2. Wesfarmers Industrial & Safety is committed to complying with Commonwealth legislation governing privacy of personal information by businesses (the Privacy Act 1988 (Cth) and the National Privacy Principles (the Privacy Act)) and to protecting and safeguarding your privacy when you deal with us.
Collection of information
3. Wesfarmers Industrial & Safety only collects information that it needs to collect to carry on its business. Some information provided to Wesfarmers Industrial & Safety by clients, customers, contractors and other third parties might be considered private or personal. Without these details Wesfarmers Industrial & Safety would not be able to carry on its business and provide services to you. We will only collect such personal information if it is necessary for one of our functions or activities.
4. Generally, personal information is collected from people by Wesfarmers Industrial & Safety in the following situations:
- If you contact Wesfarmers Industrial & Safety, we may keep a record of that correspondence.
- When you submit your e-mail address to our website mailing list.
- In order to allow you to purchase goods from us using any form of credit and for us to bill you for the products and services we supply to you or your business.
- To properly assess an application for credit, and to manage your account. When you place an order with us for goods and services and organise payment with us using credit cards, transaction approvals, or fund transfers, we need to verify your credit details. In some cases this will be your personal information rather than that of a company or business. Before we can do this, we need to know who you are and where you are for the purposes of processing your application.
- On rare occasions we may need to collect sensitive information which may include details of your membership of a trade association or any previous criminal convictions that you may have had. This information along with any financial information we collect about your personal financial position is strictly confidential.
Wesfarmers Industrial & Safety will only collect this information in accordance with the requirements of the Privacy Act. If you do not provide the personal information that we request then we may not be able to process your application for credit or process your order as quickly as you may desire, and we will not offer credit facilities to customers who wish to be anonymous or who do not provide us with sufficient information to enable us to properly assess the credit requested.
5. At or before the time the personal information is collected by us we will take reasonable steps to ensure that you are made aware of who we are, that you are able to gain access to the personal information held about you, the purpose of the collection, the type(s) of organisations to which we usually disclose the information collected about you, any laws requiring the collection of the information and the main consequences for you if all or part of the information is not collected.
How do we collect personal information?
6. Where possible we will collect the information from you or from a third party who is authorised to act on your behalf such as your accountant. When you give us personal information about other individuals we rely on you to have obtained their consent for you to do this and for you to inform those individuals of the types of third parties that we may provide the personal information to and the reasons why. Obtaining the consent of the individual is important, particularly if you are providing us with sensitive information about that person.
7. We may collect the information in writing, by telephone, through our website and by other electronic communication channels. For credit applications, you will provide much of the information we require in the completed application form you give to us.
8. We may need to ask you or others further questions to ensure we are clear about your needs and to enable us to properly assess the risk. We collect this information through our employees and through our contracted agents and other service providers. Wherever reasonable and practicable, we will ask you for the information directly. However, we may need to contact other people and organisations, such as your business associates, bankers, credit reference agencies and referees to collect information about you, subject to the requirements of the Privacy Act.
Use of information collected and disclosure of personal information to others
9. We may use or disclose personal information held about an individual for the primary purpose for which it is collected (e.g. provision of our services, including administration of our services, notification to you about changes to our services, record-keeping following termination of our services to you and technical maintenance). We may also use such information for any purpose related to the primary purpose of collection and where it would reasonably be expected by you that we would use this information in such a way. This information is only disclosed to persons outside our business in the circumstances set out in this policy or as otherwise notified to you at the time of collection of the information.
10. In addition we are permitted to use or disclose personal information held about you:
- Where you have consented to the use or disclosure;
- Where we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious, immediate threat to someone's health or safety or the public's health or safety;
- Where we reasonably suspect that unlawful activity has been, is being or may be engaged in and the use or disclosure is a necessary part of our investigation or in reporting the matter to the relevant authorities;
- Where such use or disclosure is required under or authorised by law (for example, to comply with a subpoena, a warrant or other order of a court or legal process);
- Where we reasonably believe that the use or disclosure is reasonably necessary for prevention, investigation, prosecution and punishment of crimes or wrongdoings or the preparation for, conduct of, proceedings before any court or tribunal or the implementation of the orders of a court or tribunal by or on behalf of an enforcement body.
11. Except as set out above, your information will only be seen or used by persons working for or on behalf of Wesfarmers Industrial & Safety which includes but is not limited to our employees, contractors, contracted agents, credit risk assessors, managers, credit insurers/brokers, debt collection agents, credit reference bureaus, and statisticians.
12. From time to time we may use your personal information to provide you with news or offers about products and services available from Wesfarmers Industrial & Safety or its related bodies corporate that may be of interest to you. At any time, if you no longer wish to receive this additional marketing material please contact our Privacy Officer on (02) 8873 4800, or at 26 Talavera Road, Macquarie Park NSW 2113.
Website and email use
13. We will only collect personal information about you via Wesfarmers Industrial & Safety websites if you voluntarily submit it to us by:
- sending us an email;
- sending us information via the 'Contact Us' page on the relevant web site; or
- giving us personal information when using any part of the relevant web site.
14. We will ask you when we need you to provide further personal information for any reason. We will only collect information that is relevant to the services that you ask us to provide to you and your information will not be made available to any third party without your consent.
15. Wesfarmers Industrial & Safety collects information from its websites using "IP files". When you visit the Wesfarmers Industrial & Safety sites to read, browse or download information, our system will record/log your IP address (the address which identifies your computer on the internet and which is automatically recognised by our web server), date and time of your visit to our site, the pages viewed and any information downloaded. This information will only be used for the purpose of site analysis and to help us offer you improved online service. We may automatically collect non-personal information about you such as the type of Internet browsers you use or the site from which you linked to our websites. You cannot be identified from this information and it is only used to assist us in providing an effective service on our websites.
16. Our websites may contain links to other websites and those third party websites may collect personal information about you. We are not responsible for the privacy practices of other businesses or the content of websites that are linked to our websites. Wesfarmers Industrial & Safety encourages users to be aware when they leave our websites to read the privacy statements of each and every website that collects personally identifiable information.
17. Wesfarmers Industrial & Safety is committed to protecting the privacy of the personal information you may provide to us by ensuring your e-mail address and any other personal information about you will only be disclosed to relevant employees and contractors and used for the purpose of responding to a request or to carry out instructions. However, no data transmission over the Internet, including email, can be guaranteed to be 100 per cent secure. As a result, while we strive to protect user's personal information, Wesfarmers Industrial & Safety cannot ensure or warrant the security of any information transmitted to it or from its online products or services, and users do so at their own risk. Once Wesfarmers Industrial & Safety receives your transmission, it makes every effort to ensure its security on its systems.
18. Ultimately, you are solely responsible for keeping your passwords and/or account information secret. You should be careful and responsible whenever you are online.
Security and storage
19. We recognise that you are concerned about the security and confidentiality of the information we hold about you. Wesfarmers Industrial & Safety places a great importance on the security of all information associated with our customers, clients and contractors. We have security measures in place which are intended to protect against the loss, misuse and alteration of personal information under our control.
20. Our employees who have access to your information have been briefed on the requirements of the Privacy Act and our contracted service providers have been made aware that they are required to comply with the provisions of the Privacy Act.
21. Wesfarmers Industrial & Safety retains the information you provide to us including your contact and credit card details to enable us to verify transactions and customer details and to retain adequate records for legal and accounting purposes. This information is held on secure servers in controlled facilities.
22. Information stored within our computer systems can only be accessed by those entrusted with authority and computer network password sanctions.
23. Personal information is de-identified or destroyed securely when no longer required by us.
Access to and correction of personal information
24. Wesfarmers Industrial & Safety is committed to maintaining accurate, relevant and appropriate information about our customers, clients and website users.
25. So long as your request for your personal information is in accordance with the National Privacy Principles, then we will give you access to that information through our Privacy Officer:
26 Talavera Road
Macquarie Park, SYDNEY NSW 2113
Telephone: (02) 8873 4800
Facsimile: (02) 8873 4940
You may be required to pay a fee for the costs involved in retrieving and processing the information.
26. Upon receiving instructions from you inaccurate information will be corrected. To ensure confidentiality, details of your personal information will be passed on to you only if we are satisfied that the information relates to you.
27. If we refuse to provide you with access or correct the personal information held about you by us, we will provide reasons for such refusal.
29. We will investigate your complaint and attempt to resolve any breach that might have occurred in relation to the collection, use or destruction of personal information held by us about you in accordance with the applicable legislation. If you are not satisfied with the outcome of this procedure then you may request that an independent person (usually the Commonwealth Privacy Officer) investigate your complaint.
Transfer of information overseas
30. Pursuant to the National Privacy Principles we may transfer personal information we have collected about you to someone other than you in a foreign country only if such transfer is permitted by the National Privacy Principles.
33. Should you wish to read more information on privacy legislation or the National Privacy Principles we recommend that you visit the Federal Privacy Commissioner's website at http://www.privacy.gov.au
Ethical Conduct Policy
Wesfarmers Industrial & Safety (“WIS”) and its business units are committed to the highest standards of conduct and ethical behaviour in all of their business activities, and to promoting and supporting a culture of honest and ethical behaviour, corporate compliance and good corporate governance.
The Ethical Conduct Policy is to encourage suppliers, contractors, customers or any other party to raise any concerns and report instances of unethical, illegal, fraudulent or undesirable conduct, where there are reasonable grounds to suspect such conduct, without fear of intimidation, disadvantage or reprisal.
WIS relies on the parties that it does business with to help the company achieve its commitment to a culture of honest and ethical behaviour, corporate compliance and good corporate governance. For WIS, the failure to report actual or suspected incidents of Unethical Conduct will be treated seriously and may adversely affect the ongoing business relationship.
Unethical Conduct covered by this Policy includes any conduct of a director, officer, employee, contractor or third party, whether actual or suspected, including:
- dishonest, fraudulent, corrupt or illegal conducts;
- unethical actions or behaviours (including bribe, facilitation payment or other kick-backs, inappropriate gifts; falsifying documents or other unacceptable or unethical behaviour);
- actions that have the potential to damage WIS’ property, people or reputation or that of another party (such as unsafe work practices, environmental damage, health risks or substantial wasting of company resources); or
- abuse of authority, threats, intimidation or harassment.
Unethical Conduct can be reported to:
- the employee’s immediate supervisor or manager or another senior person; or
- the Ethical Conduct email hotline on firstname.lastname@example.org and these matters will be confidentially referred to the WIS Managing Director or Chief Financial Officer.
While the person reporting the issues may wish to remain anonymous, if contact details are not provided, sufficient details will need to be included in the report to allow the matter to be investigated. WIS will investigate all reports of Unethical Conduct on a timely, thorough, confidential, objective and fair manner (subject to considerations of the privacy of those against whom allegations are made).