Tanda HR Advisory Privacy Policy

This Privacy Policy applies to Personal Information collected by us. We are bound by the Australian Privacy Principles and the Privacy Act 1988 (Cth), which governs the way private sector organisations collect, use, keep secure and disclose Personal Information.

The Privacy Act 1988 (Cth) defines “Personal Information” to mean any information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or not.
  

If you have any questions or comments about this policy please email our privacy officer at privacy@tanda.co and we will attend to your query promptly.

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We will only use or disclose your Personal Information for the primary purpose for which it was collected or as consented to by you.

At or around the time we collect Personal Information from you, we will endeavour to provide you with a notice which details how we will use and disclose that specific information.

We set out some common collection, use and disclosure instances below.

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As much as possible or unless provided otherwise in this Privacy Policy or a notification, we will collect your Personal Information directly from you.

We may collect Personal Information:

• In conversations with you, in person or by e-mail, fax and telephone;
• From your employees or colleagues when they interact with the Services;
• From third parties such as related companies, credit reporting agencies or your representatives;
• When we are required to do so by law; and
• From our own records of your usage of Tanda Employment Advisory services.
  

We may also collect Personal Information about you from other sources. For instance, when we collect information about you from third parties or from publicly available sources (e.g. court judgments, bankruptcy searches, Australia Post or social media platforms).

If we collect information about you from someone else, we will, wherever reasonably possible, make you aware that we have done this and why, unless this information is collected from any personal referee, from a publicly available source or as otherwise required by law.

Where we inadvertently collect Personal Information from you, or a third party in circumstances where we have not requested that Personal Information and we consider that it is not required, we will destroy or de-identify that information.

We take security of your Personal Information seriously, and will hold it securely and store it on infrastructure owned or controlled by us or with a third party service provider who has taken reasonable steps to assist us in complying with the Privacy Act 1988 (Cth).

If you use our website, we may utilise “cookies” which enable us to monitor traffic patterns, trends and to serve you more efficiently if you revisit our website. We may also gather your IP address as part of our business activities and to assist with operational difficulties or support issues with our services. This information does not identify you personally, but may identify your internet service provider. This information combined with other sources of Personal Information may enable us to identify you. If you do not wish for this to occur, you can set your browser to notify you of this and you may then accept or reject it.

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We provided a detail list in Section 2 of some common uses of your Personal Information. Your Personal Information may be used to:

• provide products and services to you;
• collect payments and to administer your employer’s accounts;
• provide you with updated or new information about our products or services;
• conduct creditworthiness checks and/or fraud checks;
• for development of existing and new products and services;
• maintain and update our business infrastructure and systems;
• actively promote our other products and services to you. If you do not wish to receive such communications please advise us;
• for research into our client base and for related purposes by our research team including as aggregated (anonymous) benchmarking data.

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We provided a detail list in Section 2 of some common disclosures of your Personal Information.

In providing our products and services, or collecting and using your Personal Information, we will always keep your data private to the maximum extent commercially and practically possible. In the normal course of business and in order to provide your service we may be required to disclose some of your Personal Information to organisations outside Tanda Employment Advisory. Such organisations may include:

• Our outsourced service providers, which are always carefully selected by us;
• Your employer’s legal, taxation or other professional advisors if you agree as part of the service;
• Our legal, accounting, financial or other professional advisors and bankers;
• Regulatory, government and other authorities as required by law;
• Our subsidiaries and closely related organisations;
• Other organisations involved in managing our trade receivables, business, financial affairs;
• Other organisations subscribing to our client base research data which will be aggregated and anonymised.

We may also use and disclose your Personal Information and in doing so, we are not required to seek your further consent:

• when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your Personal Information to be used or disclosed for such a purpose;
• if the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
• if we have a reason to suspect that unlawful activity has been, or is being, engaged in; or
• if it is required or authorised by law.

If we propose to or do disclose (or use) your Personal Information other than outlined in Sections 2, 4 or 5 then we must first notify you or seek your consent.

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You give your express and informed consent to us using your Personal Information in relation to direct marketing and sales as set out in this document.

Without limitation, if you have provided your inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you direct marketing material, then we may also use your Personal Information to send you direct marketing material.

We will provide you with the ability to opt-out from receiving any communications from us that you no longer wish to receive.

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The Privacy Act 1988 (Cth) contains provisions regarding the use and disclosure of credit information, which applies in relation to the provision of both consumer credit and commercial credit. Please refer to our Credit Reporting Policy for more details.

As we provide terms of payments of accounts which are greater than 7 days, we are considered a credit provider under the Privacy Act. We use your credit information or the purposes outlined in Section 2 of this policy.

We will store any credit information you provide to us or we obtain about you with any other Personal Information we hold about you.

You may request access to your credit information in accordance with Section 13, or make a complaint in accordance with Section 15.

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Because of the nature of our services, it is generally not practicable for us to correspond with you on an anonymous basis and your Personal Information may be required in order to provide you with our products and services on your employer’s behalf, or to resolve any issue you may have.

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Any Personal Information collected and held by us may be disclosed to, and held at, a destination outside Australia, including but not limited to Ireland, Estonia, Netherlands, Philippines, United Kingdom and the United States of America where we use third party service providers to assist us in providing Tanda Employment Advisory’s platform and other services to you or overseas IT services (including software, platforms and infrastructure).

Personal Information may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.

Disclosure may occur in countries other than those listed above, and we use service providers and platforms that can be accessed from various countries.

By submitting your Personal Information to Tanda Employment Advisory, you expressly agree and consent to the disclosure, transfer, storing or processing of your Personal Information outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to Personal Information. However, we will take appropriate steps to ensure that your Personal Information is used by third parties securely and in accordance with the terms of this Privacy Policy.

If you do not agree to disclosure of your Personal Information outside Australia by us, you should (after being informed of the cross-border disclosure) tell us that you do not consent. To do this, either elect not to submit the Personal Information to us after being reasonably informed in a collection notification or by this Policy, contact us via the details set out at the top of this document.

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We take reasonable precautions to make sure that the Personal Information we hold is accurate and up-to-date. To ensure this, we recommend that you notify us of errors, omissions or changes in your Personal Information. This is especially important for information required for us to communicate with you, such as a change in name, email, phone number or address.

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Tanda Employment Advisory takes reasonable steps to ensure that your Personal Information is protected from misuse, loss, unauthorised access, modification or disclosure. Some notable measures to ensure the security of your Personal Information include:

• encryption, and regular backups of the database;
• ensuring that the Personal Information we collect, use or disclose is accurate, complete and up to date;
• protecting your Personal Information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
• destroying or permanently de-identifying Personal Information if it is no longer needed for its purpose of collection.
  

You will appreciate, however, that we cannot guarantee the security of all transmissions or Personal Information, especially where human error is involved or malicious activity by a third party.

The security of this information is also dependent on your own measures to protect your email addresses and passwords from disclosure and unauthorised use.

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You have the right to access any of your Personal Information that we hold, with some exceptions as allowed by law. To obtain a copy of this information, contact us and we will provide it to you. Tanda Employment Advisory reserves the right to charge a reasonable fee for the provision of this information.

If you would like to correct any records of Personal Information we have about you, you are able to access and update that information (subject to the above exceptions) by contacting us via the details set out at the top of this Policy.

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By continuing to use our products or services or website you consent to Tanda Employment Advisory maintaining, using and disclosing your Personal Information as described in this document for a period of no less than seven years from the date of your last use of the system (or the date of the last use of the system by any user under your subscription, whichever is the latest).

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We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if required) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.

If you wish to make a complaint, please contact us at the details listed above.

In order to resolve a complaint, we:

• will liaise with you to identify and define the nature and cause of the complaint;
• may request that you provide the details of the complaint in writing;
• will keep you informed of the likely time frame within which we will respond to your complaint; and
• will inform you of the legislative basis (if any) of our decision in resolving such complaints.
  

We will maintain a register of all complaints, and any action taken.

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This Privacy Policy is a compliance document prescribed by law rather than a legal contract between two or more persons. However, certain contracts may incorporate all of part of this Privacy Policy.

By using our website, purchasing a product or service from us, where you have been provided with a copy of our Privacy Policy or had a copy of our Privacy Policy reasonably available to you, you are acknowledging and agreeing to provide the consents given by you in this Privacy Policy and you have been informed of all of the matters in this Privacy Policy.

We reserve the right to modify our Privacy Policy as our business needs require. We will take reasonable steps to notify you of such changes (whether by direct communication or by posting a notice on our website). If you do not agree to our continued use of your Personal Information due to the changes in our Privacy Policy, please stop providing us with your Personal Information and contact us via the details set out at the top of this Policy.

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