1. Purposes for which CPM collects, holds, uses and discloses personal information
We only collect, hold, use and disclose personal information which is reasonably necessary to ensure that we are able to provide you with the products and services that are appropriate to your needs. We will outline to you when you engage our services the purposes for which we will collect, hold, use and disclose your personal information.
2. Kinds of personal information CPM collects
Due to the nature of the products and services we provide, and the requirements of legislation and regulations, we ask for a range of personal information from our clients.
The types of personal information we may collect can include details such as:
- Names, employment details, contact details;
- Date of birth and gender;
- Information in identification documents (e.g. passport, driver’s licence); or
- Personal information about your spouse and dependants.
It may be necessary in some circumstances for CPM to collect sensitive information about you in order to provide specific services.
You have a right to refuse to provide us with your personal information or to anonymity or the use of a pseudonym. However, if you do refuse to provide such information, or request the use of anonymity or a pseudonym we may be unable to complete or fulfil the purpose for which such information was collected, including providing you or our clients with the services we were engaged to perform.
3. Collection, holding, using and disclosing of personal information
3.1 Collection generally:
When we collect, hold, use and disclose personal or sensitive information it must be done through lawful and fair means. Consent must be obtained to collect, hold, use and disclose personal information. We are not required to obtain your consent to collect, hold, use of disclose your personal or sensitive information if the collection is required or authorised by or under an Australian law or a court/tribunal order. There are other exceptions to the requirement of obtaining your consent in accordance with the Australian Privacy Principles. If you would like more information on these requirements, please contact our Privacy Officer.
3.2 Methods of collection:
CPM uses a variety of formats for the collection of personal and sensitive information. These include:
- Requiring you to complete a profile or other forms;
- Receipt of emails, letters and other correspondence;
- Telephone calls;
- Appointments in person;
- Publicly available records;
- Through a client’s personal representative; or
- Through use of our website, such as via contact mailboxes or online enquiry forms, or through the registration process.
In every circumstance we will attempt to obtain such personal and sensitive information directly from you. If that is unreasonable or impracticable, we will attempt to obtain such information from other sources in accordance with Clause 3(a) above.
3.3 Collection of someone else’s personal information:
You should only provide us with someone else’s personal information where you have their express consent to do so and it is for the purpose of us providing services to you. Matters in this policy should be communicated to any person whose information you collect and provide to us.
There may be circumstances where we are provided with personal information which we did not actively seek. An example may be misdirected mail, or an excess of documents provided to us by clients. In such situations, our Privacy Officer will make a determination on whether we could have obtained the information lawfully in accordance with the APPs. If the information was not lawfully obtained it will be destroyed or de-identified. We will use reasonable endeavours to notify the relevant person, whose information has been mistakenly received, if this situation arises.
4. Security of personal information and safeguarding the privacy of your information
We hold personal information in a combination of secure computer storage facilities and paper based files, and take steps to protect the personal information we hold from misuse, loss, interference, unauthorised access, modification or disclosure. CPM trains its employees carefully on handling personal information and confidentiality of such information. Once we have no purpose for holding your personal information, we will take all reasonable steps to destroy or de-identify the information.
5. Disclosure of personal information overseas and sharing personal information amongst and within the CPM network
On collection of your personal information, we will use reasonable endeavours to inform you whether it is likely we will disclose the information to an overseas recipient and, if so, where those recipients are likely to be located.
6. Privacy on our website
The CPM website uses Google Analytics to analyse aggregate user behaviour.
Google Analytics uses first party cookies, which are text files placed on your computer for the purpose of anonymously identifying your session. These cookies are not used to grant CPM access to your personally identifiable information. Non-identifiable information (such as the pages you visit) may be tracked. By directing your browser to delete your cookies, this data will be erased. For more information about Google Analytics, please follow the links provided on our website. The information is collected using first party cookies, meaning that only CPM is able to access your information.
7. Direct marketing
CPM may engage in direct marketing to you from time to time.
When required, your personal information will only be used or disclosed for direct marketing where the information is not sensitive information, is collected directly from you and there is an easy means to opt out of such marketing (and such an opt out request has not been made) in the following circumstances:
- Where you would expect CPM to use or disclose the information for direct marketing purposes; or
- You have consented to the use or disclosure of the information for direct marketing purposes.
8. Access to personal information
You have the right to access any personal information regarding you that CPM holds.
This is subject to some limited exceptions, which the Privacy Officer can provide further information on. Such requests should be made in writing to the Privacy Officer. We will acknowledge your request within 14 days and respond to it within a reasonable time.
CPM may charge a fee only to cover the cost of locating, retrieving, reviewing and copying any material requested.
We will not charge any fee to make the request or for us to give effect to the request. If your request is approved, we will provide you with access to the information in the manner requested if it is reasonable and practicable to do so.
9. Correction of personal information
CPM endeavours to ensure that the personal information it holds is accurate and up-to-date.
You are able to make a request to correct your personal information by contacting our Privacy Officer, or by telephoning or emailing us with your corrected information. In some limited circumstances your request may be refused or partially refused.
10. Procedure if your request to access or correct is refused
There may be limited circumstances where your request is refused or partially refused. If this occurs we will give you a written notice that sets out:
- The reasons for the refusal, including the reasons why access cannot be granted in an alternative way (except where it would be unreasonable to provide those reasons);
- How to make a complaint about the refusal; and
- Any other matter as prescribed by the regulations. If your request to correct your personal information is refused you have the option of submitting a statement associated with your personal information. For more information contact our Privacy Officer.
11. How to make a complaint
If you consider that any action of CPM breaches this policy or the APPs, you are able to make a complaint.
Once we have received your complaint, it will be assessed and acted upon within a reasonable time. To make a complaint please contact our Privacy Officer. If you are not satisfied with our response to your complaint, you may contact the Office of the Privacy Commissioner.
On request, we may be able to provide you with a copy of the policy in an alternate format. If you have any enquiries or would like to make a request for a copy of the policy, please contact our Privacy Officer (refer to contact details below).