Privacy laws that apply to RP Dean & Co
RP Dean & Co is required to comply with the Privacy Act 1988 (Cth) and is bound by the Australian Privacy Principles (‘APPs’) set out in that Act. The APPs establish minimum standards for the collection, use, disclosure and handling of personal information of an individual. If you are not an individual, the APPs do not apply to information about you as that is not ‘personal information’.
They apply to personal information in any form, including electronic and digital form. The APPs can be accessed at the website of the office of the Australian Information Commissioner: www.privacy.gov.au.
RP Dean & Co is also subject to other laws relating to the protection of personal information. RP Dean & Co may also be subject to privacy obligations under the Telecommunications Act 1997 (Cth) and the Telecommunications (Interception and Access) Act 1979 (Cth) in connection with the supply of telecommunications services.
‘Privacy Law’ refers to any legislative or other legal requirement that applies to RP Dean & Co’s collection, use, disclosure or handling of personal information.
‘Personal information’ means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in material form or not. Personal information includes sensitive information.
‘Sensitive information’ means personal information about an individual’s racial or ethnic origin, political opinions or memberships, religious beliefs or affiliations, philosophical beliefs, professional or trade association/union memberships, sexual preferences and practices or criminal record.
Why does RP Dean & Co collect personal information?
- RP Dean & Co collects personal information in order to:
provide and manage the products and services we provide, including for billing and credit control purposes;
- inform customers about changes and improvements in RP Dean & Co’s products and services;
- market RP Dean & Co’s products and services to current and prospective customers;
- comply with our legal obligations. RP Dean & Co needs to be able to collect personal information for most of its business activities, although the information we require depends on the particular circumstances. If we are unable to collect the personal information we need, we may be unable to meet the expectations of our customers or provide the products and services they wish to receive.
Whose personal information does RP Dean & Co collect?
RP Dean & Co collects or holds personal information about individuals who are:
- Prospective customers. This includes people we think may be interested in our products and services as well as people who have expressed interest in obtaining or learning more about those products and services.
- Current customers. This includes people who purchase RP Dean & Co’s products or services or who hold an account with RP Dean & Co.
- Past customers. These are people who have purchased RP Dean & Co products or services but do not currently hold any active RP Dean & Co account.
- Representatives of customers. This includes people who are or have been Representatives of prospective, current or past customers, such as directors (for credit checking purposes) and technical, operational or billing contacts of the customer.
- Customers of customers. This includes information about individuals to whom telecommunications services are resupplied by RP Dean & Co’s customers, such as the ultimate end user of a telecommunications service.
RP Dean & Co may treat current and past customers as prospective customers for other RP Dean & Co products and services.
As indicated, RP Dean & Co may collect personal information about individuals employed, engaged or appointed by a customer. For example, RP Dean & Co may collect personal information about nominated or authorised representatives, the holder of a credit card that is used to pay a customer’s account, a person who acts as a secondary account holder, a person who acts as guarantor for a credit contract, the directors of the customer, the landlord of a tenanted property or the nominated contact on an account.
Can you deal with RP Dean & Co without identifying yourself?
In some limited situations customers and other individuals may be able to deal with RP Dean & Co anonymously or using a pseudonym. For example, if you make a general inquiry or want to make a complaint or log a service fault unless the inquiry or complaint relates to a particular account or service. However, if you do not wish to be identified we may not be able to provide the information or assistance you require.
What personal information does RP Dean & Co usually collect?
RP Dean & Co, by nature of the products and services it provides, collects a wide range of personal information about its customers, but the type and amount of information collected depends on the particular business context. However, RP Dean & Co seeks at all times to ensure that it only collects the personal information that is necessary for the purposes of its business activities.
RP Dean & Co needs to collect basic identifying and contact information for all customers, including prospective customers, as well as for customers of our customers (such as the end users of a telecommunications service). This will usually include name, date of birth, email address, telephone number(s) and residential address. For corporate and business customers, RP Dean & Co collects information about nominated contacts, including name and title or position, date of birth, telephone number(s), trade references, licence details andÂ email and business addresses.
When you become, or apply to become, a RP Dean & Co customer, RP Dean & Co collects a range of other information that that it needs to assess a customer’s application and manage your account(s). This includes:
- Proof of identity information, including passport number, driver licence number or other government identifiers of the customer or a Representative. We need may this information to verify and ensure our customer records are accurate and up-to-date.
- Financial and credit information, including credit history, employment history, remuneration details, bank account and credit card information, information about assets and income and details of relevant court judgments and bankruptcies. We need this information to assess creditworthiness and financial suitability of current and prospective customers.
- We also collect information about the way RP Dean & Co’s products and services are consumed. This includes information about:
- product sales
- responses to offers made and/or promotions run by RP Dean & Co or its affiliates; payment patterns and history; and
- inquiries and complaints.
How does RP Dean & Co collect personal information?
We collect personal information by various means and via various media, depending on the particular business context. We collect personal information about individuals both directly and indirectly. In order to collect this information:
- We may when you make an inquiry with RP Dean & Co, including but not limited to fault tickets and escalations;
- through outbound and inbound sales activities;
- through RP Dean & Co’s websites, or websites operated by RP Dean & Co’s affiliates;
- through social media platforms such as Twitter and Facebook; and by capturing or accessing, directly or indirectly, information which is carried, or has been carried, by a carrier or carriage service provider.
- When you become or apply to become a customer, in addition to collecting personal information directly from you, we may also collect information about you and your Representatives from our agents and affiliates, credit reporting agencies,
RP Dean & Co receives unsolicited personal information from time to time. In accordance with its obligations under Privacy Law, RP Dean & Co will decide whether it would have been permitted to solicit and collect that information and if it would not have been, will destroy or de-identify the information (provided it is lawful to do so).
What information will RP Dean & Co give you when it collects personal information?
When you deal with us on the telephone, this information is given to you by the operator or via a recorded message. If we collect personal information about you from a third party, we take reasonable steps to ensure you receive the information we are required to provide. However, we may do this by requiring the third party to provide the information, rather than us providing the information to you directly.
We may also include information about our collection of personal information in welcome packs, customer account statements, update bulletins, notices and other documents we give to our customers.
RP Dean & Coâ€™s use and disclosure of personal information
Where RP Dean & Co collect personal information for a particular purpose, it may use and disclose the information for that purpose or another purpose that is related to that purpose (or that is directly related to that purpose in the case of sensitive information).
Personal information collected for the purpose of establishing or managing an account may also be used for the purpose marketing of other RP Dean & Co products and services. RP Dean & Co may contact prospective, current or past customers about products and services (including products not related to a product or service previously supplied). For example if we currently provide you with a telephone service, we may contact you with offers relating to data services.
Personal information about RP Dean & Co’s staff, agents, affiliates and service providers is used and may be disclosed for the purpose of managing the relationship with the staff member or other entity.
RP Dean & Co may disclose personal information about its customers or the customers of its customers (such as the end users of a telecommunications service) to a range of third
parties. For example, depending on the type of product or service, RP Dean & Co may disclose customer information to a wholesaler or other third party who provides or assists toÂ provide the service.
RP Dean & Co may also disclose personal information for credit checking, collection or credit reporting purposes to a credit reporting agency or credit collection agency, in accordance with the requirements of the Privacy Act 1988. Generally, this is limited to personal information about you (if you are an individual) or about your directors.
How does RP Dean & Co protect your personal information?
RP Dean & Co recognises the importance of protecting your personal information, and that of your Representatives and customers. RP Dean & Co also recognises the importance of ensuring that your personal information (and that of your Representatives) is complete, accurate, up-to-date and relevant.
We have documented processes for verifying personal information collected for particular transactions, such as proof of occupancy and change of occupier. Our staff are trained to properly handle the different types of information they receive, particularly sensitive information. We have quality assurance measures in place to monitor calls to ensure that our processes are being followed.
While some of the personal information we collect is held in hardcopy form, most personal information is stored in electronic databases. We have extensive processes in place to ensure that our information systems and files are kept secure from unauthorised access and interference. These include:
- System access is controlled by logins and different security levels. Access to customer information for all staff is centrally controlled. Access requests must be supported by a request from senior management.
- Functional restrictions apply. Remote access is only available to selected senior staff members. Measures are taken to prevent printing, copying or recording of customer information that can be accessed electronically.
Our employees undergo privacy and information security training on induction and are required to sign acknowledgements of their obligations in relation information security and appropriate use of our IT systems.
We have contractual arrangements in place with our agents, service providers and affiliates that require them to comply with applicable privacy laws and privacy policies. Our contractual arrangements with third parties who are outside Australia are designed to ensure that personal information transferred to those parties is afforded the same level of protection as would apply to the information in Australia.
Can you access or correct personal information RP Dean & Co holds about you?
You have a right to access personal information we hold about you. If your request is particularly complex or requires detailed searching of our records, there may be a cost to you in order for us to provide you with this information. If you believe there are errors in the information we hold about you, you have a right to ask us to correct the information.
Dealing with RP Dean & Co on-line
We store the Internet Protocol (IP) address of your computer when you visit our site. This information is used only to create broad demographic summaries of where our users come from. Our use of these IP addresses, however, does not go so far as to identify the actual users of the site.
We collect personal information about the other websites that are visited by computers that are used to visit our site. This information may be aggregated to provide us with information about the types of webpages and websites, or particular webpages and websites, visited by computers that use our site.
Complaints and further information
If you believe your privacy has been interfered with and wish to make a complaint, please contact our Privacy Officer. The Privacy Officer will investigate your complaint and notify you of the outcome.
If it appears from your complaint that there has been an interference with privacy by a person other than RP Dean & Co, the Privacy Officer may discuss the complaint with that person in an attempt to resolve it.
If you are dissatisfied with the outcome of your complaint, or you do not receive a response to your complaint within 30 days, you may make a complaint to the Office of the Australian Information Commissioner (OAIC). Complaints to the OAIC must be made in writing. Where possible, complaints to the OAIC should be made through the online Privacy Complaintform, available at www.oaic.gov.au/privacy/making-a-privacy-complaint.
The Privacy Officer
RP Dean & Co Pty Ltd
27-31 King William Street,
Kent Town, SA 5067