Privacy Policy
Newbery Consulting collects and stores personal information on our clients. In doing this we comply with the Privacy Act 1988 (Commonwealth). This policy describes how Newbery Consulting collects, manages, uses, discloses, protects, and disposes of personal and sensitive information in accordance with the thirteen Australian Privacy Principles (APPs) outlined in Schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012.
Definitions
Under the Privacy Act 1988 and Privacy Amendment (Enhancing Privacy Protection) Act 2012 (s6(1)), personal and sensitive information is defined as follows:
- Personal information: “information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b) whether the information or opinion is recorded in a material form or not.”
- Sensitive information: “(a) information or an opinion about an individual’s: (i) racial or ethnic origin, or (ii) political opinions, or (iii) membership of a political association, or (iv) religious beliefs or affiliations, or (v) philosophical beliefs, or (vi) membership of a professional or trade association, or (vii) membership of a trade union, or (viii) sexual preferences or practices, or (ix) criminal record, that is also personal information; or (b) health information about an individual; or (c) genetic information about an individual that is not otherwise health information; or (d) biometric information that is to be used for the purposes of automated biometric verification or biometric identification; or (e) biometric templates”.
- Our websites and services: Our websites are https://newberyconsulting.com.au/ and https://rtodatacloud.com.au/. Our services include consulting services, audit services and cloud based student and learning management systems.
What information is collected?
When using our websites and services we collect personal and sensitive information. This includes anonymous information which cannot be tied directly to personally identifiable information. We use this information (anonymous information) to improve our website performance. This information helps us focus our resources on the features that are most popular with our customers. We may collect information regarding your IP address, browser type, domain name, access time, pages visited, etc. This information is used for our own research purposes and is separate from any personally identifiable information that you may submit via our websites. You can visit our websites without disclosing any personally identifiable information about yourself. The site is monitored by a firewall the protects the site security and this does track you IP address and the IP address location. The site is also monitored by Google Analytics which tracks site usage information. Google Analytics is a web service provided by Google Inc. Cookies are used to generate data on website activity and usage. The cookies, which include IP addresses, are transmitted to and stored in Google servers in the United States where they are used to compile web-use reports. Google may transfer this information to third parties, where required by law, or for information processing on its behalf. Google will not associate IP addresses with any other data held by Google. More information on Google’s privacy policy can be found at: https://policies.google.com/privacy?hl=en&gl=au. It is possible to disable cookies by adjusting web-browser setting and to opt-out of Google Analytics (https://tools.google.com/dlpage/gaoptout). Doing so, however, may affect web-site functionality.
Newbery Consulting also collect Personally Identifiable Information via our websites. This information is collected via the following web forms:
- Contact Us Form – Information provided through this form will not be stored by Newbery Consulting and will only be communicated to its employees and used solely to respond to customer enquiries and/or service requests. To be clear, we do not retain your details collected through the contact form other than to respond to your enquiry.
- Subscribe Form – The email address collected on the VET News subscriber form will be stored in a database for the purposes for which it was collected. The email address will be supplied to and stored by a third party email subscription management services (Mailchimp) for the purposes of communicating email correspondence to the recipient from time to time. The user will be provided the opportunity to unsubscribe from this email correspondence at any time.
- Purchase Form – The details collected on this form will be stored in a Newbery Consulting database for the purposes of order fulfillment and to record the issuance of product licences. This information includes your name, contact details, address and ABN. This information will not be distributed to any other person or organisation. Identifiable information will be used to issue/verify product licences which are purchased from Newbery Consulting. This information is store in secure file storage in our CRM.
- Payment Gateway – Newbery Consulting does not retain details of your credit card, ever. When you enter your credit card information into our websites, this information is only transmitted from your browser securely to our payment gateway with the National Australia Bank (NAB Transact). We never see this information and do not store this information. To do so would be a breach of the Privacy Act 1988. We take this very seriously.
How secure is your information?
The security of all information associated with our client is an important concern to us. We exercise the utmost care in providing secure transmission of your information from your computer to our servers. Our websites and servers are secured by firewall protection and are hosted within the Equinix SY2/3 Sydney IBX Data Center at Alexandria NSW. Your data is protected behind a world class firewall and your data is encrypted whilst being stored and in transit. Whilst we have taken every possible step to ensure your data is secure, we cannot give 100% certainty of its security. This is not reasonably possible even for large corporations or government departments and therefore we are unable to warrant the security of your information you transmit to us or from our online products or services, and in providing information, you do so at your own risk.
Who will use this information?
Your information will only be used by Newbery Consulting and any third party suppliers that you have authorised. Newbery Consulting will not disclose any personal information that you submit to us about you (“Personal Information”) in a manner that connects you with the Personal Information, except when we have your explicit permission or under special circumstances, such as when we are required by law to do so.
As an example, Newbery Consulting may be compelled under s 62 of the National Vocational Education and Training Regulator Act 2011 (Cth) to provide information to the National VET Regulator about an RTO to which it provides a service by issuing a written notice to Newbery Consulting to give information and documents. It is an offence under s 64 of the National Vocational Education and Training Regulator Act 2011 to not provide information and documents when requested to do so.
Newbery Consulting does not sell its mailing lists to third parties for marketing purposes.
Newbery Consulting does not disclose personal information to overseas recipients. While people around the world can access material published on our website, no statistical or research publications contain identifiable personal information are accessible.
How can I control my information?
In case you change your mind or some Personal Information changes (such as your mailing address or e-mail address), you can contact us to correct, update or remove your Personal Information that you have provided to us by making this request to the following email address: enquiries@newberyconsulting.com.au.
Please note that we reserve the right to retain information that links a product licence we have issued with a specific business identified by the ABN. This does not include the need to retain personal information if you have requested us to remove this.
Direct marketing
Newbery Consulting respects an individual’s right not to receive marketing material and provides an option within communications and on its website for individuals to unsubscribe from receiving marketing material. Newbery Consulting conducts its marketing communications and dissemination of service information in accordance with Australian Privacy Principle 7 (Direct marketing), the Spam Act 2003 (in respect of electronic communications), and the Do Not Call Register Act 2006. It is not, however, Newbery Consulting practice to ‘cold call’ for the purpose of marketing its products and services.
Unsolicited personal information
If Newbery Consulting should receive unsolicited personal information, it will be treated and managed according to the Australian Privacy Principles.
Complaints and concerns
Complaints or concerns about Newbery Consulting management of personal information should be directed in writing to Newbery Consulting Chief Executive Officer. Newbery Consulting will respond in writing within 10 business days. Complaints received by Newbery Consulting will be managed in accordance with the Complaints and Appeals and Appeals Policy.
Acknowledgement of Policy
This policy should be read in-conjunction with the other related terms and conditions. By using our websites and services, you signify your agreement to the Newbery Consulting Privacy Policy. If you do not agree with this policy, please do not use our websites and services. Your continued use of our websites and services mean you accept this privacy policy.
Updated – 30th July 2018
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