This Policy describes how the Partners in Performance Group being Partners in Performance International Pty Ltd (“PIP”) and its related bodies corporate globally collects, uses, holds and discloses the personal information it holds about its clients, potential clients, employees, contractors and others.
Laws and rules regarding the use of personal information may vary by jurisdiction. PIP Group members comply with applicable laws and rules in the jurisdiction where they are located or where the personal information is provided or received.
In Australia, PIP is bound by the Australian Privacy Principles (APPs) contained in the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) (“the Act”). The APPs are designed to protect the confidentiality of information and the privacy of individuals by regulating the way personal information is managed and to ensure that it is managed in an open and transparent way. “Personal information” is information or an opinion relating to an individual which can be used to identify that individual.
Why does PIP collect personal information?
PIP collects personal information in order to understand and meet its clients’ needs, conduct its business, provide and market its services and to meet its legal obligations.
About whom does PIP collect personal information?
The type of information PIP may collect and hold includes (but is not limited to) personal information about:
- Clients, business associates and potential clients and their employees
- Suppliers and their employees
- Prospective employees, employees, contractors; and
- Other people who come into contact with the PIP Group.
What types of personal information does PIP collect?
In general, the type of personal information PIP collects and holds includes (but is not limited to): names, addresses, contact details, employment history, occupations, educational qualifications and other information which assists it in understanding and meeting its clients’ needs, conduct its business, provide and market its services and meet its legal obligations.
How does PIP collect personal information?
PIP will generally collect personal information by way of forms filled out by people, interviews, business cards, telephone conversations, emails, through business activities and from third parties.
Personal information provided by other people
In some circumstances PIP may be provided with personal information about an individual from a third party, for example, a report provided by a medical professional or a referral from another person or entity.
How might PIP use and disclose personal information?
PIP may use or disclose your personal information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Act.
In general, PIP uses and discloses your personal information for the following purposes:
- Understand and meet its clients’ needs
- Conduct its business
- Manage and develop its employees
- Provide and market its services
- Communicate with you
- Purchase from you; and
- Meet its legal obligations.
To whom might PIP disclose your personal information?
PIP might disclose your personal information to:
- Other members of the PIP Group
- Other companies or individuals, in or outside Australia who assist PIP in providing services or who perform functions on their behalf
- Anyone else to whom you authorise them to disclose it.
PIP also collects personal information from these organisations and individuals, and deal with that information in accordance with this Policy.
Sending information overseas
PIP may disclose your personal information to other members of the PIP Group located outside of Australia when consented to by you or otherwise authorised under the Act. The PIP Group members will treat personal information collected in Australia and sent to them in accordance with the requirements of the APPs and any applicable local laws relating to privacy.
A current list of countries in which PIP Group members are located or operating can be obtained from the Privacy Officer upon request. Contact details are set out below.
Some of the third parties with whom we share personal information may be located outside your country or the country from which the data was provided (collectively the “jurisdiction of origin”). While such third parties will often be subject to privacy and confidentiality obligations, you accept that where lawful such obligations may differ from and be less stringent than the requirements of the privacy laws of the jurisdiction of origin.
Some personal information which PIP collects is sensitive information. “Sensitive information” includes information or an opinion about a person’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, tax file numbers, sexual preferences or practices, criminal record or health information.
Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or where certain other limited circumstances apply (e.g. where required by law).
Storage of personal information
Personal information that has been collected by PIP is stored on on-site secure physical servers or by on-line cloud-based third party data storage providers. All access to data is password protected, and PIP employs the use of Rights Management Services (RMS) in some circumstances.
Management of personal information
PIP endeavours to ensure that the personal information they hold is accurate, complete and up-to-date. It encourages you to contact PIP in order to update any personal information it holds about you. Contact details are set out below.
You have the ability to request access to your personal information and to request it correction. Subject to the exceptions set out in the Act, you may seek access to the personal information which PIP holds about you by contacting the PIP Privacy Officer.
PIP will require you to verify your identity and to specify what information you require. A fee may be charged for providing access. PIP will advise you of the likely cost in advance.
Updates to this Policy
This Policy will be review from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The most current version of this Policy is located at www.pipint.com and can be obtained by contacting the PIP Privacy Officer.
If you have any questions about privacy-related issues, please contact the PIP Privacy Officer by email to email@example.com or by telephone +61 2 9321 0800. Any complaint about PIP’s handling of personal information should be made in writing to PIP’S Privacy Officer who will respond within 30 days. If the complaint remains unresolved, you can refer it to the Office of the Australian Information Commissioner.