purposes:
    • that are related (or, in the case of sensitive information, directly related) to the primary purpose and reasonably expected; or
  • to which you have

CodeSafe will only use and disclose information which may be classified as a government related identifier (such as qualification and driver’s licence numbers) if it is reasonably necessary to verify your identity for the purposes of the Platform/App.

 

Job applicants, staff members and contractors

In relation to personal information of job applicants, staff members and contractors, CodeSafe’s primary purpose of collection is to assess and (if successful) to engage the job applicant, staff member or contractor, as the case may be.

The purposes for which CodeSafe uses personal information of job applicants, staff members and contractors include:

  • administering the individual’s employment or contract, as the case may be;
  • insurance purposes;
  • engaging in marketing for CodeSafe; and
  • satisfying CodeSafe’s legal

Where CodeSafe receives unsolicited job applications, these will usually be dealt with in accordance with the unsolicited personal information requirements of the Privacy Act.

 

Direct marketing 

CodeSafe may use your personal information in order to conduct direct marketing of CodeSafe goods and services where:

  • you have provided that information; and
  • you have consented to, or are likely to expect, direct

In each direct marketing communication, you will be given the option to opt out.

CodeSafe will not disclose your personal information for the purpose of direct marketing by third parties.

 

Who might CodeSafe disclose personal information to?

If you are a user of the Platform/App, CodeSafe may disclose your personal information to:

  • CodeSafe’s clients, to the extent that your personal information is related to the provision of the Platform/App to that client;
  • government organisations collecting information; and
  • CodeSafe ‘Super-Users’ who are subject to non-disclosure

If you are an employee or staff member of a CodeSafe client, CodeSafe may disclose your personal information to a third party for the purpose of assisting with client queries.

CodeSafe will not disclose your personal information to overseas recipients.

 

Management and security of personal information

CodeSafe has in place steps to protect the personal information CodeSafe holds from misuse, interference, loss, unauthorised access, modification or disclosure by use of various methods including:

  • storing personal information in a fully encrypted database; and
  • limiting access to the database to those who have signed non-disclosure agreements.

 

Updating personal information

CodeSafe endeavours to ensure that the personal information it holds is accurate, complete and up-to-date.

An individual may seek to update their personal information held by CodeSafe by updating their user profile on the Platform/App or by contacting the CodeSafe Privacy Officer at any time.

The Australian Privacy Principles require CodeSafe not to store personal information longer than necessary.

Under the Privacy Act, an individual has the right to obtain access to any personal information which CodeSafe holds about them and to advise CodeSafe of any perceived inaccuracy. There are some exceptions to this right set out in the applicable legislation.

To make a request to access any information CodeSafe holds about you, please contact  the Privacy Officer at privacy@codesafe.com.au.

CodeSafe may require you to verify your identity and specify what information you require. Although no fee will be charged for accessing your personal information or making a correction, CodeSafe may charge a fee to retrieve and copy any material. If the information sought is extensive, CodeSafe will advise the likely cost in advance.

 

How long will CodeSafe keep my personal information?

If CodeSafe no longer requires your personal information, it will be de-identified or destroyed. It may, however, be kept for statistical, research and marketing purposes where you have consented to that in writing with us.

 

Enquiries and privacy complaints

If you would like further information about the way CodeSafe manages the personal information it holds, please contact the Privacy Officer.

If you have any concerns, complaints or if you think there has been a breach of privacy, then also please contact the Privacy Officer who will first speak to you usually over the phone. If we then have not dealt satisfactorily with your concerns, we will meet with you to discuss further. If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner via: