- Policy Introduction
- Collection of Personal Information
We may collect personal information about an individual in a variety of ways, including when an individual interacts with us in person or electronically, for example when some individual accesses our website.
ProMed will only collect personal information about an individual where the information is reasonably necessary for one or more of our functions or activities. The kinds of personal information collected and held, how that information is collected and held and the purposes for which that information will be collected, held, used and disclosed will depend on the circumstances.
Examples of instances where personal information may be collected byProMed include:
i. collecting personal information from shareholders for the purposes of enabling proper records to be kept and for reporting purposes; and
ii. collecting personal information from individuals who enter into service agreements, joint venture agreements or other transactions with ProMed for the purpose of administering those agreements or transactions or for reporting purposes.
Examples of the kinds of personal information ProMed may collect and hold include:
iii. phone number;
iv. fax number;
v. email address;
vi. information about goods or services ordered, acquired or supplied;
vii. information from enquiries made;
viii. communications between ProMed and an individual; and
ix. credit card information.
ProMed will take reasonable steps to ensure that the personal information that is collected, used or disclosed by it is complete and up to date. ProMed will only collect personal information about an individual from that individual unless it is unreasonable or impractical to do so.
Use and Disclosure of Personal Information
At or before, or if that is not practicable, as soon as practicable after, the time that the personal information is collected, ProMed will take reasonable steps to ensure that the individual is aware of the matters required by the Australian Privacy Principles, including:
i. why the personal information is being collected;
ii. who else the personal information might be given to;
iv. how to contact ProMed, including to make a complaint.
If ProMed collects personal information about an individual from someone else, ProMed will take reasonable steps to ensure that the individual is aware that ProMed has collected the information and of the above matters.
ProMed will only use or disclose this personal information for:
i. the purpose for which it was collected;
ii. any related purpose for which it would reasonably be expected to be used or disclosed;
iii. a purpose required or permitted by law; or
iv. a purpose for which the individual has provided consent.
Examples of instances where ProMed may disclose personal information about individuals to third parties include disclosure to providers of services to ProMed, government agencies, regulatory authorities, related bodies corporate of ProMed and professional advisers of ProMed. ProMed requires its service providers to keep the personal information confidential and not use it for any purpose other than performing those services.
Where the Privacy Act so permits ProMed may also disclose credit-related information (in respect of commercial credit) to CRBs such as Veda or Dunn & Bradstreet, if it receives an application for commercial credit or a request to increase a commercial credit limit with ProMed.
Where ProMed collects information that it is likely to disclose to a CRB:
the CRBs may include that information in reports provided to ProMed to assist it to assess your creditworthiness;
*if you fail to meet payment obligations in relation to commercial credit or commit a serious credit infringement, ProMed may be entitled to disclose this to the CRB;
ProMed will only disclose personal information to CRBs where ProMed is a member of a recognised External Dispute Resolution Scheme (‘EDR Scheme’). If ProMed discloses your personal information to CRBs, ProMed will provide you written notice prior to that disclosure, as well as the details of the recognised EDR Scheme.
ProMed does not disclose personal information for any secondary purposes without the relevant person’s consent or as required by law, and it does not sell or license any personal information that it collects.
ProMed is unlikely to disclose personal information to overseas recipients.
- Security of Personal Information
ProMed will take reasonable steps to ensure that the personal information that it holds is protected from misuse, interference and loss and from unauthorised access, modification and disclosure.
ProMed will also take reasonable steps to ensure that personal information it holds that is no longer necessary for the disclosed purpose is destroyed or permanently de-identified, subject to any legal obligation to keep the personal information for any required period of time.
Access to, Updating and Correcting Personal Information
At the request of an individual, ProMed will, in most circumstances, provide access to an individual to any personal information that is being held by ProMed about that individual.
There are certain circumstances where ProMed will not provide an individual access to such personal information in accordance with the Act. These circumstances include where providing access would have an unreasonable impact on the privacy of others, where providing access would reveal commercially sensitive information about the organisation or where providing access would be unlawful.
An individual can seek access to, and update or correct, any personal information that is being held by ProMed about that individual by contacting us here.
- Amendment of Policy - ProMed may amend this Policy from time to time.
- Intranet and Website - This Policy as amended from time to time is to be placed on theProMed intranet and website and is also available upon request
- Concerns, Queries and Complaints
If a person has any concern, query or complaint about:
i. any personal information that may have been collected, used or disclosed by ProMed
iii. a breach of the Australian Privacy Principles,
they are to be referred to the Company Secretary/Chief Financial Officer.
ProMed takes a complaint seriously and will respond shortly after receiving written notice of the complaint.