Crown Worldwide (Aust) Pty Limited Privacy Policy
(Notice of Collection of Information)



Purpose
Commencement
Application
Variations
Definitions
Kinds of Personal and Sensitive Information collected and held
How and why we collect and use Personal and Sensitive Information
Means of Collection of Information
Unsolicited Personal Information
Disclosure of Personal Information to External Bodies
Overseas Disclosure of Personal Information
Government Identifiers
Security of Personal Information
Destruction of Personal Information
Anonymity and pseudonymity
Direct Marketing
Accessing Personal Information
Correcting Personal Information
Using our Website
Privacy Audits
More Information / Complaints
National Privacy Officer
Availability of the Policy


Purpose

Crown Worldwide (Aust) Pty. Limited (“Crown Relocations”) is committed to protecting personal information. The purpose of this policy is to outline how and what kind of personal information Crown Relocations will collect, use, store, share and dispose of in line with the Privacy Amendment (Enhancing Privacy Protection) Act 2012, Australian Privacy Principles (APPs) and the Crown Worldwide Group Binding Corporate Rules on Data Protection.

Furthermore Crown Relocations also complies with US / EU Safe Harbor Principles.

Commencement

This Policy will commence from 12th March 2014. It replaces all other Privacy policies of Crown Worldwide (Aust) Pty Limited (whether written or not).

Application

This Policy applies to all Crown Relocations clients, transferees and prospective employees.

This policy does not apply to the personal information of Crown Relocations employees, however Crown Relocations is committed to applying the same level of protection to information relating to these individuals.

Variations

Crown Relocations reserves the right to vary, replace or terminate this policy from time to time.

Definitions

Personal information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Sensitive information means:
a) information or an opinion about an individual’s:

  1. racial or ethnic origin;
  2. political opinions; 
  3. membership of a political association;
  4. religious beliefs or affiliations;
  5. philosophical beliefs;
  6. membership of a professional or trade association; or
  7. membership of a trade union; or
  8. sexual preferences or practices; or
  9. criminal record; that is also personal information; or

b) Health information about an individual; or

c) Genetic information about an individual that is not otherwise health information.

Kinds of Personal and Sensitive Information collected and held

Through conducting our business, we may need to collect personal and sensitive information from those that we interact with. The type of information that we may collect from individuals will depend upon the particular service being provided. Examples of information collected include, but are not limited to:

  • Name, title, address;
  • Telephone numbers;
  • Email address;
  • Records of communication with Crown Relocations;
  • Passport and visa details;
  • Previous, current and future employment details;
  • Family details, including relationship status, names and ages;
  • Bank account and / or credit / debit card information;
  • Salary details; 
  • Health records;
  • Website usage information; and
  • Service Level Agreements.

How and why we collect and use Personal and Sensitive Information

Crown Relocations does not collect personally identifiable information about individuals except when such individuals specifically provide such information on a voluntary basis which is reasonably necessary for, or directly related to, one or more of Crown Relocations’ functions or activities. For example, an on-line service request requires the collection of personal data in order for us to be able to respond promptly and correctly to the service request.

If Crown Relocations is not able to collect all or some of the personal information required, we may not be able to provide our services to you.

Personal information is collected in a number of ways including:

  • Online, through the Crown Relocations website, another website or via email
  • Over the phone 
  • In person
  • By a third party, such as one of Crown Relocations’ Corporate Clients providing limited details of their employee

Personal information is collected for a variety of reasons, some examples include:

  • Conducting, improving, maintaining and developing a business relationship;
  • Quoting, planning, processing coordinating and conducting relocations and the various services that form part of this;
  • Responding to individuals queries;
  • Marketing; and 
  • Improving the Crown Relocations website.

All personal information is stored electronically on the Crown Relocations secure network and / or in hardcopy stored in secure cupboards and cabinets.

Crown Relocations does not disclose your personal information for any secondary purposes unless your consent has been given or as required by law.

Crown Relocations will not sell any personal information that it collects from an individual.

Means of Collection of Information

Crown Relocations only collects information by lawful and fair means. Crown Relocations only collects personal information about an individual from that individual unless it is unreasonable or impractical to do so.

Unsolicited Personal Information

If Crown Relocations receives unsolicited personal information about an individual that it could have collected upon requesting it from the individual, it may be used, stored or shared if it is reasonably necessary for, or directly related to, one or more of Crown Relocations functions or activities.
Crown Relocations takes reasonable steps to ensure unsolicited personal information that is not needed is destroyed immediately or de-identified (all identifying features are removed).

Disclosure of Personal Information to External Bodies

To provide our services, Crown Relocations may be legally required to disclose your personal information to Government agencies, such as the Department of Immigration and Citizenship, Australian Quarantine and Inspection Service, Australian Customs and Border Protection Service.

Crown Relocations may also need to disclose your personal information to our contractual service partners to complete your service. All contractual service partners are required to sign a Code of Conduct and Non-Disclosure Agreement which includes an obligation to protect the private and confidential information of Crown Relocations and its customers.

By signing the Crown Relocations Service Agreement, you consent to Crown Relocations disclosing your personal information where it is reasonably necessary for the sole purpose of facilitating our services.

Overseas Disclosure of Personal Information

The Crown Worldwide Group is a global organisation and due to the nature of our business, we may need to disclose personal information overseas in order to provide our services. We may be required to disclose an individual’s personal and sensitive information to both private and government agencies. Crown Relocations will submit this personal information only to government agencies and contractual service partners who have a legitimate need for the personal information. Individuals can expect their personal information to be disclosed to Crown Relocations or its contractual service partners in the origin country, the destination country or potentially a third country if the service is not being managed by the origin or destination country. Information is also electronically stored in a secure data centre in Hong Kong.

By signing the Crown Relocations Service Agreement, you consent to the disclosure of your information (including overseas) where reasonably necessary to provide our services.

Government Identifiers

Crown Relocations does not adopt, use or disclose government related identifiers (such as a passport number or tax file number) of an individual unless it is reasonably necessary to verify the identity of an individual or fulfil our obligations to a Government agency.

Security of Personal Information

Crown Relocations will take reasonable steps to ensure that any personal information held is protected from:
a)misuse, interference, loss; and
b)unauthorised access, modification or disclosure.

Destruction of Personal Information

When personal information about an individual is no longer needed for the purpose for which it was collected (taking into account legal requirements for retaining certain information), Crown Relocations will ensure the secure destruction or de-identification of such information.

Anonymity and pseudonymity

An individual has the option of not identifying themselves, or of using a pseudonym when dealing with Crown Relocations.

However, individuals should be aware that there will be limitations to the services that Crown Relocations is able to provide unless some identifying information is provided (the level of information depends on the service being provided).

Direct Marketing

From time to time, Crown Relocations may contact you regarding our services using the personal information (not sensitive information) you have supplied to us.
 
If you do not want to receive marketing information, please advise your point of contact at Crown Relocations. If you are not sure who this is, you can contact the National Privacy Officer (contact details outlined at the end of this policy) who will assist you or direct you to the most appropriate person.
 
We will not provide your information to any third party for the purpose of direct marketing.

Accessing Personal Information

An individual can access personal information held by Crown Relocations about themselves by making contact with their point of contact at Crown Relocations, except where an exception applies (please see exceptions listed below). If they are unsure who to contact, they should contact the Crown Relocations National Privacy Officer (contact details outlined at the end of this policy) who will assist them or redirect their enquiry to a more appropriate person.

Crown Relocations will respond to the request for access to the personal information within a reasonable period after the request is made. Crown Relocations will give access to the information in the manner requested by the individual, if it is reasonable and practicable to do so.

Circumstances under which an individual would not be given access to their information include:

  1. Crown Relocations reasonably believes that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or
  2. Giving access would have an unreasonable impact on the privacy of other individuals; or
  3. The request for access is frivolous or vexatious; or
  4. The information relates to existing or anticipated legal proceedings between Crown Relocations and the individual, and would not be accessible by the process of discovery in those proceedings; or
  5. Giving access would reveal the intentions of Crown Relocations in relation to negotiations with the individual in such a way as to prejudice those negotiations; or
  6. Giving access would be unlawful; or
  7. Denying access is required or authorised by or under an Australian law or a court / tribunal order; or
  8. Both of the following apply:

    1. Crown Relocations has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to Crown Relocations’ functions or activities, is being or may be engaged in;
    2. Giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or
  9. Giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
  10. Giving access would reveal evaluative information generated within the entity in connection with a commercially sensitive decision-making process.

If Crown Relocations elects not to give access to the information for one or more reasons outlined above, we will take reasonable steps to give access in a way that meets the needs of Crown Relocations and the individual. The individual will be provided with a written notice that sets out:
a) The reason for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so; and
b) The mechanisms available to complain about the refusal.

Correcting Personal Information

An individual can correct personal information held by Crown Relocations about themselves by making contact with their point of contact at Crown Relocations. If they are unsure who to contact, they should contact the Crown Relocations Sydney Head Office and speak to the National Privacy Officer (contact details outlined at the end of this policy) who will assist them or redirect their enquiry to a more appropriate person. Crown Relocations will respond to the request for correction to the personal information within a reasonable period after the request is made.

If Crown Relocations has corrected personal information about an individual that we have previously disclosed to a third party, and the individual requests that Crown Relocations notifies the third party of the correction, we will take reasonable steps to give that notification unless it is impracticable or unlawful to do so.

If Crown Relocations refuses to correct the personal information as requested by the individual, we will provide a notice to the individual which sets out:
a)The reasons for the refusal except to the extent that it would be unreasonable to do so; and
b)The mechanisms available to complain about the refusal.

If Crown Relocations refuses to correct the personal information as requested by the individual, the individual may request Crown Relocations to associate a statement outlining that the information is inaccurate, out of date, incomplete, irrelevant or misleading. Crown Relocations will take such steps as are reasonable in the circumstances to associate the statement in such a way that will make the statement apparent to users of the information.

Using our Website

Providing Visitors with Anonymous Access

Visitors can access our website home page and browse our site without disclosing personal data by disabling the cookie settings on our website.

We do not collect information about our visitors from other sources, such as public records, public bodies or private organizations.

Automatic Collection of Information

We use cookies on the Crown Relocations website to store information on your computer or mobile device. Cookies are small text files which help us understand how the website is being used. They let you navigate between pages efficiently, remember your preferences, and generally improve your browsing experience. Cookies can also help ensure information you see on-line is more relevant to you.
 
To give you the very best browsing experience, the cookie settings on the website are set to allow all cookies. If you continue to browse the site without changing these settings, you consent to this.

Privacy Audits

Crown Relocations will conduct a privacy audit at least annually in each Australian branch / office to ensure that the requirements of this policy are being adhered to.

More Information / Complaints

If you would like to make a complaint related to Crown Relocations breaching the Australian Privacy Principles (APPs) or would like further information on the way that Crown Relocations collects, uses, stores shares and disposes of your information, please contact the National Privacy Officer (contact details outlined at the end of this policy).

The nature of your complaint will determine how it is dealt with, however steps may include an investigation, escalation, review of internal policy or process and / or apology to those affected.

National Privacy Officer

Peter Schacht
Crown Relocations Australian Head Office
288 Woodpark Road, Smithfield NSW
(02) 8787 0400
pschacht@crownww.com

Availability of the Policy

This policy is available on the Crown Relocations Australia website (http://www.crownrelocations.com.au). Alternatively, you can request a copy in person, by phone or email to your nearest Crown Relocations branch, and we will provide a hard copy or send it to you by your preferred method (facsimile, email or physical mail).


POLICY VERSION AND REVISION INFORMATION
Policy Authorised by: Mark Ellis Original issue: 12/03/2014
Title: Managing Director
Policy Maintained by: Melissa O’Connor Current version: 3
Title: National HR Manager
DOCUMENT VERSION
Created: 24/02/2014 Version: 1
Review Date: 01/01/2017 Version: 3
Next Review Date: 01/01/2018 Version: 4

TESTIMONIALS
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