Genetiqe Pty Ltd trading as Smartfish Creative is committed to protecting your privacy and ensuring that all officers, employees and subcontractors are aware of and understand our obligations under the Privacy Act 1988 (Cth) (Act).
We will achieve this through the provision of training and through maintaining and implementing internal policies and procedures to prevent personal information from being collected, used, disclosed, retained, accessed or disposed of improperly. This policy applies to all your dealings with us, whether in person, by phone, email, on the internet, or through any other means.
The purpose of this Policy is to:
- Give you a better and more complete understanding of the kinds of personal information we collect and hold;
- Clearly and concisely communicate how and when we collect, disclose, use, store and otherwise handle personal information;
- Inform you about the purposes for which we collect, hold, use and disclose personal information;
- Provide you with information about how you may access your personal information, and seek correction of your personal information;
- Provide you with information about how you may make a complaint, and how we will deal with any such complaint;
- Advise you of the circumstances in which we are likely to disclose personal information to overseas recipients; and
- Enhance the transparency of our operations.
For the purposes of this policy, the following terms shall have the following meanings, as attributed to them by section 6 of the Act:
Sensitive information means:
- Information or an opinion about an individual’s:
- Racial or ethnic origin; or
- Political opinions; or
- Membership of a political association; or
- Religious beliefs or affiliations; or
- Philosophical beliefs; or
- Membership of a professional or trade association; or
- Membership of a trade union; or
- Sexual orientation or practices; or
- Criminal record
Collection of Personal Information
Any time you talk to us we will ask for any personal information you choose to provide to us, in order to provide the service you requested. We will not collect your personal information unless it is reasonably necessary for, or directly related to, one or more of the services we provide or functions we carry out.
The types of personal information we generally collect include but is not limited to:
- Email address.
- Home telephone number.
- Work telephone number.
- Mobile telephone number.
- Your occupation and business address.
We will only collect sensitive information in circumstances where:
- It is reasonably necessary for one or more of the services we provide or functions we carry out; and
- You consent to the collection of the information; or
- We are required or authorised by law to collect the sensitive information.
If it is reasonable and practicable to do so, we will collect personal information directly from you. For example, we may collect information when you fill out a form, provide it to us when you make a purchase, subscribe to our mailing list, participate in a promotion, etc.
We’ll collect information from your website if you give us permission to do so. Sometimes we’ll collect personal information from a third-party or publicly available source. For example, we may need to collect personal information from your company’s website. If we receive personal information that we didn’t solicit, we’ll determine as soon as reasonably practicable whether we could have lawfully collected that information as part of our functions or activities.
Use and Disclosure of Personal Information
Personal information collected by Smartfish Creative will ordinarily be used for the following purposes:
- Client and business relationship management.
- Marketing of products and services to you or your customers.
We will only use and disclose personal information for the primary purpose for which it was initially collected, or for purposes which are directly related to one of our functions or activities.
- You have consented.
- You would reasonably expect, or you have been told, that information of that kind is usually passed to those individuals, bodies or agencies.
- It is otherwise required or authorised by law.
- It is reasonably necessary for enforcement related activities conducted by, or on behalf of, an enforcement body (e.g. Police, ASIC, Immigration Department).
Many Australian business services like Smartfish Creative may rely on third party suppliers or contractors to provide specialised services like website hosting, data storage, or cloud computing. They won’t use or share any of your government related identifiers unless they are required or authorized to do so by law or by a court or tribunal order, or in order to fulfill their obligations to a state or territory authority. If personal information is provided to these suppliers and contractors in order to enable them to perform the agreed tasks, we will make every effort to ensure that the supplier or contractor handles the personal information in accordance with the Act and the Australian Privacy Principles. We will also require all suppliers and contractors to provide privacy undertakings and enter into confidentiality agreements.
Marketing our products and services
Smartfish Creative may use or disclose your personal information to let you know about products and services in which you may be interested. You can contact us at any time if you no longer wish us to market our products and services to you.
Accuracy of Personal Information
Smartfish Creative will take reasonable steps to ensure that all personal information it collects, uses or discloses is accurate, complete and up-to-date. If you believe that your personal information is not accurate, complete or up-to-date, please contact us. We will make reasonable efforts to correct or remove your personal information.
Your personal information may be stored in hard copy documents or electronically. Smartfish Creative is committed to keeping your personal information secure and safe. Some of the ways we do this are:
- Requiring employees and contractors to enter into training and confidentiality agreements
- Secure hard copy document storage (i.e. storing hard copy documents in locked filing cabinets)
- Security measures for access to our computer systems
- Providing a discreet environment for confidential discussions
- Access control for our buildings
- Security measures for our websites (see the Your Privacy on the Internet section from information)
The security of your information will be reviewed regularly, and updated as necessary. In addition, we will review your personal information and sensitive information and ensure that information that is no longer needed for a purpose for which it was originally collected is destroyed or de-identified.
Your Privacy on the Internet
Our website takes precautions to protect your information. For example, we use firewalls and data encryption. You can browse to other websites through links on our website. Those other websites are not subject to our privacy standards, policies and procedures. To ensure your personal information is secure, you should contact or review those websites directly.
Access to Personal Information
You may request access to your personal information that Smartfish Creative holds about you (see the Contacting Us section for more information). We will acknowledge your request within five business days of the request being made. We will usually grant you access to your information within three business days of our acknowledgment, but we can’t guarantee this, especially where your request involves complex considerations or voluminous photocopying or scanning. We will let you know which timeframe applies to your request and if any delays are anticipated. We will need you to verify your identity before access is granted.While we cannot and do not charge a “application fee” for you applying to access your personal information, we may charge a fee for actually giving you access to your personal information in your preferred format (where reasonable and possible), which will cover our costs involved in locating and collating information as well as reproduction costs.
We always make every effort to ensure that all information provided to you is accurate, complete and up-to-date. If you discover that the information is inaccurate, incomplete or out-of-date, please let us know by contacting us (see the Contacting Us section for more information).
If you request access to your personal information, or if you request that we correct your personal information, we will allow access or make the correction unless we consider that there is a sound reason to withhold the information, or not make the correction.Under the Act, we may refuse to grant access to personal information if:
- We believe that granting access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety.
- Granting access would have an unreasonable impact upon the privacy of other individuals.
- Denial of access is required or authorised by law or by a Court or Tribunal order.
- Giving access would be unlawful.
- The request for access is frivolous or vexatious.
- Legal proceedings are underway or anticipated and the information would not be accessible by way of the discovery process in those proceedings.
- Giving access would reveal our intentions in relation to negotiations between us and you in such a way as to prejudice those negotiations.
- Giving access is likely to prejudice enforcement related activities conducted by, or on behalf of, an enforcement body.
- Giving access is likely to prejudice action being taken or to be taken with respect to suspected unlawful activity or serious misconduct relating to our functions or activities.
- Giving access would reveal information in connection with a commercially sensitive decision-making process.
If we don’t agree to give you access to your personal information or to correct your personal information, you’ll have the opportunity to let us know why, and we will explain to you in writing what we can do to fix the issue.
You may contact us by mail, or email as follows:
PO Box 6039 Maroochydore QLD 4558
If you have a concern or complaint about any personal information we hold about you, please send an email to the address in the contact details below, or contact us by phone or post. We will acknowledge receipt of a complaint within 2 business days. We will investigate the complaint and attempt to resolve it within 20 business days after the complaint was received. If it is anticipated that this timeframe is not achievable, we will contact you to provide an estimate of how long it will take to investigate and respond to the complaint.We will keep the complainant informed of any progress made.If you consider that we have not adequately dealt with a complaint, you may complain to the Office of the Australian Information Commissioner on the below details:
GPO Box 5218 SYDNEY NSW 2001
1300 363 992
This policy is to be reviewed as follows:
- Annually as a minimum.
- Following an information security incident.
- Following significant changes to our systems.
- Following changes to the relevant State and Commonwealth legislation
Reviews are to determine if there has been any change in the policy, its appropriateness, and to assess the compliance of the policy taking into consideration new corporate, system and compliance requirements.