We are bound by the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”). This Policy explains how and why we collect, use, hold and disclose your personal information.
“We”, “us” and “our” means EPE Oceania Pty Ltd (ABN 46 003 083 609), trading as EPE Trusted to Protect, and any of our Related Companies (as defined in the Corporations Act (Cth) 2001) (each and collectively, “EPE”) of 383 Boundary St, Spring Hill QLD 4000, and all our related entities.
This Policy should be considered in light of affiliated policies and regulatory matters (if any) such as use of emails, Spam Act, Facebook Protocols, and the Do Not Call Act. Most of these may not necessarily directly deal with ‘personal information’ as defined in the Act but extend to uses of data that may incidentally include personal information.
You consent to us collecting, holding, using and disclosing your personal information in accordance with this Policy.
What is personal information?
Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.
What personal information do we collect and hold?
The personal information collected and used by EPE can be provided or used electronically or, in rare circumstances, by conventional or tangible methods and the principles of protection outlined in this Policy apply equally to all information mediums.
EPE provides protective goods and services to Defence Forces, Law Enforcement, and other government agencies throughout Australia, New Zealand and the Indo-Pacific region.
We collect the personal information of individuals from our websites, our servers (emails), other electronic means (such as through phone services) and occasionally in person. We also collect it through exchange of business cards, referrals from other individuals, and attendance registers.
We collect information about you and your interactions with us, for example, when you purchase or use any of our products or services, call us or otherwise visit our website. The information we collect from you may include your name and contact details, your history of purchases and use of our products and services and details of enquiries or complaints you make.
In most cases, the information will only involve your name and your business title or position, your business email addresses and mobile phone number. Depending on the purposes for the collection, we may necessarily have to include for legal compliance purposes, your name, date of birth, home and work addresses, email address, banking and credit card information, qualifications, professional title, personal mobile telephone numbers or direct landline numbers.
In every mode of collection or use, we follow the guidelines and rules laid down by the Australian Privacy Principles. Our compliance procedures can be overridden by legal process – law enforcement, regulatory intervention, and emergency health or safety issues all take priority to our protocols and procedures.
We only collect the information we need to provide you with the goods and services you seek or are likely to be interested in due to the nature of our relationship. Generally, it’s to administer that relationship, whether for supplies, acquisitions or disposals of assets or interests, potential clients, contractual or legal compliance and insurance purposes.
We do not collect tax file numbers or other government identifiers of individuals, except as a legal necessity and for employment purposes, if you are an individual carrying on a business we will collect and use the ABN of that business for our business and tax requirements.
Sensitive Information
We may in selected specific circumstances, have to ask for sensitive information. If the information is expressly required by a law or regulation or is required or relevant to our purpose or the services we provide, including for our employment purposes, we will identify the law or regulation when we ask for the information. Sensitive information is treated separately and more confidentially and is destroyed as soon as it is no longer needed for the purpose. We will require your written consent to the disclosure of information that contains sensitive information if such disclosure is required. EPE has relevant security measures such as restricted access to limited approved parties as and when required.
Website access
We may collect de-identified information about how you access, use and interact with the website. We do this by using a range of tools such as Google Analytics. This information may include:
- the location from which you have come to the site and the pages you have visited; and
- technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system.
We use cookies on the website. A cookie is a small text file that the website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the website.
Why do we collect, hold and use your personal information?
We collect, hold and use your personal information so that we can:
- provide you with products and services, and manage our relationship with you;
- contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;
- comply with our legal obligations and assist government and law enforcement agencies or regulators; or
- identify and tell you about other products or services that we think may be of interest to you.
If you do not provide us with your personal information we may not be able to provide you with our services, communicate with you or respond to your enquiries.
The personal information we may solicit and collect directly from you or from another entity about you is only the information that is reasonably necessary for us to do our job for you for our functions and our activities.
Examples of personal information collected by us could include:
- personal information provided by an individual in response to a request, direction or order
- personal information about an individual provided by another entity in response to a request, direction, order or arrangement for sharing or transferring information between both entities
- personal information provided at a business meeting, where it relates to the subject matter of the meeting, including business cards exchanged at the meeting
- a completed form or application submitted by an individual
- a record of a credit card payment
- an employment application sent in response to a job advertisement.
How do we collect your personal information?
We will collect your personal information directly from you whenever you interact with us.
We collect the information in numerous ways – telephone, internet, email, and written correspondence. Other sources of collection of that personal information may include:
- notices, invoices and order forms
- forms and notices for statutory compliance purposes (such as consents to act)
- surveys and questionnaires
- project and consultancy proposals and contracts for services
- telephone enquiries to our offices
- email broadcasts
- business cards
- publicly available directories and publications.
Where you provide us with personal information about someone else, you must ensure you have that individual’s consent to give it to us, especially if it is an employee or contractor to you.
Our online facilities such as web browsers, log information collectors, and cookies do not collect personal data about individuals. You can disable cookies and opt out of online advertising, but there is a risk that in doing so, you and your business may not receive the services you have sought from us or updates or other information pertinent to our relationship with you.
We may also collect information from third parties such as credit agencies and referral services.
How do we store and hold personal information?
We store all information about you in centralised computer systems and databases operated by either us or our IRAP certified external service providers.
While our data is presently residing in datacentres in Australia, there may be times when, due to the nature of the transaction you seek with us or the communication facility used, your data is available to overseas recipients. The purpose of these sorts of disclosures are for software solutions, help desk support or for simply storage purposes through contracted service providers or facilities we use that include cloud options.
Please note that by using our telecommunication facilities and specifically internet access, you will be consenting to the possibility of the data we collect for the service transaction or relationship being disclosed overseas and to unknown destinations. This covers those cases where we are simply undertaking normal business activity.
Some information about you may be recorded in paper files that we store securely.
We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.
These processes and systems include:
- compliance with the Australian Systems Directorate’s Essential Eight cyber security mitigation strategies;
- the use of IRAP certified providers;
- the use of identity and access management technologies to control access to systems on which information is processed and stored;
- requiring all employees to comply with internal information security policies and keep information secure; and
- monitoring and regularly reviewing the organisation’s practise against our own policies and against industry best practice.
We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs (including where it is needed for legal reasons).
Who do we disclose your personal information to, and why?
We may transfer or disclose your personal information to our related companies. Disclosure to third persons could include regulatory and other government agencies connected with the subject matter of our dealings with you and contracted service providers who are undertaking a service on our behalf.
We may disclose personal information to external service providers so that they may perform services for us or on our behalf.
We may also disclose your personal information to others outside our group of companies where:
- we are required or authorised by law to do so;
- you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
- we are otherwise permitted to disclose the information under the Privacy Act.
If the ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.
Do we disclose personal information to overseas recipients?
EPE provides goods and services to entities throughout Australia, New Zealand and the Indo-Pacific region. We have offices in Brisbane, Australia, Wellington, New Zealand, and Kentucky, USA. Additionally, EPE work with international partners and market their product and services globally.
EPE does not routinely disclose personal information outside Australia.
However, in some cases, your dealings with us may involve the transfer of your personal information overseas. In these cases, we are not responsible for the use of that information at its destination, or the recipient’s compliance with our Policy, Australian privacy laws or their own internally regulated security or privacy compliance. While any contractual arrangements we may undertake on your behalf that involve an overseas recipient include specific obligations in relation to protection of your information (including any confidential information you need to disclose), it is neither practicable nor reasonable for us to identify each possible recipient, the business, or agency and to explore and advise on their privacy environments, and you are taken to have full responsibility for the consequences.
In the course of providing services to you, we may disclose your personal information to third parties. These third parties may transfer your personal information overseas. In these cases, we will have contractual arrangements in place to ensure your personal information is protected to a similar extent as under Australian law and you consent to such disclosure to third parties when you share your personal information with us.
Do we use your personal information for marketing?
If you have been a customer, we may use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to. These products and services may be offered by us, our related companies, our other business partners or our service providers.
Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.
In all cases where we use or disclose personal information for the purposes of our own direct marketing or to facilitate another organisation’s direct marketing, and the consent express or implied has been obtained in accordance with this APP, you can always request that you be removed from the marketing list and or ask us not to disclose your data to the other organisation(s) for that purpose.
Access to and correction of your personal information
You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date and complete.
Notifiable data breaches
We are committed to doing all that we can to protect data and personal information.
As the internet is inherently insecure no matter how many protection measures are taken, should there be a data breach, EPE may, in compliance with the law, notify the relevant parties as soon as practicable. In the case of what is known under the law as an ‘eligible data breach’, EPE may notify the relevant parties of what has occurred, what information is involved, what the implications may be, what can be done and what EPE will do in the specific circumstances.
Complaints
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
Contact details
If you have any questions, comments, requests or concerns, please contact us at . You can also let us know of any concerns or complaints you may have about how your personal information is being handled by EPE by marking your email PRIVACY – URGENT.
If you are in email contact with EPE already, then submit your request to your usual contact and copy .
Changes to this Policy
From time to time, we may change our Policy on how we handle personal information or the types of personal information which we hold. Any changes to our Policy will be published on our website. You may obtain a copy of our current Policy from our website or by contacting us at the contact details above.