This document sets out the approach which Site Hustle will take in relation to the treatment of Personal Information. It includes information on how Site Hustle collects, uses, discloses and keeps secure, individuals’ personal information. It also covers how Site Hustle makes the personal information it holds available for access to and correction by the individual.
This policy is a public document and has been prepared in light of APP 1, Open and transparent management of Personal Information.
1.1 Site Hustle will only collect Personal Information where the information is necessary for Site Hustle to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 Site Hustle collects Personal Information primarily to supply employees of member organisations and individuals who obtain Site Hustle products and services directly from Site Hustle with information and details of its products and services. Site Hustle also collects and uses Personal Information for secondary purposes including:
provision of products and services;
accounting purposes; and
business planning and product development.
1.3 Site Hustle collects Personal Information in a number of different ways including:
forms (both paper and online, electronic forms);
face to face meetings;
communications via telephone, email or facsimile;
interaction with our websites; and
via our social media accounts.
1.4 Site Hustle will notify individuals (including, but not limited to, our customers) of the matters listed below at the time of collecting any Personal Information:
the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
other related Uses or Disclosures that we may make of the Personal Information(Secondary Purposes);
our identity and how individuals can contact us, if this is not obvious;
that individuals can access the Personal Information that Site Hustle holds about them;
that individuals should contact Site Hustle if they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;
the organisations or types of organisations to whom we usually Disclose the Personal Information;
where applicable, any law that requires the Personal Information to be collected;
the consequences (if any) for the individual if all or part of the Personal Information is not provided to Site Hustle.
1.5 Where it is not practicable for Site Hustle to notify individuals of all of the Collection Information before the collection of Personal Information, Site Hustle will ensure that individuals are notified of the Collection Information as soon as possible after the collection. Site Hustle will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.
1.6 Site Hustle will not collect Sensitive Information from individuals except with express consent from the individual and only where it is necessary for Site Hustle to collect such information for an activity or function.
1.7 Site Hustle will not collect Personal Information secretly or in an underhanded way.
2.1 Site Hustle will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual’s Reasonable Expectations.
2.2 Site Hustle Uses Personal Information primarily for the purposes listed in 1.2 above.
2.3 Site Hustle will ensure that:
individuals are clearly notified of their right to Opt Out from further Direct Marketing; and
if the individual Opts Out of all Direct Marketing the Opt Out will be respected by Site Hustle and implemented free of charge.
2.4 Site Hustle will not use Sensitive Information for Direct Marketing.
2.5 Site Hustle may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 Site Hustle will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
2.7 Site Hustle will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.
3.1 Site Hustle may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.
3.2 Site Hustle may Disclose Personal Information to unrelated third parties to enable outsourcing of functions where that Disclosure or Use is for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations.
3.3 Site Hustle will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
3.4 In the rare event that Site Hustle is required to disclose Personal Information to law enforcement agencies, government agencies or external advisors Site Hustle will only do so in accordance with the Privacy Act or any other relevant Australian legislation.
3.5 Site Hustle may Disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
4. Information Quality
4.1 Site Hustle will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 Site Hustle will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.
5. Information Security
5.1 Site Hustle requires employees and contractors to perform their duties in a manner that is consistent with Site Hustle’ legal responsibilities in relation to privacy.
5.2 Site Hustle will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Site Hustle who have a genuine “need to know” as well as “right to know”.
6. Access and Correction
6.1 Site Hustle will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 Site Hustle will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting Site Hustle
6.4 Site Hustle will not charge a fee for processing an access request unless the request is complex or is resource intensive.
7.1 Contact with Site Hustle via phone or web inquiry will be the first point of contact for inquiries about privacy issues.
7.2 Site Hustle will endeavour to manage any privacy-related complaint efficiently and in a timely manner.
8. Anonymous Transactions
8.1 Site Hustle will not make it mandatory for visitors to its websites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. Site Hustle may however, request visitors to provide Personal Information voluntarily to Site Hustle (for example, as part of a competition or questionnaire).
8.2 Site Hustle will allow its customers to transact with it anonymously wherever that is reasonable and practicable.
9. Transferring personal information overseas
9.1 Site Hustle generally does not send information overseas.
9.2 If Personal Information must be sent by Site Hustle overseas for sound business reasons, Site Hustle will require the overseas organisation receiving the information to provide a binding undertaking that it will handle that information in accordance with the Australian Privacy Principles, preferably as part of the services contract.
Last updated: 14th November 2018
Site Hustle. ABN: 67 697 825 403