OUR PHILOSOPHY
Little Button Essentials Pty Ltd ACN 618 779 463 trading as Carla Dillon Lactation (we or us) is committed to protecting and respecting your privacy by handling all personal information securely and with care, in accordance with the Australian Privacy Principles (the APPs) and as set out in the Privacy Act 1988 (Cth) (the Act). The APPs regulate the manner in which personal information is collected, used, disclosed, stored, accessed, corrected and disposed of.
We have adopted this Privacy Policy to ensure that we comply with the APPs. The Policy provides an overview of:
- the types of personal information collected and held by us;
- how personal information is collected and held;
- the purposes for which personal information is collected, held, used and disclosed;
- whether the entity is likely to disclose personal information to overseas recipients;
- how an individual may access their personal information and seek its correction; and
- how an individual may complain if we breach the APPS or any registered APP code, and how the complaint will be handled.
Please read the Policy carefully to ensure that you understand our practices regarding the management of any information you disclose to us. We reserve the right to change the Privacy Policy at any time, so please check back regularly to keep informed of updates to this Policy.
WHAT IS ‘PERSONAL INFORMATION’ AND ‘SENSITIVE INFORMATION’?
‘Personal Information’ is any information or an opinion about you or an individual that identifies you or that could reasonably identify you. This could include information such as your name, contact detail, date of birth or employment details.
‘Sensitive Information’ is any information or opinion about you or an individual which is health information or which relates to your racial or ethnic origin, political opinion, religious beliefs, sexual orientation or criminal record. The APPs place more stringent obligations on us when we handle your sensitive information.
WHAT INFORMATION DO WE COLLECT?
We collect, hold, use and disclose your Personal Information and Sensitive Information that you disclose to us or which we obtain from third parties enables us to provide products and services to you. We will only collect and retain information that is reasonably necessary for the performance of our activities and functions so that we are able to provide you with the products and services you require or which we recommend to you.
The kinds of Personal Information and Sensitive Information we collect and hold depends on the specific products and services provided to you, but will generally include basic personal contact information, as well as other information that is deemed relevant. This includes, but is not limited to:
- your identity and contact details (name, postal and/or residential address, email address, telephone number(s), age and gender, government id (e.g. drivers licence, Medicare card etc.);
- your personal details (date of birth, gender, cultural identity, socio-economic status, etc.);
- financial and transaction information;
- user data;
- contact history with us;
- marketing and communications data;
- your health information and medical history;
- information on personal issues, experiences and relationships;
- your family background and community supports (which can include Personal Information and Sensitive Information of third parties); and
- your child or children’s identity and contact details (name, postal and/or residential address, email address, telephone number(s), age and gender, government id (e.g. drivers licence, Medicare card etc.).
If you do not provide us with the required information, we may not be able to perform the products and services which you require us to provide.
HOW WE COLLECT AND HOLD PERSONAL AND SENSITIVE INFORMATON
During the course of providing our products and services to you, we will collect Personal Information and Sensitive Information from you by asking you verbally for that information, or requiring you to complete forms or documents necessary to enable us to provide you with our products and services.
We may be/will often be provided with your Personal Information and Sensitive Information from your referring practitioner or other third parties, including your doctor, mental health worker, allied health professional or hospital.
We may also collect personal information from third parties including from:
- public sources (for example, in public registers or social medial);
- information service providers; and
- anyone authorised to act on your behalf.
We may also generate new personal information from time to time – e.g. reports or analysis based on other information we hold about you.
We will take reasonable steps to store information in a secure manner, to protect the security of your personal information. We implement a range of measures, including people, process and technology controls to protect the security of your personal information. Examples of these measures include:
- a combination of physical and technical measures. Information that we store in hard copy, is stored securely within a locked filing cabinet. Information that we store electronically, is stored in a local server/secure cloud-based facility and/or on our computers, which are password protected and are kept in secure locations at all times.
- appropriate technology to protect your personal information stored electronically, such as passwords, as well as limiting the number of personnel who have access to your personal information, whether stored electronically or in hard copy;
- staff are bound by internal confidentiality and information security policies that require them to keep personal information secure at all times;
- protecting personal information in accordance with the Office of the Information Commissioner’s Guide to Securing personal information;
- maintaining an ongoing security program where we invest continually in cyber security; and
- regular training to our staff regarding the collection, storage and handling of your personal information.
Our security controls are continually reviewed to protect your personal information appropriately.
When we no longer require your Personal Information and Sensitive Information, it will be destroyed or permanently de-identified. However, we will retain information for as long as the law requires.
THIRD PARTY PERSONAL AND SENSITIVE INFORMATION
We may ask you for Personal Information and Sensitive Information about other individuals, for example, your family members. If you provide us with this information, we rely on you to tell those individuals that you are giving their Personal Information and Sensitive Information to us, and to make them aware of this Policy.
HOW WE USE YOUR PERSONAL AND SENSITIVE INFORMATION
We may use your Personal Information and Sensitive Information for the following purposes:
- to confirm your identity;
- to provide you with lactation advice and related products and services;
- to contact you directly about your products and services;
- to share it with our related entities, subsidiaries or other specialist providers as required to perform functions on our behalf;
- to share with suppliers and third parties that carry out specific functions on our behalf, so that we can provide you with the products and services;
- for other purposes communicated to you when your information is collected;
- for disclosures required by law, regulation or court order; and
- to provide data to Government department and agencies who provide funding for our products and services;
- to share with parties involved in business transfer transactions (and prospective transactions); and
- to conduct internal client research and assessment.
This includes us using this information to communicate with you about our products and services, for internal administration, direct marketing and planning purposes. We will also use your personal information for purposes related to those described above which would be reasonably expected by you. You may request not to receive direct marketing communication from us by contacting the Privacy Officer (details below).
We will not use your Personal Information and Sensitive Information for purposes other than those described above, unless we have your consent, or there are specified law enforcement or public health and safety reasons (as permitted under the Act).
TRANSFER OF PERSONAL AND SENSITIVE INFORMATION
We may outsource business functions to other organisations and as such, it is possible that your Personal Information and Sensitive Information will, as required from time to time, be disclosed or transferred to other organisations to allow them to assist us to provide you with products and services.
It is very unlikely that we will disclose your Personal Information and Sensitive Information to overseas recipients. If we transfer your Personal Information outside Australia, we will endeavour to comply with the requirements of the Act that relate to transborder data flows, but we cannot guarantee compliance and you specifically agree that you understand this. Therefore, to the fullest extent permitted by law, we disclaim all liability and responsibility for any damage you may suffer due to our non-compliance with APP 8.1, except to the extent that our liability cannot be excluded by applicable laws and regulations which we are subject to.
You should also be aware that:
- any overseas recipient may not be subject to any privacy obligations or to any principles similar to the APPs;
- you may not be able to seek redress in the overseas jurisdiction; and
- any overseas recipient may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.
While we will not directly disclose your Personal Information and Sensitive Information to overseas recipients without your consent, the entities to which we may disclose your Personal Information and Sensitive Information may do so. We are unable to say what countries, if any, those recipients are likely to be located in.
HOW TO CHANGE OR ACCESS THE INFORMATION WE HOLD ABOUT YOU
You can access the Personal Information and Sensitive Information we hold about you.
We will take reasonable steps to ensure that any Personal Information or Sensitive Information that we collect, use, store or disclose, is relevant, accurate, complete and up-to-date. If you believe the information we hold is inaccurate, incorrect, or incomplete, you may request that your information be corrected and we can then take reasonable steps to correct this information.
Please contact our Privacy Officer (details below) to access or request updates to any Personal Information and/or Sensitive Information which we hold.
COOKIES AND WEB BEACONS
If you are accessing this Privacy Policy via our website (the Site), we may use cookies on the Site from time to time. Cookies are small text files created by a website and stored in your computer, which recognize and track your preferences. Cookies, on their own, will not provide us with your email address or other personally identifiable information. However, cookies allow third parties, such as Google, Facebook and Instagram, to cause our advertisements to appear on your social media and online media feeds as part of our online marketing campaigns. If and when you choose to provide the Site with personal information, this information may be linked to the data stored in the cookie. If you do not wish to have cookies placed on your computer, please set your browser preferences to reject all cookies before accessing our website.
If you are accessing this Privacy Policy via the Site, we may use web beacons on the Site from time to time. Web beacons (also known as Clear GIFs) are often a transparent graphic image that is placed on a website or in an email that is used to monitor your behaviour. For example, web beacons can be used to count the number of users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
LINKS TO OTHER WEBSITES
If you are accessing this Privacy Policy via the Site, the Site may contain links to other third party websites. We have no control over those websites and we are in no way responsible for the protection and privacy of any personal information you provide whilst visiting those third party websites. Those websites will not be governed by this Privacy Policy and we recommend that you seek out their privacy policy when redirected to a third party website to ensure that you are aware of how they may use your personal information.
COMPLAINTS
If you have a complaint about the way we have dealt with your Personal Information or Sensitive Information, or about this Policy itself, we invite you to provide written details of your complaint to our Privacy Officer (contact details below).
Our Privacy Officer will contact you within 14 days of the date we receive the written details of your complaint to acknowledge that we have received it. Our Privacy Officer will then:
- review the way we dealt with your Personal Information and/or Sensitive Information;
- conduct an internal investigation (if necessary) into how your Personal Information and/or Sensitive Information came to be handled in the way that it was; and
- provide a report to you within one month of the date we acknowledged receipt of your complaint.
If you believe we have breached the APPs, you may also lodge a complaint with the Office of the Australian Information Commissioner.
CONTACT US
Should you have any queries, complaints or comments about this Privacy Policy, please contact our Privacy Officer in writing by post or email at:
POST: Attention: The Privacy Officer
Little Button Essentials Pty Ltd ACN 618 779 463 trading as Carla Dillon Lactation
PO Box 641, Goondiwindi QLD 4390
EMAIL: contact@carladillonlactation.com.au
Contact