Saropa understands that privacy is an important issue for its customers and generally for individuals.
Saropa believes that due respect for individual privacy not only protects an important right of the individual but is a powerful tool in the creation of healthy relationships with its customers and suppliers and with others with whom it deals in the business community.
As the provider of a repository service for our customers’ personal information we accept that privacy and security is of special importance for our customers.
There are two categories of personal information that Saropa collects:
- general information to enable us to manage our relationships with customers, suppliers and other businesses; and
- the information that our customers up-load to our on-line repository service.
In the early phases of our business the Privacy Act may not, in fact, apply to Saropa - and while we do not formally opt-in to the Privacy Act rules, we aim to comply with privacy laws, including the National Privacy Principles set out in the Privacy Amendment (Private Sector) Act 2000 (Cwth). We will also continue to comply with all other privacy related obligations that apply to us, and our obligations of confidentiality.
It is our belief that by doing so we will enhance the level of trust in our relationships with customers, suppliers and other individuals.
It is the responsibility of all Saropa employees to comply with privacy laws and this policy. Saropa requires that its employees familiarize themselves with and accept and adopt this policy. Saropa employees must do everything within their power to cause Saropa to meet its privacy obligations and to achieve the benefits referred to above. Saropa will regard non-compliance with this policy most seriously. In the case of employees, violation of this policy will lead to disciplinary procedures being imposed, including the possibility of dismissal.
Saropa will, wherever practicable, require its independent contractors to be contractually bound to comply with this policy. Contractors who display a willingness to do so and a culture of respect for privacy and compliance with privacy laws will be preferred.
SOME IMPORTANT TERMINOLOGY EXPLAINED
Personal Information - this means information or an opinion, including information or opinion forming part of a data base concerning an individual. It does not matter whether the information or opinion is true or justifiable or not. It does not matter how the information is recorded, but it must be recorded. Finally, the information must be such as to identify the individual or to enable the identity of the individual to be reasonably ascertained.
Personal information relates to individuals not companies. However, personal information can include information within a business context.
Personal information also includes sensitive information (see below).
Privacy Act means the Privacy Act 1988, as amended by the Privacy Amendment (Private Sector) Act 2000 and includes the National Privacy Principles, or “NPPs”.
Sensitive Information is personal information concerning an individual’s:
- racial or ethnic origin; or
- political opinion; 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 preferences or practices; or
- criminal record; or
- information; or an opinion about the health or disability of an individual or an individual’s wishes about the future provision of health services.
Consent is not always required under the Privacy Act, but where it is required we will provide sufficient information to enable the individual to make an informed decision about whether or not to give consent. We will explain all relevant matters fully and adequately and we will not put undue or inappropriate pressure on an individual to give consent. We believe that for consent to be valid it must be voluntary.
WHAT KIND OF PERSONAL INFORMATION WE COLLECT
Generally, we will not collect sensitive information from individuals unless we obtain consent to do so.
Customer information up-loaded to the on-line repository - In the case of personal information up-loaded by our customers to our on-line repository, we have no control over the content of that material - and so we assume that if the material is up-loaded with the consent of the customer.
Personal Information collected for general business purposes - Other than information up-loaded by a customer to our on-line service, we will not normally collect personal information other than an individual’s name, and contact details such as address, phone numbers and email addresses.
THE PURPOSES OF COLLECTING THE PERSONAL INFORMATION AND WHAT WE DO (AND WILL NOT DO) WITH IT
Customer information up-loaded to the on-line repository - this information is “collected” by Saropa because that is the service Saropa is in business to supply
We will never disclose personal information uploaded by a customer to our on-line repository service in a manner that enables the customer to be identified.
From time to time we may use the information that we collect for commercial purposes, such as sale to marketing analysts or commercial firms having an interest in demographic data or statistics. We will always de-identify information before we use it in this manner.
Personal Information collected for general business purposes - We will generally collect personal information to enable us to contact our customers, suppliers, business partners and others with whom we have business relationships. This will enable us to fulfil our commitments and responsibilities to members and to enable them to reap the full benefits of membership. This will also enable us to monitor and administer our contracts and perform our contractual obligations.
We also collect personal information to enable us to carry out marketing initiatives - to let our customers and contacts know about the services we offer from time to time.
ACCURACY OF PERSONAL INFORMATION
Customer information up-loaded to the on-line repository - we have no control over the accuracy of this information. It is the responsibility of our customers to ensure that the information up-loaded to our on-line service is accurate.
Personal Information collected for general business purposes - It is our policy to ensure that when personal information is collected from an individual it is accurately recorded. This is the responsibility of all staff involved in the collection and recording of such information. It is also our policy to collect personal information direct from the individual wherever possible since this is likely to generate greater accuracy.
Individuals have a right of access to the personal information held by Saropa and will have the opportunity to correct any inaccuracies (as to which, see below).
Saropa will respond promptly to any request for correction of data.
SECURITY OF PERSONAL INFORMATION
It is not appropriate in this policy to provide specific details of security measures adopted by Saropa to protect information held by it. To do so could compromise those security measures.
Customer information up-loaded to the on-line repository - Saropa pays special attention to the security of the information up-loaded to the on-line repository by its customers.
To some extent the battle with computer crime involves an “arms race” and a constant battle of technological measure and counter-measure. Accordingly Saropa can never guarantee security, but to maintain the integrity of information, Saropa has acquired and will continue to up-date appropriate technology, such as “fire-walls” and encryption programmes to exclude unauthorized access, hacking and computer virus infection from Saropa’s computer system.
Personal Information collected for general business purposes - Saropa will use an appropriate combination of administrative protocols, physical barriers and technology to help prevent unauthorised persons or intruders from gaining access to information.
INDIVIDUALS’ ACCESS AND CORRECTION RIGHTS
Customer information up-loaded to the on-line repository - The business Saropa is in involves the supply of an on-line repository for information. Saropa charges fees for the supply of that service. Saropa may deny access to the on-line repository if the agreed service fees are not paid.
Personal Information collected for general business purposes - Saropa will provide individuals access to the personal information which Saropa holds about them. This right of access will be advised when personal information is collected.
Saropa will respond to requests for access as soon as possible and will acknowledge the request within 14 days and deal with it within 30 days.
As regards other personal information collected and retained by Saropa for general business purposes (i.e. not up-loaded to the on-line repository), Saropa will not charge individuals for access to their personal information.
In some circumstances it may be appropriate and lawful for Saropa to deny access, as set out in NPP 6.
ELECTRONIC COMMUNICATION AND OUR WEB SITE
Special issues arise when personal information is collected or communicated by electronic means.
The Saropa web site will contain:
- a copy of this policy
- a policy statement specifically about on-line privacy; and
- at each point within the web site where personal information is collected, a collection notice as required by NPP 1.3
OUR OUTSOURCING OF SOME FUNCTIONS
From time to time, Saropa may engage external contractors to perform certain functions or services for Saropa, such as:
- hosting or maintaining the Saropa website and database, including the on-line repository;
- hosting or maintaining our IT generally;
- providing direct marketing and mailing services.
It is our policy that our contracts with such external providers, to the extent that it is contractually and commercially possible in each case, should require the provider to comply with the Privacy Act and the National Privacy Principles.
COMPLAINTS AND FURTHER INFORMATION
If you have a complaint about a privacy matter or require further information, please contact us by one of the following means:
- email: firstname.lastname@example.org
- phone: +1 (919) 727-6720
The Privacy Officer
Saropa Pty Limited
244 5th Avenue, Suite 200
New York, N.Y. 10001
The Privacy Officer
Saropa Pty Limited
Level 14, 309 Kent Street
Sydney NSW 2000
Saropa Pty Limited aims to improve its approach to privacy and may from time to time update this policy statement.