Altogether Perfect (AP) is committed to protecting the privacy and security of any personally identifiable information.
This policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.
1.1 AP will only collect Personal Information where the information is necessary for AP to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 AP collects Personal Information primarily for the purpose of responding to and fulfilling your requests for our products and services.
Generally, we may collect personal information from you when you:
- Make a booking;
- Deal with us over the telephone;
- E-mail us;
- Request a publication or sign up to our newsletter or ‘Friends of the Hunter Valley’;
- Enter a competition or trade promotion
AP also collects and uses Personal Information for secondary purposes:
- provision of related products and services,
- accounting purposes;
- business planning and product development.
1.3 AP will notify individuals (including, but not limited to, our customers) of the matters listed below at the time of collecting any Personal Information:
- the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
- other related Uses or Disclosures that we may make of the Personal Information(Secondary Purposes);
- if it might be disclosed to third parties, and if so, the names of those parties;
- our identity and how individuals can contact us, if this is not obvious;
- that individuals can access the Personal Information that AP holds about them;
- that individuals should contact AP if they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;
- the organisations or types of organisations to whom we usually Disclose the Personal Information;
- where applicable, any law that requires the Personal Information to be collected;
- the consequences (if any) for the individual if all or part of the Personal Information is not provided to AP.
1.4 AP will not collect Sensitive Information from individuals except with express consent from the individual and only where it is necessary for AP to collect such information for an activity or function.
1.6 AP will not collect Personal Information secretly or in an underhanded way.
2.1 AP will use your personal information for a purpose only for which it is relevant. This means we will use your personal information only for the particular purpose that you provided it, or for a directly related purpose.
In other words, we may also use your personal information for a related secondary purpose where that other use is:
- required or permitted by law; or
- with your express or implied consent.
2.2 If AP relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:
- individuals are clearly notified of their right to Opt Out from further Direct Marketing; and
- if the individual Opts Out of all Direct Marketing the Opt Out will be respected by AP and implemented free of charge.
2.4 AP will not use Sensitive Information for Direct Marketing.
2.5 AP may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 AP will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
2.7 AP will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.
3.1 AP may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.
3.2. AP, in order to deliver on the goods & services provided on its website, discloses information to its accommodation and tourism product suppliers
- AP provides the guest name, telephone number, address and email address for each booking made to the relevant supplier. Our suppliers require this information for the provision of their services to customer. Although AP offers services from reputable suppliers, we have not placed specific limitations on these suppliers from using or disclosing information without permission. AP encourages individuals to review the privacy policies of the suppliers’ the goods or services have been purchased from.
3.2 AP will take reasonable steps to ensure that its contracts with other third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
3.4 In the rare event that AP is required to disclose Personal Information to law enforcement agencies, government agencies or external advisors AP will only do so in accordance with the Privacy Act or any other relevant Australian legislation.
3.5 AP may Disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
3.6 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, AP will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
3.7 AP does not generally share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved.
4. Information Quality
4.1 AP will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 AP will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.
5. Information Security
5.1 AP requires employees and contractors to perform their duties in a manner that is consistent with AP’s legal responsibilities in relation to privacy.
5.2 AP will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within AP who have a genuine “need to know” as well as “right to know”.
5.3 AP will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6. Access and Correction
6.1 AP will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 AP will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting AP on firstname.lastname@example.org.
6.4 AP will not normally charge a fee for processing an access request unless the request is complex or is resource intensive.
7.1 Contact with AP via phone or web inquiry will be the first point of contact for inquiries about privacy issues.
7.2 Any formal privacy related complaints should be directed in writing to Hunter Valley Wine & Tourism Association, 455 Wine Country Drive, Pokolbin NSW 2325 Australia.
7.3 AP will endeavour to manage any privacy related complaint efficiently and in a timely manner.
8. Anonymous Transactions
8.1 AP will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service or product. AP may however request visitors to provide Personal Information voluntarily to AP (for example, as part of a competition or questionnaire).
8.2 AP will allow its customers to transact with it anonymously wherever that is reasonable and practicable.
Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.
Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of AP, the association’s members or those of an independent third party organisation.
Disclosure generally means the release of information outside AP, including under a contract to carry out an “outsourced function”.
Health Information means:
- information or an opinion about:
i. the health or a disability (at any time) of an individual; or
ii. an individual’s expressed wishes about the future provision of health services to him or her; or
iii. a health service provided or to be provided to an individual;that is also personal information; or
- other personal information collected to provide or in providing a health service; or
- other personal information about an individual collected in connection with the donation; or intended donation by the individual of his or her body parts or body substances.Opt Out means an individual’s expressed request not to receive further Direct Marketing.
Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.
Reasonable Expectation means a reasonable individual’s expectation that their personal information might be Used or Disclosed for the particular purpose.
Sensitive Information means:
- information or an opinion about an individual’s:
racial or ethnic origin; or
ii. membership of a political association; or
iii. religious beliefs or affiliations; or
iv. philosophical beliefs; or
v. membership of a professional or trade association; or
vi. membership of a trade union; or
vii. sexual preferences or practices; or
viii. criminal record; that is also personal information or; or
- Health Information about an individual
Use means the handling of Personal Information within AP.