Document:  LDT-POL-005

Revision Date:  8/12/2017

PRIVACY POLICY

  1. Overview

This Privacy Policy (Policy) applies to Sanpoint Pty Ltd ABN 62 052 314 682, trading as LD TOTAL, (referred to as LD TOTAL, ‘we’, ‘our’, ‘us’ in this policy).  This Policy sets out how we handle personal information that can identify you, including sensitive information.

This Policy addresses the kinds of personal information that we collect, how we collect and hold personal information, how we store personal information, why we collect, hold, use and disclose personal information, and how you can access and seek correction of your personal information.

The Policy also details how you can contact us if you have any questions about this Policy or if you would like to lodge a complaint with us regarding our compliance with the Privacy Act, or this Policy.

We are committed to protecting your privacy and ensuring that our Privacy Policy complies with the Australian Privacy Principles set out in the Privacy Act 1988.  We may change our Privacy Policy from time to time.  The most current version is available on our website www.ldtotal.com.au. A copy of our Privacy Policy is also available by contacting our Privacy Officer using the contact details set out below.  We will take all reasonable steps to provide you with a copy in the form that you have requested.

By providing information to us after viewing this Privacy Policy you acknowledge and consent to our collection, use, and disclosure, of your personal information as set out in this Privacy Policy.

  1. Kinds of personal information we collect

‘Personal Information’ refers to information or an opinion (whether true or not) about an individual in which an individual’s identity can be ascertained.

LD TOTAL will only collect personal information for a lawful purpose that is directly related or reasonably necessary for the purposes of our business.  The personal information we collect will depend on the nature of your interaction with us and the circumstances of the collection.

The kinds of personal information we collect and hold, may include any of the following:

  • Your name, address (residential or business), and contact details (e.g. phone and email)
  • Information about your personal circumstances (e.g. marital status, age, gender)
  • Information about your identity (e.g. date of birth, passport details, visa details, driver’s licence)
  • Information about your financial affairs (e.g. payment details, bank account details and superannuation)
  • Information about your workers compensation claims, results of drug and alcohol testing, and in some cases, health (limited)
  • Information about your employment (e.g. work history, reference checks, remuneration, occupation and employer)
  • Information about your background (e.g. qualifications, career history, professional memberships and affiliations)
  • Records of communications and interactions with us
  • Records relating to your engagement, conduct, hours worked, and payment as a contractor
  • Credit card and debit card information
  • Your ABN and government related identifiers
  • Information about the way you use our website
  • Your Internet Protocol (IP) address

In carrying out our functions and activities we may collect personal information that is sensitive information.  ‘Sensitive Information’ is a special category of Personal Information and includes information about your health, race ethnic origin, religious beliefs or criminal record.

LD TOTAL will only collect sensitive information with your consent and will not disclose your sensitive information without your consent, unless there is a need to disclose such information in accordance with the Privacy Act or to comply with any Australian law or court/tribunal order.  LD TOTAL may also collect sensitive information where authorised to do so for the purposes of human resource management and taking appropriate action against suspected unlawful activity or serious misconduct.

From time to time we receive personal information that is not requested by us or reasonably necessary for our business purposes.  Where unsolicited information is received from us we will, as soon as is practicable, destroy or permanently de-identify this information, unless it is unlawful for us to do so

  1. How we collect and hold personal information

LD TOTAL will collect personal information directly from you where it is lawful and reasonable and practicable to do so.  This is primarily done through forms, other electronic or paper correspondence where you have corresponded with or registered your details with us, entered into an arrangement with us or provided feedback to us.  Personal information may also be collected from third parties, such as recruitment agencies and Australian Government agencies.

We may collect your personal information if you:

  • Submit information through our website
  • Visit our website (use of ‘cookies’)
  • Interact with us on our social media platforms
  • Communicate with us orally, by telephone, in writing (mail and email), SMS and in person
  • Attend a face to face meeting or event conducted by us, our Contractors or Clients
  • Submit an application, quote, purchase order and/or service request to us
  • In the course of supplying products and services to you, or through our other dealings with you

Where we outsource our functions to third party service providers (including Sub-contractors), those providers may also collect personal information from you on our behalf.

You do not have to give us your personal information.  You can advise us if you wish to remain anonymous or use a pseudonym when dealing with us.  However, if you do not provide us with your personal information or identify yourself, it may impact on our ability to provide you with our services, process or assess your application, resolve a dispute, finalise payments, or otherwise do business with you or an entity you are connected with.

  1. How we store personal information

We hold your personal information in paper-based form, electronic records, including cloud computing, at our own secure premises.

We are committed to keeping your personal information safe, confidential and secure.  All reasonable steps are taken to ensure that the personal information that we hold is protected from loss, interference, misuse, unauthorised access, modification, disclosure, and corruption by computer viruses.

We use physical, electronic and procedural safeguards to do this.  We also train our employees on privacy matters as appropriate, and seek to limit access to personal information to those staff members, and third parties who need to know that information.

When we no longer require your personal information, we will take reasonable steps to archive, destroy or permanently de-identify that information.  Document retention and destruction comply with relevant legislation requirements.

  1. Why we collect, hold, use and disclose personal information

We use and disclose your personal information for the purposes disclosed to you at the time it is collected, or to which you have consented, or as otherwise set out in this Policy.

We collect, use and disclose personal information that is reasonably necessary for our business purposes and as required by law.

Those purposes may include:

  • Supplying our customers with products and services
  • Managing the supply of our products and services (including processing invoices, receipts and payments)
  • Responding to enquiries
  • Assessing job applications or expressions of interests from potential Sub-contractors and managing those relationships
  • Performing our employment and personnel functions in relation to our employees and Sub-contractors
  • Performing legislative and administrative functions
  • Handling of complaints
  • Ensuring safety on our worksites
  • Management of correspondence with the public
  • Contract management

LD TOTAL is unlikely to disclose your personal information to overseas recipients.

  1. How I can access my personal information and seek correction of it?

LD TOTAL will take all reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete, kept up to date, not misleading and is relevant.

Under the Privacy Act you have the right to access the personal information we hold about you and request that it be updated or corrected.  To ensure confidentiality, we will only pass details onto you where we are satisfied that that the information relates to you.  Please contact our Privacy Officer using the contact details set out below.

We will usually respond to reasonable requests for personal information and correction of personal information within 30 days of receiving the request in writing.  Where possible we will give you access to your requested personal information in the way that you have requested it.  If we refuse your request, we will give you notice in writing, setting out the reasons for our refusal and the process for you to complain about the refusal.

Factors that may affect your right to access include:

  • We reasonably believe that access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety
  • Access would have an unreasonable impact on the privacy of other individuals
  • The request for access is frivolous or vexatious
  • The information relates to existing or anticipated legal proceedings between you and us, and would not be accessible by the process of discovery in those proceedings
  • Access would prejudice negotiations with you
  • Access would be unlawful
  • Denying access is required or authorised under Australian law or a court/tribunal order
  • Access would prejudice appropriate action being taken in relation to serious misconduct, unlawful activity or enforcement related activities
  • The information relates to commercially sensitive decision-making process
  1. Who can I contact if I have a complaint or question?

If you have any questions regarding our Privacy Policy, a complaint regarding the way we handle your personal information, or you believe that we have not complied with our obligations under the Privacy Act and this Policy, you can make a complaint.

All complaints should be made in writing to:

Mail:
The Privacy Officer
LD TOTAL
172 Burswood Road
Burswood WA 6100

Email:
privacy@ldtotal.com.au

LD TOTAL will review and investigate complaints as soon as possible, usually within 30 days of receiving the complaint.  If you are not satisfied with the way your complaint has been handled by us, you can refer your complaint to the Office of the Australian Information Commissioner (OAIC).  Details can be found below.  Please note that the Information Commissioner may not investigate your complaint if you have not written to us in the first instance and given us a reasonable time frame to resolve your complaint.

Office of the Australian Information Commissioner (OAIC)

Telephone:   1300 363 992

Email:             enquiries@oaic.gov.au

Mail:               GPO Box 5218, Sydney NSW 2001 or GPO Box 2999, Canberra ACT 2601