Date: 10 November 2014
The Woodhouse Partnership Limited Ltd (TWPL) (we, us, our) provides online Asset Management training services to corporate and government customers globally. In providing these services, we collect, use and disclose personal information. Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is either identified or reasonably identifiable.
We are required to comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). The APPs regulate the manner in which personal information is handled. We are also required to comply with more specific privacy legislation in some circumstances, such as applicable State and Territory health privacy legislation, the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).
2. What types of information do we collect?
2.1 Personal Information
The type of personal information that we collect and hold about you depends on the type of dealings that you have with us. If we need to identify you or verify your identity, we may collect your name, gender, date of birth, driver’s licence and/or passport details, student ID number, username, password, security question and answer. If we need to communicate with you, we may collect your email, residential and postal addresses and telephone numbers. If you apply to enrol in a training course or otherwise access our services, we may collect details of your employment and employer (or, if you are a contractor, your head contractor),training and compliance history, qualifications, banking and payment details.
To help us improve our services, we may collect your responses to surveys and details about how, when and why you access our services.
If you apply for a job with us, we will collect the information you include in your application.
2.2 Sensitive information
Sensitive information is personal information such as health information and information about racial or ethnic origin that is generally afforded a higher level of privacy protection.
We only collect sensitive information where it is reasonably necessary for our business functions and you have consented, or we are required to do so by law.
2.3 Information other than personal information (“non-personal information”)
When you visit our website, some of the information that is collected about your visit is not personal information, because it does not reveal your identity. We use this information to help us improve our services. We may aggregate this information for our own statistical purposes. Provided that it remains anonymous, we may disclose that aggregated information to third parties or publish it for marketing or research purposes.
Site visit information
We may record your server address, the date, time and duration of your visit, search terms you used, the pages you viewed, any documents you downloaded and the type of device, browser and operating system you used.
By using the Site, you agree that we can store and access cookies as described in this policy.
3. How do we collect personal information?
3.1 Methods of collection
We will collect personal information by lawful and fair means as required by the Privacy Act. We will also collect personal information directly from you where this is reasonable and practicable. We collect personal information in a number of ways, including:
- directly from you in person, over the phone, through written communications (either on paper or electronic) or by you completing forms or answering questions on our websites;
- from third parties, including your employer, (or, if you are a contractor, your head contractor), direct marketing database providers, government agencies, our related companies and your authorised representatives;
- from our own records of your use of our services.
3.2 Collection notices
Where we collect personal information directly from you, we will take reasonable steps to notify you of certain matters in a collection notice. We will do this at or before the time of collection, or as soon as practicable afterwards.
Where we collect information about you from your authorised representative, we will take reasonable steps to make sure that you are made aware of the collection.
If you provide to us personal information about someone else (as their authorised representative), we rely on you to inform them that you are providing their personal information to us and to advise them that we can be contacted for further information.
4. Why do we collect, hold, use and disclose your personal information?
The main purposes for which we collect, hold, use and disclose personal information are:
- to identify you and verify your identity;
- to communicate with you about our services;
- to provide our services to you, including:
- facilitating your enrolment in online training;
- facilitating your access to online training materials;
- verifying and validating your compliance history;
- facilitating your communications with others via our website; and
- obtaining payment for our services;
- for purposes required or authorised by or under law;
- to help us improve our services;
- for any other purposes that you have consented to.
4.2 Direct marketing
Where we have your express or implied consent, or where we are otherwise permitted by law, we may use your personal information to send you information about the services we offer, as well as other information. We may send this information by mail, email, SMS and telephone.
You can opt out of receiving these communications at any time, in the following ways:
- if you have an online account via our website, you can update your communications preferences by logging in to your account and following the instructions on our website;
- contact us (see section 10 below) and tell us;
- use the unsubscribe facility that we include in our commercial electronic messages (i.e., email or SMS) to opt out of receiving those messages.
5. To whom do we disclose your personal information?
We may disclose your personal information to any of the organisations that we deal with in the ordinary administration of our business for the purposes set out in section 4 above, including:
- your employer, (or, if you are a contractor, your head contractor);
- financial institutions;
- our service delivery partners, including:
- information technology service providers (including cloud services providers);
- mailing houses, postal, freight and courier service providers;
- printers and distributors of client communications;
- external business advisers (such as recruitment advisers, auditors and lawyers).
In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you.
We may de-identify and aggregate the personal information of you and others for our own statistical purposes. Provided that it remains permanently de-identified, we may disclose that aggregated information to third parties or publish it for marketing or research purposes.
If you apply for a job with us, we may discuss your application with your nominated referees.
If you have an online account via our website, you can access and change your privacy settings by logging in to your account and following the instructions on our website. Depending on the privacy settings that you chose, some of the personal information in your user profile may be disclosed to other users.
If you post comments or otherwise communicate publicly with other users via our website, any information about yourself that you include in the communication may be stored on the website and accessed by other users. For this reason, we encourage you to use discretion when deciding whether to post any information that can be used to identify you.
6. Cross border disclosure of personal information
It is our current policy not to disclose personal information to third parties located overseas.
7. Data quality and security
We hold personal information in a number of ways, including in electronic databases, email contact lists, and in paper files held in secure premises. Paper files may also be archived offsite in secure facilities. We take reasonable steps to:
- make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
- protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure;
- destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the APPs.
The steps we take to secure the personal information we hold include ICT security (such as encryption, firewalls, anti-virus software and login and password protection), secure office access, personnel security and training and workplace policies.
We process payments using PayPal and online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.
While we strive to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone or post (see section 10 below).
You can also help to protect the privacy of your personal information by maintaining the confidentiality of your account (including your password), and by ensuring that you log out of your account on our website when you have finished using it. In addition, if you become aware of any security breach, please let us know as soon as possible.
8. How can you access and correct your personal information?
You can request access to the personal information that we hold about you and request corrections by contacting our Privacy Officer (see section 10 below).
If you have an online account via our website, you can access and change some of your personal information by logging in to your account and following the instructions on our website.
If you have a complaint about how we have handled your personal information, please contact our Privacy Officer (see section 10 below).
Our Privacy Officer will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week.
If your complaint can't be resolved at first instance, we will ask you to complete a Privacy Complaint Form.
We will endeavour to acknowledge receipt of the Privacy Complaint Form within 5 business days of receiving it and to complete our investigation into your complaint in a timely manner.
In most cases, we expect that complaints will be investigated and a response provided within 30 days of receipt of the Privacy Complaint Form. If our investigation may take longer, we will let you know.
If you are unhappy with our response, you can refer your complaint to the Office of the Australian Information Commissioner or, in some instances, other regulatory bodies, such as the Australian Communications and Media Authority.
10. Further information
Please contact us if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details for privacy queries are set out below.
The Woodhouse Partnership Ltd
Mail: Prince Henry House, Kingsclere Park, Kingsclere, Newbury, Berkshire RG20 4SW
Email: For online enquiries you can contact us at firstname.lastname@example.org.
Telephone: + 44 (0)1635 298800
11. Changes to this Policy