CCIs Privacy Policy

The Chamber of Commerce and Industry of Western Australia (CCI) is bound by the National Privacy Principles (“the NPP’s”) as set out in the Privacy Act 1988 (as amended by the Privacy Amendment (Private Sector) Act 2000).

To comply with obligations under the NPP’s CCI has a Privacy Policy, which sets out how we manage privacy in our organisation.

Privacy and Confidentiality

CCI appreciates the importance of confidentiality when dealing with our members and the broader business community.

Our privacy policy deals with your additional right to privacy and is independent of our contractual and ethical obligations.

We are committed to protecting your privacy and ensuring that your contact with us and your use of our web site and other facilities is a safe and rewarding experience.

INFORMATION COLLECTED

Membership Details

When an organisation joins CCI we collect the names and job titles of key contacts within that organisation. This allows us to tailor our services to the most appropriate people within member companies. These details are used by CCI for business purposes only and are not provided to external bodies.

Your name and contact details may however, be provided to CCI related companies in order to provide you with, or make you aware of, the full range of services provided by CCI and these related organisations.

Web-site

If you visit the CCI web site to read, browse or download information without logging in, our system will record the date and time of your visit, the pages viewed, the information downloaded and the country from which youve accessed the site. It does not identify you personally.

If you log in with your login number and password, the system will record your name and the company for which you work in addition to the information mentioned in the first point.

This information is strictly confidential and used for internal research purposes only. It helps us track which sections of the site are most popular and gives us a clear idea of what type of information and services to include on our site. It also tells us which members and subscribers are using the site, which further helps us to tailor our on-line information.

Business Advice Centre

Calls to our Business Advice Centre are logged by the Adviser you talk to who will ask you for your name and commonly your job title. A brief record of the conversation will be made and maintained on our internal database. This historical record helps us to provide consistent advice as well as a facility to advise members on issues they have sought assistance on during the course of their membership. This information may be used for internal research purposes.

Registrations - training & functions, on-line publication purchases

The CCI web site offers a number of interactive facilities including the realtime training course and function registration facilities along with the on-line purchasing system for CCI publications.

Any information you send via these registration forms is kept strictly confidential. The appropriate details are recorded against the company name on our customer database - ie:

• name
• address and phone number
• membership number (if applicable)
• the name of the training course, function or publication purchased
• method of payment - ie credit card or invoice
• the type of credit card but not the credit card number or the expiry date - ie Visa, Mastercard
• the name of the credit card holder
• on-line registration date

These details are also stored in a secure, password protected back-end database on our web-site.

If you decide to complete an online application form, we will only collect the information that you enter into the online form if you submit your application. If at any stage you cancel your application or log out prior to submitting your application, the information you have entered to that point will be automatically deleted.

On-Line Recruiting

The CCI website supports the JobOffice online recruitment software and the collection of recruitment data.

Consent will be obtained prior to the collection of your recruitment data and after acceptance of the terms of CCIs privacy policy.

Any personal information you send or we collect about you, from you or your referees will only be used to assess your application.

The information collected about you may be disclosed to CCI staff involved in assessing your application or in supporting roles or to referees.

If your application is unsuccessful, we will destroy the information collected immediately unless you indicate your desire for your application and updated files to be retained for a further three months in the event that another suitable position becomes available. If your application is successful, your personal information will be placed on your personal file and used in relation to your employment.

USE AND DISCLOSURE OF INFORMATION

Any information you provide to CCI is kept strictly confidential. The content of our customer database is not available in any form to third parties with the exception of third party suppliers used for the purposes of mailing services and market research etc.

Your name and contact details may however, be provided to CCI related companies in order to provide you with, or make you aware of, the full range of services provided by CCI and these related organisations.

A formal CCI Confidentiality Agreement prevents third party suppliers from disclosing any of the CCI database details to any other party.

How we Handle Email and Facsimiles

We will preserve the content of any e-mail or facsimile that you send us where it is necessary for the effective delivery of our services or where legally required to do so. Where appropriate, we may record your e-mail or facsimile address against the relevant company name on our confidential customer database. The names and email addresses/ facsimile numbers of individuals may be disclosed where emails/ facsimiles are simultaneously sent to more than one person.

SECURITY OF WEB–BASED INFORMATION

CCI has taken all reasonable care to preserve the security of personal information submitted via the CCI web site.

CCI regularly reviews developments in security and encryption technologies.

Unfortunately, no data transmission over the Internet can be guaranteed as totally secure. Consequently, CCI cannot guarantee the security of any  information you transmit to us or from our online products or services and you do so at your own risk.

After receiving your transmission, we take the necessary steps to preserve the security of the information in our customer database.

ACCESS TO YOUR PERSONAL INFORMATION

Subject to this Policy, individuals are able to access the personal information CCI holds about them. A person is able to inspect, take notes of or receive copies or print outs of the personal information held Requests for access are to be made in writing and proof of identity will be required to ensure that personal information is only provided to the correct individual.

Access to personal information can be declined if:

• the request does not relate to the personal information of the person making the request;
• providing access would pose a serious and imminent threat to life or health of a person;
• providing access would create an unreasonable impact on the privacy of others;
• the request is frivolous and vexatious;
• the request relates to existing or anticipated legal proceedings
• providing access would prejudice negotiations with the individual making the request;
• access would be unlawful;
• denial of access is authorised or required by law;
• access would prejudice law enforcement activities;
• access discloses a ‘commercially sensitive’ decision making process or information; or
• any other reason that is provided for in the National Privacy Principles (NPPs) set-out under the Privacy Act.

Any dispute over the right or form of access to personal information will be dealt with in accordance with the Complaints Procedure outlined at the end of this Policy.

CCI will endeavour to provide access within 30 days of receiving the written request although this time frame may be shorter where the request is simple or relates to a small volume of information. The following charges will apply to cover costs incurred by CCI:

• Photocopying – 50 cents per A4 page
• Provision of electronic database records – 50 cents per A4 page
• Delivery cost of information stored off-site – where information if stored off-site, the cost of obtaining access to the information - $15 per item

Sensitive information is information that details a persons political or religious beliefs, medical details, ethnic origin, health or disability. CCI may need to collect some sensitive information as part of a selection process when recruiting. We will only collect sensitive information when relevant to a particular position and will not be released to a third party unless applicants have given their consent.

Sensitive information may need to be obtained in the following circumstances:

• Where a pre-employment medical assessment is required
• Date of birth superannuation, or
• Where a Working with Children check is required.

The candidate will be advised in advance of the need to collect sensitive information if required and such information will only be disclosed where necessary.

ACCURACY OF INFORMATION

CCI takes all reasonable precautions to ensure that the information it collects, uses and discloses is accurate, complete and up-to-date. However, the accuracy of that information depends to a large extent on the information you provide. For this reason, CCI recommends that you:

•  let us know if there are any errors in your personal information; and
• keep us up-to-date with changes to your personal information such as your name or address.

COMPLAINTS PROCEDURE

What is a privacy complaint?

A privacy complaint relates to any concern or dispute that an individual has with CCI’s privacy practices as it relates to their personal information. This could include matters such as:

(a) How personal information is collected

(b) How personal information is stored

(c) How this information is used or disclosed

(d) How access is provided.

How will a privacy complaint be resolved?

CCI will endeavour to resolve complaints in a timely fashion. Any complaints about privacy should be directed to the Contact Person identified at the end of this Policy.

All complaints will be logged on a database/complaints register.

Complaints must be received in writing stating the specific nature of the complaint. CCI’s Contact Person will be the proper person to discuss or resolve your complaint, however, if your privacy complaint is not resolved the matter may be referred to a Senior CCI Officer.

The Complaints Procedure

The goal of this procedure is to achieve an effective resolution of your complaint within a reasonable timeframe of 30 days or sooner if practicable.

Once the complaint has been made, the Contact Person can then resolve the matter in a number of ways:

1. Request further information and investigation: CCI may request further information from the complainant who will be expected to give as many details as possible including details of any relevant dates and documentation. This will enable the Contact Person to investigate the complaint and determine an appropriate and useful solution. All details provided will be kept confidential.

2. The complaint may be investigated. Where no additional information is required, CCI through the Contact Person, will investigate the complaint. It may be necessary for CCI to contact others in order to proceed with the investigation and to progress your complaint.

3. Discuss options: CCI will discuss options for resolution with the complainant. The Contact Person could also suggest other solutions or give examples of how the personal information can be revised or stored in a different way.

4. Refer to Senior CCI Officer: If your complaint is not resolved by the Contact Person it will be referred to a senior CCI officer. This officer would be provided with the history and may discuss the complaint with the employees, or other parties that are involved.

5. Resolution: The complainant will be informed of the outcome of the investigation and the reasons for the decision. If this does not resolve the complaint, the matter may be referred to a mutually agreed intermediary or to the Office of the Privacy Commissioner.

Records

CCI will keep a record of the complaint and the outcome. This record will be properly stored and used by CCI for internal monitoring purposes only.

Anonymous complaints

Anonymous complaints will not be accepted as we are unable to investigate properly and follow-up such complaints.

However, in the event that an anonymous complaint is received CCI will note the issues raised and try and resolve them appropriately. For example, CCI may wish to conduct further training or provide assistance in a given area.

CONTACT PERSON

For any further information about this policy please contact CCI’s Privacy Officer on 9365 7735 or email: [email protected].