1.   Background

This Privacy Policy (Policy) applies to Visionstream Australia Pty Ltd and related bodies corporate or connected entities and Visionstream Pty Ltd (New Zealand Company Number 2250171) (together Visionstream, we or us).

Visionstream is committed to complying with the privacy laws which apply to its business and respecting the privacy and security of any personal information it receives or collects.

When we handle personal information in Australia or New Zealand or of our Australian and New Zealand customers and business partners we are bound by either:

  1. the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs); or 
  2. the New Zealand Privacy Act 1993.

(as the case may require, Privacy Act).

This Policy details how we handle personal information in accordance with those requirements. It sets out the sort of personal information we collect, how that information may be used, and under what circumstances it may be disclosed by Visionstream.

This Policy does not apply to certain types of information which are not covered by the Privacy Act.

We will review and update this Policy from time to time to reflect our current information handling practices. We will notify you of any changes by posting an updated version of the Policy to our website.

 2.   Purpose

Personal information is any information (including an opinion) which can be used to identify you. Sensitive information is a subset of personal information which includes (for example) information about an individual’s race or ethnicity, political or religious beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences, criminal record and health information.

This Policy outlines how we handle personal information, including:

  1. the types of personal information we collect and hold;

  2. how and why we collect, hold, use and disclose that personal information;

  3. when we may disclose personal information overseas and, and in which countries;

  4. when we may collect personal information from and disclose personal information to third parties;

  5. confidentiality and security measures we apply in relation to personal information we hold;
  6. your right to access and seek correction of your personal information;
  7. how we will handle unsolicited personal information we receive;
  8. circumstances where we may destroy or de-identify your personal information;
  9. our use of cookies; and
  10. how you may complain about privacy matters and how we will handle your complaint.

 

3. What personal information do we collect?

Visionstream will only collect, use or disclose personal information where it is reasonably necessary for the purposes of our business, including to: enable us to deliver services or information to you or to an organisation you work for; maintain or establish a business relationship with you, including as a customer, supplier, contractor or staff member; enable us to assist you in using our services; improve, and better understand your preferences in respect of our services; and, fulfil our legal or regulatory obligations from time to time.

Situations in which Visionstream may collect personal information include:

  1. recruitment and engagement of staff, including contractors;
  2. when receiving services from our third party suppliers, including subcontractors;
  3. when providing services to our clients or customers;
  4. when providing travel services to our staff and their families;
  5. when required by law;
  6. when dealing with certain government agencies; and
  7. when visitors to our website provide their personal information, such as name and email address, via our website.

The types of personal information we may collect include:

  1. personal details, such as your name, mailing address, email address, telephone numbers, age and gender (and in the case of the provision of travel services, information recorded in your passport or visa documents);
  2. human resource information relating to staff, including directors and officers;
  3. details of visitors to Visionstream’s physical premises;
  4. applications for employment with Visionstream, including information relating to your personal skills, work history, experience and details of your performance, education, qualifications and skills professional memberships, hobbies and affiliations;
  5. details of referees and personal references;
  6. answers you provide to questions we ask which assist us to conduct our business, including to determine whether you are appropriate for employment; and
  7. stated or likely individual preferences, for example whether you are interested in receiving particular investor publications.

We collect personal information orally, in writing, by telephone, by e-mail, via our website and through other methods of communication.

Visionstream generally collects personal information directly from the individual to whom it relates, except where that individual has consented to Visionstream collecting the personal information from a third party or the law otherwise permits us to do so, or where it is unreasonable or impracticable for us to collect it directly.

We will only collect sensitive information directly from you with your consent, or where we are required, authorised or otherwise permitted to collect the information from a third party by law.

Personal information may also be collected from, and disclosed to, third parties in the course of our business activities. For example, Visionstream may take steps to verify that your academic, training and professional qualifications are accurate and complete and, in appropriate circumstances due to the nature of the available position, we may carry out health checks, credit checks or criminal records checks.

You have the option, where lawful and practicable, not to identify yourself when entering into transactions with Visionstream but unless we have agreed otherwise, it will be impracticable for us to do business with you unless you provide us with your personal information. 

3.1   Purposes for which we collect, hold, use and disclose personal information

Your personal information will be stored in our systems for our immediate business and administration purposes, as detailed above, and may be used or disclosed by Visionstream for the purpose for which it was collected, or for a related purpose which you may reasonably expect.

Sensitive information will only be disclosed for a purpose which is directly related to the purpose for which we collected it from you.

Your personal information may be disclosed between related bodies corporate within the Visionstream group, and used by those entities for the same purposes for which we are entitled to use it.  Visionstream may also use or disclose your personal information (including to overseas recipients):

  1. with your consent;
  2. where we are required, authorised or permitted to do so by law, including to any government agency if we believe in good faith that we must do so to comply with the law or that doing so is required to prevent, detect, investigate or remedy improper conduct potentially affecting Visionstream; or
  3. to a person authorised to act on your behalf.

We may also disclose your personal information to third party service providers and business associates who provide services in connection with our business. These third parties may be located locally or overseas.

 

3.2   Disclosure outside Australia or New Zealand

As detailed above, in some circumstances Visionstream may disclose your personal information to entities located outside Australia or New Zealand, including to our own related bodies corporate, third party service providers and business associates.

Where we disclose personal information overseas, we will comply with the requirements of the applicable Privacy Act and take all reasonable steps to ensure that the recipient will handle the information in a manner consistent with the applicable Privacy Act.

 

4. CONFIDENTIALITY AND SECURITY

We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, interference, unauthorised access, modification or disclosure and loss or corruption by computer viruses and other sources of harm.

We restrict access to personal information to those staff members, joint venture partners, related bodies corporate and third parties who need to know that information.

 

5. ACCESSING OR CORRECTING PERSONAL INFORMATION

You can request access to the personal information that we hold about you at any time.

We will respond to such a request within a reasonable time, and will try to give you full access to personal information in the manner you have requested, unless there is a legal or administrative reason we cannot do so. In some cases we may charge a reasonable fee for providing access.

We will also take reasonable steps to ensure the personal information that we hold is accurate, complete, up to date, relevant and not misleading.

At any time you may request that your personal information be corrected or supplemented if you believe it to be inaccurate or misleading. If we agree, the change will be made. If we disagree, we will advise you and include a notation on the record that you dispute the information’s accuracy.

Please contact us if you wish to access your personal information, if your personal information changes or if you believe that the personal information we hold is no longer accurate or complete:

  1. Visionstream staff may request access, corrections or supplements to their personal information by writing to the Manager, People and Capability;
  2. Job applicants may access, correct or supplement their personal information by emailing info@visionstream.com.au;
  3. All other requests for access, corrections or supplements to personal information should be made to:
    1. For Australia, The Proper Officer, Legal Department, Visionstream, Locked Bag 3, Bentleigh East Victoria, Australia 3165;
    2. For New Zealand, The Proper Officer, Legal Department, 8 Hereford Street, Freemans Bay Auckland NZ 1011; or
    3. In either case via email to The Proper Officer, Legal Department, legal@visionstream.com.au.  

We will respond to your request to correct or supplement your personal information within a reasonable time period.

 

6. DESTRUCTION AND DE-IDENTIFICATION OF PERSONAL INFORMATION

Our records management policies govern the archiving and destruction of records including personal information.  If we receive unsolicited personal information, it will either be handled in accordance with this policy or destroyed or de-identified as required by law. 

 

7. USE OF COOKIES

A cookie is a small text file downloaded onto your computer or mobile device when you access a website, including our website. Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website’s owners and third parties.

Cookies allow a website to recognise your computer or mobile device. Cookies do not identify you as an individual, but do identify the computer or mobile device you use to access the Internet and can therefore be used to collect information about your use of the Internet. Cookies do not allow access to any information stored on your computer or mobile device.

We may use cookies from time to time, and when we do, cookies are used to:

  1. determine the number of visitors to our website and to identify how visitors move around the site and, in particular, which pages they visit. This allows us to improve our website and our services;
  2. determine from where in the world our website is being visited so that we can ensure sufficient coverage; and
  3. collect information, where available, about your computer or mobile device for system administration purposes, such as your IP address, operating system and browser type.

 

We will only use information collected through the use of cookies to evaluate our website’s effectiveness and to improve your experience when you visit it. Cookies are not used by us to identify who you are or send you targeted advertising.

 

8. LINKS TO OTHER WEBSITES

Our website provides hyperlinks to websites owned and controlled by others. Visionstream is not responsible for the privacy practices of these websites. By accessing or using our website you consent to the collection, use and disclosure of your personal information as described in this Policy, as amended from time to time.

 

9. COMPLAINTS AND FURTHER INFORMATION

If you have a question, concern or complaint regarding the way in which we handle your personal information, or if you believe that Visionstream has breached its obligations under the relevant Privacy Act or has failed to comply with this Policy, you can make a complaint.

Any complaint should be made in writing to:

  1. For Australia: The Proper Officer, Legal Department, Visionstream, Locked Bag 3, Bentleigh East Victoria, Australia 3165;
  2. For New Zealand: The Proper Officer, Legal Department, Visionstream, 8 Hereford Street, Freemans Bay Auckland NZ 1011; or
  3. In either case, via email to legal@visionstream.com.au.

 Visionstream will review and respond to your complaint as soon as possible, and generally within 30 days of receiving it.

 If you are not satisfied with our response, as may be applicable, you can refer your complaint to:

a)     the Office of the Australian Information Commissioner (OAIC); or

b)      the Office of the Privacy Commissioner (New Zealand).