GWA Group Limited and each of its wholly owned subsidiaries (collectively “GWA”, “we”, “us”, “our”) respect the privacy of information with which we are provided.
1. What is personal information?
Personal information is any information or opinion about you or an identifiable individual whether that information actually identifies you or not, or information from which your identity or that of another person can be reasonably determined.
2. Kinds of personal information that we collect
We may collect personal information about you in the course of your dealings with us. We will only collect such information as is necessary for our business functions.
The type of personal information we collect will depend on your dealings with us. The kinds of personal information we may collect include:
If you apply for a job with us then the personal information we collect may include your resume, qualifications, skills, education history, work history and residency status.
We generally do not collect sensitive information, however if we do we will only collect it with your consent.
From time to time, you may be able to visit our website or deal with us anonymously or by pseudonym. However, we require certain personal information to be able to provide you with the services and information you request. If you do not provide us with certain personal information, we may not be able to provide you with access to those services or respond to your request, or we may need to request that personal information at a later time.
3. How do we collect your personal information?
We may collect personal information from our customers, prospective employees, contractors, individuals from our suppliers or trading partners, and existing or possible consumers of our products and services.
We may collect personal information:
We also collect personal information about you when you use our apps and digital tools on your mobile device and our websites. When you do so, the information we collect may include the type of device you are using and information about your usage and in some cases your location.
Where it is reasonable and practicable to do so, GWA will collect personal information directly from you. On occasions, your personal information may be collected from the following third parties:
Where we collect information from a third party, we will notify you that we have collected that information.
4. Why do we collect, hold, use and disclose your personal information?
We collect, hold, use and disclose your personal information for the purposes for which we collected it, and for other related purposes that you would reasonably expect. These may include:
We may also use or disclose your personal information:
If you consent, we may send you promotional offers and other direct marketing material about events, products and services we believe may be of interest to you by mail, phone, fax, email, or SMS. You can opt out of receiving marketing and promotional communications at any time through any opt out method notified to you in the communication that we send to you, or by sending your request to us through the following methods:
In some situations we may collect some additional identity information for the purpose of enabling us to verify your identity (which we may do, for example, when you enter a promotion or make an inquiry over the internet or wish to obtain copies of our price lists or catalogues).
If you do not provide your personal information, we may be unable to do one or more of the above.
6. To whom do we disclose your personal information?
We may disclose your personal information to:
7. Disclosure of personal information overseas
Any personal information you provide to us, including via our websites or through our applications may be collected, processed and stored by our website service provider and digital agency service provider. Our service providers will collect and process your personal information on our behalf, and disclose it to us so that we may use it for the purposes set out in this policy. This may involve disclosure of your personal information to service providers who are likely to be located in Australia, New Zealand and India.
We also make use of cloud service providers for the purposes of data storage and enterprise management, whose servers may be located in various countries around the world.
8. Ensuring your personal information is up to date
We rely on the personal information we hold about you to effectively conduct our business. For this reason, it is important that the information collected is accurate, complete and up to date. We will take reasonable steps to ensure that your information is accurate, up to date and complete. In addition, you may contact us at any time using the methods outlined below to update your personal information.
9. How do we hold your personal information?
Personal information is mainly held in secure electronic databases, but we may also hold hard copies of information. We take reasonable precautions to safeguard your personal information from loss, misuse, unauthorised access, modification or disclosure.
We will take reasonable steps to destroy or permanently de-identify your personal information when we no longer require it for any purpose for which it was collected. We may retain your personal information for as long as necessary:
Your personal information may also be retained in our IT system back-up records and will be deleted only as part of our usual data retention and refresh policies.
The transfer of data over the internet is inherently insecure. We cannot guarantee the security, during transmission, of any personal information provided to us via our websites. Please bear this in mind when transmitting information by this means to us.
10. Access to and correction of your personal information
You may lodge a request to correct personal information that we hold about you if you believe it is inaccurate, incomplete, out-of-date, irrelevant or misleading, in which case please contact our Privacy Officer via the contact details shown below.
You may request that we provide you with access to the personal information we hold about you. Generally, we will provide you with access, except in limited circumstances where the law permits us to deny access. Any such requests must be made in writing to us via the details shown below.
If we refuse to give you access or update your personal information, we will provide you with the reasons for our refusal.
11. How to notify us of your concerns or lodge requests for access
you can do this by:
12. How can I make a complaint?
If you have a complaint about the way that we have handled your personal information, you may lodge a complaint by:
All complaints are reviewed and considered by the GWA Privacy Officer. We will generally respond to complaints within 30 days, or within timeframes otherwise required by law.
13. What if I’m not satisfied with GWA’s response?
If you are not satisfied with the result of your complaint to GWA, you can refer your complaint to the relevant Privacy Commissioner.
In Australia, the Office of the Australian Information Commissioner can be contacted by:
In New Zealand, the Office of the Privacy Commissioner can be contacted by: