1. General Information
2. Personal Information
“Personal information”, when used in this policy, means any information, opinion or data that we collect about an individual where the individual is identified or reasonably identifiable.
The types of information we may collect, and hold will vary depending on your interaction with us. This information includes:
- names and contact details (email, phone and physical address);
- details regarding gender and marital status;
- dates of birth;
- proof of identity documentation, such as passports, drivers licenses and birth certificates;
- health information;
- job qualifications and history;
- profession, occupation or job title;
- computer IP addresses; and
- any additional information relating to you that you provide to us directly through our websites or indirectly through use of OnePassport System.
3. Collection of personal information
We collect information from you when you use the OnePassport System. We collect information from you when you register, modify your account, communicate with us directly or make purchases through the OnePassport Platform.
While we store documents that you upload, we are not able to view the content of the documents in your account. Where you are an individual and you create an account on the OnePassport System you are able to link or unlink your account to other accounts (eg the account of your employer) and provide them with access to documents that you have uploaded. We will generally collect your personal information directly from you. We do this in various ways including:
through your communications with us (electronically, over the phone or in person);
through the OnePassport Platform (including details you enter to register for use of the OnePassport Platform);
through feedback and survey forms.
We may also collect your personal information from a third party parties where you have consented to the personal information being provided by that party (eg an employer providing information about employees to upload intovia the OnePassport System).
4. Purpose of collection, use and disclosure of personal information
The primary purpose for which we collect, hold, use and disclose information about you is to enable us to perform our business activities, functions and services effectively. We collect, hold, use and disclose your personal information for the following purposes:
- to provide our services to you;
- to manage and improve the OnePassport System and our products and services;
- to share relevant information with your employer(s);
- for any purpose we disclose at the time of collection;
- to provide you with information about our services and products; and
- as required or permitted by law.
If you do not provide the personal information, we may not be able to provide you with the OnePassport System products or services you request.
5. Direct Marketing
We may use your contact details (name and email address) to provide you with updates, on our products and services. These communications may be sent in various ways including email or through the OnePassport System.
You can opt out of receiving these newsletters by contacting us at [email protected].
6. Disclosure of Personal Information
We may disclose your personal information to:
- our employees, related bodies corporate, contractors or external service providers for the purposes of the operation of the OnePassport System or our business, fulfilling requests by you, and otherwise providing products and services to you;
- our existing or potential agents, business partners or joint venture entities or partners to enable us to perform our business activities and provide products and services to you;
- specific third parties authorised by you to receive information held by us (eg your employer);
- relevant authorities and institutions in connection with the provision of our services or if required by law; and
- the police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator if required by law or we consider it reasonably necessary for the protection of our systems or for the prevention or detection of illegal activity.
8. Storage and Security of personal Information
To provide the OnePassport System and our products and services, SureComply contracts with third party suppliers who store data on secure data centres in Australia. Further details on our third party storage provider’s location and security can be found here https://cloud.google.com/terms/cloud-privacy-notice.
9. Sending personal information overseas
As stated in section 9 our data and systems are hosted in Australia. However, data may be accessed in a country other than Australia when an entity or individual (who has been authorised to access the personal information) accesses the OnePassport System while in another country.
Where we disclose data overseas, we take measures to ensure your information is treated in accordance with at least the standards that apply in the country whose privacy or data protection laws apply to that personal information (other than when compelled to make disclosure under local laws).
Our site may from time to time have links to other websites operated by third parties. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that SureComply is not responsible for the privacy practices of other such websites. We encourage our users review the privacy policies on any third-party websites.
11. Access to and correction of your personal information
If you wish to access, verify or correct any of the personal information you have submitted to us, you may do so by using the available features on the OnePassport System or by contacting us at [email protected].
We do not have access to the documents that you upload to your account. However, we will provide you with access to the information which we hold about you and allow corrections to be made to this information unless an exception under the relevant privacy law applies. A small administrative fee may be payable for the provision of information.
Our security procedures mean that we may request proof of identity before we provide you with access to personal information.
12 Complaints and inquiries
If you have a question about this policy or have a complaint about the management of your personal information you should contact us at [email protected]. Complaints should include details of the conduct that is the basis for the complaint and any specific details about the grievance.
We take complaints very seriously and will respond shortly after receiving written notice of your complaint. We will endeavour to determine the nature of the issue and how it occurred. We may contact you during the process to seek any further clarification if necessary. We will also contact you to inform you of the outcome of the investigation.
We will aim to ensure that all questions and concerns are resolved in a timely and appropriate manner.
If you are dissatisfied with the outcome of your inquiry or complaint you can contact the Privacy Commissioner at the Office of the Australian Information Commissioner (1300 363 992 or at www.oaic.gov.au)
You can also obtain general information about Privacy from www.privacy.gov.au