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Privacy

Description:

In the conduct of its business WCB necessarily seeks, records and uses personal information of individuals. The appropriate management of this information is very important to WCB and the individual to whom the information belongs.

Scope:

Organisational level

Related Policies

None

Policy Administration:

CFO and Company Secretary, General Manager ICT/PMO, General Manager HR

Revised in:

December 2016

  1. Purpose of this Policy

    The purpose of this privacy policy is to provide information about the Personal Information Warrnambool Cheese and Butter Factory Company Holdings Limited (WCB) collects, how that information will be handled, how you can access and correct your Personal Information and how to make a complaint about WCB's handling of the information.

    WCB is committed to meeting its compliance obligations and protecting personal information.

    The Privacy Act 1988 (Privacy Act) introduces thirteen Australian Privacy Principles (APPs) which regulate the handling of Personal Information. As WCB is an APP Entity (as defined in the Privacy Act), it must comply with the APPs. This Privacy Policy sets out how WCB complies with the APPs.

  2. Personal Information, Sensitive Information and Anonymous Information

    As is required by the Privacy Act, WCB ensures the protection of any Personal Information it receives. 

    'Personal Information' is defined in the Privacy Act as:

    information or an opinion about an identified individual, or an individual who is reasonably identifiable:

    1. whether the information or opinion is true or not; and
    2. whether the information or opinion is recorded in a material form or not.

       

      ‘Sensitive Information’ includes, but is not limited to, things such as race, sexual orientation, political opinions, members of a trade association or trade union, criminal record or health information. 

      ‘Anonymous Information’ is gathered anonymously. The information is not associated with you as an individual, by itself or in combination with other information.

  3. Type of Information Collected

     

    WCB collects and holds the following kinds of Personal and Sensitive Information from individuals, who include employees, milk suppliers and customers:

    • Name, date of birth and home address
    • Mailing address 
    • Gender
    • Telephone numbers 
    • E-mail address 
    • Occupation 
    • Employment history 
    • References 
    • Remuneration 
    • Banking details
    • Tax file number
    • Superannuation fund
    • Motor vehicle licence
    • Educational history
    • Emergency contact 
    • Membership of professional or trade associations and trade unions 
    • Health information - pre and post employment medical test results
    • Health information - Workcover claims
    • Drug and alcohol testing results

       

  4. Collection of Personal Information
    • 4.1.WCB collects Personal Information only by fair and lawful means where it is reasonable and practicable to do so. 
    • 4.2.If WCB is required to collect Personal Information under an Australian law or a court/tribunal order, WCB will inform you that the collection is so required, including details of the law or court/tribunal order requiring the collection. 
    • 4.3.WCB collects Personal Information during your transaction with WCB to enable WCB to provide the goods and services to you. If you fail to provide the Personal Information, WCB may be unable to enter into the transaction with you. 
    • 4.4.WCB also collects Personal Information through its website to enable WCB to:
      • 4.4.1.enforce the website's terms of use; and
      • 4.4.2.prevent potentially prohibited or illegal activities for security purposes.
    • 4.5.WCB will only collect Personal Information about you from you, unless:
      • 4.5.1.you consent to the collection of the information from someone else; or  
      • 4.5.2.it is unreasonable or impracticable to collect the information from you.  
    • 4.6.If WCB collects Personal Information from a third party, WCB will inform you that Personal Information has been collected and the circumstances of such collection. 
    • 4.7.WCB will not collect Personal Information (other than Sensitive Information) unless the information is reasonably necessary for one or more of WCB’s functions or activities.
    • 8.3.WCB holds Personal Information to:
      • 8.3.1.ensure transactions can be completed;
      • 8.3.2.keep its database up to date; and
      • 8.3.3.comply with applicable laws. 
    • 8.4.When personal information is no longer required, such steps as are reasonable in the circumstances are taken to destroy or de-identify the information.  Where it is not practical to do so such steps as are reasonable in the circumstances are taken to protect the Personal Information against loss, unauthorised access, use, modification or disclosure, and against other misuse.
    • 9.3.WCB may use or disclose Personal Information (other than Sensitive Information) about you for the purposes of direct marketing if WCB collects the information from you and you would reasonably expect WCB to use or disclose the information for the purpose of direct marketing.  
    • 9.4.WCB may also use or disclose Personal Information (other than Sensitive Information) for the purposes of direct marketing if it is collected from someone other than you and either:
      • 9.4.1.you have consented to the use or disclosure of the information for the purpose of direct marketing; or
      • 9.4.2.it is impractical to obtain that consent.
    • 9.5.You may, by notice in writing to WCB:
      • 9.5.1.request not to receive direct marketing communications; or
      • 9.5.2.request for your Personal Information to not be used or disclosed for direct marketing purposes. 
    • 9.6.WCB may only use or disclose Sensitive Information about you for the purposes of direct marketing if you have consented to the use or disclosure of the information for that purpose. 
    • 9.7.WCB may also use or disclose Personal Information where WCB is permitted by the Privacy Act to do so.
    • 9.8.WCB may also disclose your Personal Information to service providers to help WCB to do any of those things.
    • 9.9.WCB may disclose Personal Information to companies affiliated with WCB located in Canada or in the United States or to any successor in interest to its business by merger, sale of assets, reorganization, operation of law or otherwise.
    • 10.4.WCB may charge a fee to cover its reasonable costs in meeting an access request.
    • 10.5.If you wish to seek a correction of your Personal Information, you must lodge a request seeking correction with WCB through the contact details listed below.
  5. Collection of Sensitive Information

    WCB will not collect Sensitive Information about you unless:  

    • 5.1.you consent to the collection of the information; or
    • 5.2.the information is reasonably necessary for one or more of WCB’s functions or activities; or
    • 5.3.the collection of the information is required or authorised by or under law or a court/tribunal order; or  
    • 5.4.a permitted general situation exists in relation to the collection of the information by WCB; or  
    • 5.5.a permitted health situation exists in relation to the collection of the information by WCB.
  6. Collection of Anonymous Information

    WCB also collects certain Anonymous Information regarding the usage of its website. This information is gathered to improve the performance of the website and to help us determine which features and services are most important to visitors. The Anonymous Information collected may include information such as the type of browser you are using, the website’s pages viewed, your IP address and the length of the visit to the website.

  7. Unsolicited Personal Information 

    Where WCB receives Personal Information which was not solicited by us, WCB must, within a reasonable period after receiving the information, determine whether or not WCB could have collected this information under APP 3.  If it is determined that WCB could not have collected the Personal Information and that the information is not contained in a Commonwealth record, then WCB must as soon as practicable, destroy the information or make sure the information is de-identified, as long as it is reasonable and lawful to do so.

  8. Storage of Personal Information
    • 8.1.WCB will take such steps as are reasonable in the circumstances to protect the security of the Personal Information that WCB holds. This includes taking appropriate measures to protect electronic materials and materials stored and generated in hard copy.
    • 8.2.Personal Information collected will be held:
      • 8.2.1.if the information is in hard copy in locked filing cabinets or locked storage facilities.
      • 8.2.2.if the information is in soft copy, on WCB’s or its affiliates’ electronic filing systems or with the assistance of WCB's services providers located in Australia and overseas in Canada and in the United States. Access to this information is restricted by various security methods and controls including fully managed firewalls, anti-virus and intrusion detection, user access restrictions/role based permissions, penetration and vulnerability testing and restricted access facilities.
  9. Use and disclosure of personal information
    • 9.1.Your Personal Information will be used or disclosed for the purpose for which it was collected. This includes:

      (a) to respond to a query from you; and

      (b) to provide you with goods and services.

    • 9.2.WCB may use or disclose Personal Information (other than Sensitive Information) about you for the purpose of marketing if:
      • 9.2.1.WCB collected the information from you; and
      • 9.2.2.you would reasonably expect WCB to use or disclose the information for that purpose.
  10. Accessing or Correcting Personal Information
    • 10.1.WCB aims to ensure that the Personal Information it holds is accurate, up to date and complete. Please ensure any information you provide is accurate, up to date and complete, and notify WCB if you believe it holds information that is outdated, inaccurate or incomplete.
    • 10.2.You are entitled to access your Personal Information held by WCB at any time.
    • 10.3.If you wish to access your Personal Information, you must lodge a request for access with WCB through the contact details listed below. WCB is entitled to deny access to you where WCB is entitled by law to do so, including:
      • 10.3.1.providing access would create an unreasonable impact on the privacy of others;
      • 10.3.2.providing access would pose a serious threat to life, health or safety to any individual or to public health or public safety;
      • 10.3.3.the request is frivolous; or
      • 10.3.4.denial of access is otherwise authorised by law.
  11. Enquiries and Complaints

    Individuals wishing to make enquiries or lodge a complaint in relation to how WCB handles Personal Information are encouraged to do so. At first instance enquiries or complaints about breaches of the APPs by WCB should be made directly to the Company Secretary, on:

     

                    Telephone:     03 5565 3185

                    Email:            Paul.Moloney@saputo.com

                Mail:              Company Secretary

    Warrnambool Cheese and Butter

    5331 Great Ocean Road

    Allansford, Victoria 3277

     

    WCB will respond to a complaint within a reasonable time after receipt of the complaint. If WCB is unable to resolve a complaint to the satisfaction of the individual, he or she may be able to refer the matter to the Office of the Australian Information Commissioner (www.oaic.gov.au), who can be contacted by phoning 1300 363 992 or emailing enquiries@oaic.gov.au.

  12. Modifications to Policy

WCB reserves the rights to modify this policy, along with related procedures, at any time without prior notice. Modifications to the policy will be posted on WCB’s website and will become effective on the day that they are posted.