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PRIVACY POLICY & PROCEDURES

OVERVIEW

Sunpork Farms (the Group) recognises that it is both necessary and required by law for it to store a variety of records of factual information about Customers and other persons. The Group recognises its responsibilities and obligations under the Privacy Act 1988 (the Act) and as outlined in the Australian Privacy Principles (APPs).

DEFINITIONS

Sensitive Information

Sensitive information is defined as any of the following:

Personal Information

Personal information is broadly defined as any information or opinion that can identify a person. However, in accordance with the Act, employee records or an act or practice engaged in directly related to a current or former employment relationship are exempt.

Authorised Access to Records

Authorised access is as that which is required for work-related purposes. For example, reaching selection decisions or providing vocational guidance.

POLICY

The Group accepts that the general principles of confidentiality and privacy apply to the use and availability of its records. Where information about a person includes personal details as defined by the Privacy Act 1988 (as amended) (Cth), that person expects that the Group will maintain confidentiality, except where disclosure is required for legitimate and legal purposes.

PROCEDURES

Collection

Personal information will only be collected where the information is necessary for one or more of its functions or activities.

The personal information we collect directly about you may include (but may not be limited to):

Sensitive information may be collected about you which may include (but is not limited to) health information and criminal background checks. We will not collect sensitive information unless the individual has consented, it is required by law or a collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual, where the subject of the information is physically or legally incapable of giving consent. We will only collect personal information in a way that is fair, lawful and not intrusive.

Generally personal information is collected directly from individuals. However, where personal information is collected by a third party, reasonable steps will be taken to ensure that the person providing the personal information is made aware of:

These obligations will be met through the use of appropriate forms and training of staff.

Use and Disclosure

Use or disclosure of any information will only be for the following reasons:

An individual’s written consent for disclosure of his/her information will be obtained generally.

We will endeavour to receive an individual’s consent for disclosure of his/her information by way of writing. If necessary, verbal consent will be accepted and a file note or database record will be taken.

Personal information is not generally transmitted to an overseas third party, however, in such an unlikely event, we will only transfer personal information to third parties subject to confidentiality provisions as we deem appropriate.

Direct Marketing

Your personal information may be used or distributed for direct marketing in specified circumstances. We may contact you via email or other means in order to provide you with updated information about the company, details of products, or other relevant information.

If you prefer not to receive such information, please contact us and put “unsubscribe” in the subject line together with the name of the publication you wish to unsubscribe from. Our email communications will also include an “unsubscribe” link.

Storage

We may store your files in hard copy or electronically in our IT systems, which may include Australian-based cloud servers.

Reasonable steps will be taken to protect personal information from misuse, loss and unauthorised access modification or disclosure.

Reasonable steps will be taken to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed.

The following guidelines will be followed for the storage of information:

Employees and other persons who are directly involved with the activities of the Group are required to consent to applicable confidentiality obligations in writing.

Access and Correction

Reasonable steps will be taken to make sure that the personal information collected, used or disclosed is accurate, complete and up-to-date.

The Group acknowledges that it must give an individual access to their personal information on request. We may refuse access where the Act allows us to do so, which includes (but is not limited to) where:

Where providing access would reveal evaluative information in connection with a commercially sensitive decision-making process, an individual explanation for the commercially sensitive decision rather than direct access to the information may instead be given.

If the individual is able to establish that the information is not accurate, complete or up-to-date, the Group will take reasonable steps to correct the information so that it is accurate, complete and up-to-date.

Where an individual and the Group disagree about whether the information is accurate, complete and up-to-date, and an individual asks the Group to attach a statement with the information that identifies the information to be inaccurate, incomplete or not up-to-date, reasonable steps will be taken to do so. Reasons will be provided for a denial of access or a refusal to correct personal information.

All inquiries regarding access or correction in accordance with this policy are to be communicated, preferably in writing, to the Chief Financial Officer. The relevant contact details are set out under the heading “Contact us”.

Identifiers of Individuals

Generally, the Group will not adapt, use or disclose an identifier that has been assigned by a Commonwealth Government agency.

Handling of Sensitive Information

Sensitive information will not be collected unless:

COMPLAINTS PROCESS

If you have any questions or concerns about this Policy or if you believe we have not complied with this Policy or the Act, please contact the Chief Financial Officer in the first instance. The relevant contact details are set out under the heading “Contact Us”. The Chief Financial Officer will investigate your complaint and determine whether a breach has occurred and what action, if any, to take. Your complaint should be made in writing to the company and we aim to respond in a timely and efficient manner, usually within 30 days.

If you remain dissatisfied, you can also make a formal complaint to the Office of the Australian Information Commissioner (OAIC).

CHANGES TO THIS POLICY

The date on which this Privacy Policy was last updated is set out below. By using our website, or otherwise continuing to deal with us, you accept this Privacy Policy as it applies from time to time.

CONTACT US

If you have any questions or concerns, or you would like to gain access to or seek correction of your personal information, please direct your queries to the Chief Financial Officer on 07 3908 1475 or PO Box 7276, Hemmant QLD 4174.

REVIEW

This policy will be reviewed every 2 years to ensure it continues to meet legislative requirements.

REFERENCES

The Privacy Act 1988