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Privacy and Data Protection Policy

(Aligned with Australian Privacy Act 1988 & Australian Privacy Principles)

1. Introduction

This Privacy and Data Protection Policy (“Policy”) sets out of the commitments of 1000 Feet Deep Pty Ltd (“the Company”) to protecting the privacy and personal information of customers, clients, and business contacts (“data subjects”) under the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”).

Under the Privacy Act, “personal information” refers to information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in material form or not.

This Policy outlines the Company’s obligations regarding the collection, use, disclosure, storage, and disposal of personal information. The procedures and principles herein must be followed at all times by the Company, its employees, contractors, and agents.

We are committed to the lawful, fair, and transparent handling of all personal information, respecting the privacy, rights, and trust of all individuals with whom we deal.

2. Australian Privacy Principles (APPs)

The Company complies with the 13 APPs as set out in Schedule 1 of the Privacy Act 1988:

  1. Open and transparent management of personal information.
  2. Anonymity and pseudonymity.
  3. Collection of solicited personal information.
  4. Dealing with unsolicited personal information.
  5. Notification of the collection of personal information.
  6. Use or disclosure of personal information.
  7. Direct marketing.
  8. Cross-border disclosure of personal information.
  9. Adoption, use, or disclosure of government-related identifiers.
  10. Quality of personal information.
  11. Security of personal information.
  12. Access to personal information.
  13. Correction of personal information.

3. Collection of Personal Information

We collect personal information that is reasonably necessary for our business functions and activities, including:

  • Contact Information: Name, address, email address, telephone number, and other contact details as well as a communication history.
  • Employment Information: Job title, employer details, and professional qualifications.
  • Financial Information: Bank account details, payment information, and other financial details as required for our services.
  • Business Information: Information about your business, including its operations, financial performance and strategic goals.
  • Enrolment and Participation: Enrolment details for training or CPD courses  as well as records of participation in workshops or e-learning programs.
  • Other Information: Any other personal information you provide to us in the course of our consultancy services.

 We collect personal information in the following ways:

  • Directly from you: When you provide information to us through consultations, meetings, emails, phone calls or other direct interactions.
  • Through our website: When you submit information via our website, including through contact forms or subscription services.
  • From third parties: With your consent, we may collect information from third parties, such as your business partners, services providers, or publicly available sources.
  • Automatically: Through the use of cookies and similar technologies when you visit our website, subject to your consent where required.

Where possible, personal information will be collected directly from the individual. If collected from a third party, we will take reasonable steps to ensure the individual is informed.

4. Use and Disclosure

We will only use or disclose personal information:

  • For the purpose for which it was collected.
  • Where the individual has consented.
  • As required or authorised by law.
  • Where reasonably necessary for enforcement-related activities.
  • To provide business consultancy services tailored to your needs.
  • To communicate with you regarding our services, including responding to your inquiries and providing updates.
  • To manage our business operations, including billing, administration and record-keeping.

Direct marketing communications will only be sent where permitted under APP 7, and individuals will always have the option to opt out.

5. Data Quality and Accuracy

We take reasonable steps to ensure that personal information is accurate, complete, and up-to-date. Individuals may request correction of their information at any time.

6. Data Security and Storage

We protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure by:

  • Using secure servers, password protection, and encryption.
  • Restricting access to authorised personnel only.
  • Securely destroying or de-identifying personal information when no longer needed, in line with the Notifiable Data Breaches (NDB) scheme.

If personal information is no longer required for the purposes for which it was collected, and we are not required by law to retain it, we will take reasonable steps to destroy or de-identify the information.

7. Cross-Border Disclosure

We will not disclose personal information to an overseas recipient unless:

  • The recipient is subject to similar privacy obligations, or
  • The individual has provided informed consent, or
  • It is required or authorised by Australian law.

8. Access and Correction

Individuals may request access to, or correction of, their personal information by contacting the Privacy Officer. Requests will be handled within a reasonable timeframe (usually within 30 days) in accordance with APP 12 and APP 13.

9. Notifiable Data Breaches

If a data breach is likely to result in serious harm to any individual, we will:

  • Notify the Office of the Australian Information Commissioner (OAIC).
  • Notify affected individuals as soon as practicable, including details of the breach and recommended protective actions.

10. Privacy Officer Contact

Privacy Officer: [Name]

Email: [email address]

Phone: [phone number]

Address: [postal address]

11. Complaints

If you believe we have breached the APPs or mishandled your personal information, you may lodge a complaint with our Privacy Officer. Please provide as much detail as is possible about the nature of your complaint. We will investigate your complaint and respond within 30 days. If unresolved, you may escalate the complaint to the Office of the Australian Information Commissioner (“OAIC”) for further assistance. The OAIC can be contacted at www.oaic.gov.au.

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