THE KADEN CENTRE LIMITED (ABN: 30620923668), its related bodies corporate, officers, employees, agents and contractors (‘Kaden Centre’, ‘Kaden’, ‘our’, ‘us’ or ‘we’) are committed to providing you with the highest possible protection for your Personal Information.
In this Policy “Personal Information” is any information or opinion that identifies you, or can be used to identify you, whether the information or opinion is true or not and whether the information or opinion is recorded in material form or not. For example, your name, age, address or contact details.
Information is not Personal Information where the information cannot be linked to an identifiable individual.
Personal Information is information which is regulated by the Privacy Act 1998 (Privacy Act) as amended from time to time. We are committed to complying with the Privacy Act in relation to all Personal Information we collect. For example, when entering into an agreement to become a member or subscribe to our services it will be necessary for your Personal Information to be disclosed to us.
Our Privacy Policy applies to any person in relation to whom we currently hold, or may in the future collect, Personal Information.
We may modify this Privacy Policy from time to time, and if we do, we’ll publish it on our website. If you would like us to send you a copy of the policy, just let us know.
COLLECTION OF PERSONAL INFORMATION
Where we can, we will allow you to deal with us anonymously or by using a pseudonym. If you would like to use a pseudonym or remain anonymous when dealing with us, you should notify us and we will try to accommodate your request, subject to our ability to perform the services. However, in the course of your dealings with us it may be necessary for you to disclose your Personal Information to us or for us to collect it from you.
The type of Personal Information we collect and hold about you will depend on the circumstances and the nature of the relationship between Kaden Centre and the person that we are collecting the Personal Information from. Broadly, we collect Personal Information relating to prospective and actual clients, contractors, subcontractors and agents who perform services on our behalf, and prospective employees and prospective agents, contractors and subcontractors. Generally, the Personal Information that we collect and hold will include information which is relevant to providing our services to you, including responding to your enquiries our Home Programs, Membership, or information which is relevant to engaging you.
For example, the types of Personal Information that we may collect and hold includes:
- individual and company data including, name, postal address, email address, contact numbers;
- proof of identification documents such as a driver’s licence or passport;
- profile related data such as age group, marital status, lifestyle interests;
- details about your personal requirements and preferences in relation to our products or services;
- information in relation to other people who come into contact with Kaden Centre;
- any information that you may provide to us, either directly or through our website, or via our staff or representatives; and
- any additional information necessary to deliver products and services to you or engage you.
This is not an exhaustive list as Kaden Centre may be required to collect further information in fulfilment of its service to clients.
We do not actively seek to collect sensitive information about clients/clients but in some cases, we may collect sensitive information if it is relevant in providing our products and services.
We will not collect sensitive information without the individual’s consent to which the information relates unless permitted under the Privacy Act.
Kaden Centre may collect Personal Information by way of electronic and hard copy enquiry forms and by way of questionnaires, exhibition attendance, social media campaigns, website forms, inbound and outbound telemarketing campaigns and in person.
At or before the time Personal Information is collected (or as soon as practicable after), Kaden Centre will take reasonable steps to inform the individual about the purpose for which the information is collected, the rights to access the information and other matters contemplated by law unless it is obvious from the circumstances.
Should the Kaden Centre seek to disclose information to another organisation, reasonable steps will be taken to ensure the individual is aware of the organisation or the type of organisation to receive the information.
Generally, Kaden Centre will collect Personal Information directly from the individual concerned unless it is not reasonable or practical or the individual consents to the information being collected from a third party. We may also collect Personal Information in other ways, such as:
- from government bodies;
- from paid search providers and public registers;
- through referrals from individuals or other entities;
- from your advisors;
- from your doctor;
- from your health advisor;
- from your carer;
- from banks and financial institutions; and
- from our agents, contractors and subcontractors.
If we do receive unsolicited Personal Information about you and it is not needed in respect of your purchase or enquiry, then we will destroy or de-identify that information (unless prohibited by law).
PURPOSES FOR COLLECTION, HOLDING, USE AND DISCLOSURE
Our primary purpose for collecting, using, holding and disclosing Personal Information varies, depending on the type of information and the individual from whom we are collecting the information, but is generally as follows:
- in the case of current or prospective clients – to provide our products and services to you, which may involve the following secondary purposes:
- to manage and perform any contract entered into between you and Kaden Centre;
- to help us identify and develop products and services that may interest you;
- to maintain and enhance our relationship with you;
- to conduct market or client satisfaction research;
- to conduct promotions;
- to invite you to events;
- to send you newsletters;
- to ensure compliance with legislative and regulatory requirements;
Kaden Centre is committed not to hold, use or disclose Personal Information that it has collected, other than in the manner contemplated by the relevant law. In particular, Kaden Centre’s policy is not to hold, use or disclose Personal Information other than for the primary purpose for which it was collected or any reasonable secondary purposes that are within an individual’s reasonable expectations and that are related to the primary purpose of collection.
It is Kaden Centre’s policy to obtain its clients’ consent before it uses information for a purpose or in a manner different to the purpose for which it was originally collected.
Personal Information may be shared between Kaden Centre and other organisations or persons such as:
- our suppliers, partners, contractors, subcontractors and agents including business support service providers (for example, software suppliers and data back up providers) we engage from time to time;
- employers of individuals;
- government bodies
- our external auditors;
- banks;
- advisors; and
- insurance providers and brokers,
however, no Personal Information will be sold or disclosed to companies not engaged by us to assist us to perform our services.
Depending on the circumstances, Kaden Centre may be under a legal obligation to disclose Personal Information to third parties, such as a law enforcement agency. Kaden Centre will endeavour to disclose this information in accordance with the relevant law and will inform you of any such disclosure and the content of the information disclosed (unless prohibited to do so by law).
Otherwise, we will only disclose Personal Information to third parties if permitted by the Privacy Act.
By providing your Personal Information to us, you agree and consent to any disclosures by us of your information to an individual or organisation for any of our purposes listed above.
KADEN CENTRE’S MARKETING ACTIVITIES
It is important for Kaden Centre to maintain contact with its clients and potential clients. That contact may involve the sending of advertising material through the post or by email to existing and potential clients. In these circumstances, it is Kaden Centre’s policy to comply with the stated purpose for which Personal Information was collected and consequently we will only ever contact you if you give your permission. Kaden Centre’s existing and potential clients will always have the opportunity to decline to receive further marketing material and can ask to be removed from our marketing lists at any time. If Kaden Centre receives such a request, Kaden Centre will update its records appropriately, within a reasonable time.
DISTRIBUTION OF PERSONAL INFORMATION
Kaden Centre employs a number of agents, contractors and subcontractors in the course of its business activities. It is sometimes necessary for Kaden Centre to give its agents, contractors and subcontractors access to Personal Information held about its clients in order to provide its services. In these circumstances, it is Kaden Centre’s policy to require the agents, contractors or subcontractors who receive from Kaden Centre Personal Information about clients to comply with Kaden Centre’s privacy policy, which includes compliance with the relevant laws.
Organisations or individuals outside Kaden Centre are required to respect clients’ rights to privacy and also to use the information in accordance with Kaden Centre’s purposes and directions.
It is Kaden Centre’s policy not to sell Personal Information about existing or potential clients to any organisation.
SECURITY OF PERSONAL INFORMATION
Kaden Centre takes reasonable steps to protect and secure Personal Information that it collects from misuse, interferences, loss, unauthorised access, modification or disclosure. Our usual approach to holding Personal Information is to hold that Personal Information electronically on secure servers. We secure the Personal Information we hold in numerous ways, including by requiring unique passwords and security access IDs to restrict access to environments storing Personal Information.
Kaden Centre will take reasonable steps to destroy or permanently de-identify Personal Information if it is no longer needed for any purpose for which the information may be used or disclosed, unless prohibited by law.
DATA BREACHES
A data breach occurs when Personal Information is lost or subjected to unauthorised access, use, modification or disclosure or other misuse or interference.
We have implemented a data breach response plan to assist us to effectively contain, evaluate and respond to data breaches in order to mitigate potential harm to any persons affected by a data breach.
In summary, our data breach response plan:
- directs our staff as to the steps they should take in the event of an actual or suspected data breach;
- appoints a team to handle data breaches;
- specifies a strategy for assessing and responding to data breaches;
- sets out the process for notifying any affected persons, the Privacy Commissioner and other relevant parties; and
- outlines our review process to help prevent data breaches in the future.
We will generally notify you if we reasonably believe that your Personal Information has been subjected to a data breach if:
- there is a risk of serious harm to you;
- notification could enable you to avoid or mitigate serious harm;
- the compromised Personal Information is sensitive or likely to cause humiliation or embarrassment to you; or
- we are required to notify you by law.
We will also notify the Privacy Commissioner if we reasonably believe that your Personal Information has been subjected to a data breach that is likely to result in serious harm to you. Where appropriate, we may also notify other third parties of a data breach.
ACCESS TO AND CHANGING PERSONAL INFORMATION
Kaden Centre will, if requested to do so, give individuals copies of the Personal Information that Kaden Centre holds about them, unless prevented by law from giving this information to you. Before such information is released, Kaden Centre will require reasonable proof of identity from the enquiring person. Any requests for copies of Personal Information should be directed to Kaden Centre’s Development Director. We will grant a person access to their Personal Information as soon as possible, subject to the circumstances of the request.
A request to access Personal Information may be rejected if:
- the request is unreasonable;
- providing access would have an unreasonable impact on the privacy of another person;
- providing access would pose a serious and imminent threat to the life or health of any person; or
- there are other legal grounds to deny the request.
Kaden Centre may charge you a reasonable fee for access to your Personal Information, but we will advise you of the fee before we process your request.
If access to information is to be denied (e.g. if required by law), Kaden Centre will provide reasons for the denial.
If any individual wishes to update or correct Personal Information held by Kaden Centre about them, Kaden Centre will do so on receipt of a written request addressed to Kaden Centre’s Development Director. This is in keeping with Kaden Centre’s policy to maintain accurate records.
We do our best to make sure that the Personal Information we hold about you is accurate, up to date and complete. If you believe we need to update your Personal Information just let us know. We will promptly update it and confirm to you when we have done so.
OVERSEAS USE OF INFORMATION
We do not generally disclose your personal information to overseas recipients.
KADEN CENTRE’S WEBSITE
When Kaden Centre’s website is visited, the website may send “cookies” to the visitors’ computer. Cookies are used in transactions over the internet for various reasons including the maintenance of security. Cookies can also be used to monitor the areas of a website that are visited. Visitors to Kaden Centre’s website who do not wish to receive cookies should select the appropriate settings in their web browser.
We do not use cookies to collect personally identifiable information about a person.
PRIVACY COMPLAINTS OR QUESTIONS
If you have a privacy complaint or question, would like to know what Personal Information we hold about you, or would like to update your Personal Information please contact our Development Director:
Loukas Nadiotis
E: loukas@kadencentre.org.au
A: Unit 2/4 Ironbark Close
Warabrook
NSW 2304
Our Development Director will endeavour to respond to your privacy questions, or resolve any privacy concerns you have in a timely manner.