1.1 Colpak Logistics Pty Ltd (A.C.N. 107 564 198) (Colpak) recognises that the privacy of personal information is important and is committed to protecting personal information that it collects and holds. The Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles set out the applicable legal requirements with respect to the management of personal information.
1.2 This policy sets out how Colpak collects, uses, discloses and otherwise manages personal information. ‘Personal information’ is information or opinions relating to an identifiable individual. Information is not personal information where it cannot be linked to an identified individual.
1.3 This policy does not apply to acts and practices that directly relate to employee records of Colpak’s current and former employees.
1.4 The policy is effective from 1 October 2019.
Types Of Personal Information Colpak Collects
2.1 The types of personal information that Colpak may collect and hold in relation to customers, subcontractors, employees and prospective employees including:
(a) contact information;
(b) financial information;
(c) banking information;
(d) credit information; and
(e) information that Colpak is legally required to collect.
2.2 ‘Sensitive information’ is a special category of personal information and includes information that could have serious consequences for the individual if it is used inappropriately. Colpak may, with the consent of the individual, collect sensitive information about subcontractors and prospective employees including:
(a) medical history;
(b) drug and alcohol test results;
(c) criminal history; and
(d) membership of unions and professional associations.
2.3 Colpak will not collect sensitive information without the individual’s consent to whom the information relates unless it is permitted to do so under the Privacy Act.
2.4 Colpak also collects video recordings and photographs from in-vehicle cameras and closed-circuit television cameras at its business premises.
What Types Of Credit Information Does Colpak Collect?
3.1 In providing services to a customer, Colpak may collect and hold the following types of credit information:
(a) information about any credit that has been provided;
(b) repayment history information and information about overdue payments; and
(c) information in relation to court proceedings that are initiated in relation to customer credit activities and any relevant bankruptcy or insolvency arrangements.
3.2 Colpak also uses CreditorWatch (https://creditorwatch.com.au/), which provides Colpak with credit risk information on corporate customers. Ordinarily Colpak will not use CreditorWatch to obtain credit information on individuals.
3.3 Other sources from which Colpak may collect credit information include:
(c) suppliers; and
(d) Colpak’s subcontractors and agents.
3.4 Colpak may also collect personal information which may affect a customer’s creditworthiness from other credit providers, such as trade referees, who may collect that information from credit reporting bodies. The types of personal information Colpak collect may include any of those types of personal information outlined in section 3.1 of this policy.
Purpose Of Collecting Information
4.1 Colpak collects the personal information of customers and potential customers to allow it to:
(a) provide transport services;
(b) comply with legislative requirements; and
(c) provide information about any additional services Colpak offers.
4.2 Colpak may collect personal information via its website (www.colpaklogistics.com.au) when that information is provided by a client voluntarily, such as by completing a form to receive updates or newsletters.
4.3 Colapk’s website may collect information including the Internet address and domain name used and the date and time of any visit together with information as to types of browsers and links followed. However, any such information is anonymous and only used for statistical purposes.
4.4 Colpak collects the personal information of prospective employees to allow it to:
(a) comply with legislative requirements; and
(b) determine whether to offer employment to a prospective employee.
4.5 Colpak collects personal information from in vehicle monitoring systems and closed-circuit television cameras:
(a) to prevent and detect crime;
(b) to assist in providing a safe working environment;
(c) to protect Colpak’s property and the property of Colpak’s customers, subcontractors, agents and visitors; and
(d) for quality and compliance purposes.
What Happens If Personal Information Is Not Provided?
If a person fails to provide Colpak with personal information that Colpak seeks, or if that information is inaccurate or incomplete, Colpak may be unable to provide that person with transport services or to consider offering that person employment.
How Does Colpak Collect Personal Information?
6.1 Colpak usually collects personal information directly from the person to whom the information relates.
6.2 Colpak may also collect personal information from:
(a) government bodies and agencies;
(b) public records and registers;
(c) courts and tribunals;
(d) current and previous employers;
(e) recruitment agencies and labour hire providers;
(f) doctors or other medical professionals who carry out health screening checks;
(g) in-vehicle cameras and closed-circuit television cameras; and
(h) online searches and social media.
How Does Colpak Use And Disclose Personal Information?
7.1 Colpak uses personal information to deal with and provide and market services to its customers and prospective customers.
7.2 Personal information may be disclosed to:
(a) Colpak’s subcontractors;
(b) entities that conduct licence checks for Colpak;
(c) government bodies such as WHS authorities, the Department of Home Affairs, the Department of Human Services, the National Heavy Vehicle Regulator and the Australian Taxation Office;
(d) customers who require information from Colpak for their compliance procedures or to meet legislative requirements;
(e) entities that provide medical testing and drug and alcohol testing for Colpak;
(f) Colpak’s insurance providers and insurance brokers; and
(g) third party technology providers including Linksoft which provides software to allow Colpak to run its transport business.
How Does Colpak Protect Personal Information?
8.1 Colpak uses various physical and electronic security measures to protect personal information held by Colpak, including using:
(a) security systems and other restrictions to limit access to Colpak’s premises;
(b) locked filing cabinets;
(c) secure electronic databases;
(d) unique usernames, passwords and other protections on systems that can access personal information; and
(e) electronic security systems and firewalls.
8.2 Colpak also manages the personal information it collects by:
(a) providing its staff with training on their obligations under the Privacy Act;
(b) supervising staff who regularly handle personal information;
(c) implementing procedures to identify and report privacy breaches and to respond to complaints about privacy breaches; and
(d) designating a privacy officer whose role is to manage compliance with the Privacy Act.
Colpak does not generally disclose personal information to overseas recipients.
Accessing And Correcting Personal Information
10.1 Any person may request access to personal information about them held by Colpak or request that their personal information is corrected.
10.2 Requests may be made to Colpak’s Privacy Officer by emailing firstname.lastname@example.org.
10.3 If a request is made in accordance with clause 10.1, Colpak will take reasonable steps to:
(a) provide access to relevant personal information that it holds; and
(b) correct any personal information if the data or information held is incomplete, irrelevant or misleading.
10.4 Colpak will not disclose any personal information under clause 10.1 without proof of identity.
10.5 Colpak may deny access to personal information if:
(a) the request is unreasonable;
(b) providing access would have an unreasonable impact on the privacy of another person;
(c) providing access would pose a serious and imminent threat to the life or health of any person; or
(d) there are other legal grounds to deny the request.
11.1 Complaints about a breach of the Australian Privacy Principles may be made to Colpak’s privacy Officer by emailing email@example.com.
11.2 All complaints will be responded to within a reasonable time.
11.3 Complaints may also be referred to the office of the Australian Information Commissioner (see details at www.oaic.gov.au).
Changes To The Policy