MASTER BUILDERS WESTERN AUSTRALIA PRIVACY POLICY
We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). This policy explains how and why we collect, use, hold and disclose your personal information.
“We”, “us” and “our” means The Master Builders’ Association of Western Australia (Union of Employers) Perth, and its wholly owned subsidiary MBAWA Apprentice Academy Pty Ltd (ABN 62 681 880 320), which is a registered group training organisation, (trading as the FutureBuild Academy), both of 35-37 Havelock Street West Perth WA 6005, and any other related body corporate (MBAWA).
What is personal information?
Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.
Sensitive information includes information or an opinion about an individual’s health or genetic information (and aspects of biometric information), racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union membership or associations, sexual orientation or practices and criminal record. The Privacy Act affords sensitive information a higher level of privacy protection than other personal information.
References to personal information in this Policy include sensitive information.
What personal information is not covered by this policy?
This policy does not apply to personal information about employment of the current or former MBAWA’s staff. Please refer to your contract of employment or other relevant policy relating to your employment records.
Consent
MBAWA is committed to ensuring that any personal information we collect is obtained lawfully, transparently and with your consent, whenever it is practical for us to do so. By providing personal information to us, you consent to us collecting, using and disclosing your personal information as described in this policy. In some circumstances, where it is not reasonable or practical for us to collect this information directly from you, responsible persons may consent on your behalf – to the extent permitted by law.
What personal information do we collect and hold?
We collect information about you and your interactions with us, for example, when you apply for membership, purchase any of our event tickets or products or services, call us, email us or otherwise visit our website or engage in our group training organisation activities involving our apprentices or if you employ one of our apprentices. The information we collect from you may include your identity and contact details, your business name, ABN and a description of its services, and use of our products and services and details of enquiries or complaints you make.
We use cookies on our website. A cookie is a small text file that the website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the website.
Why do we collect, hold and use your personal information?
We will only collect, use, disclose and store your personal information to provide you with products and services, and manage our relationship with you (that is to pursue our commercial functions or activities), arrange the employment of our apprentices and otherwise undertake our group training organisation activities, or otherwise where required by or authorised under law or a court/tribunal order. Our primary commercial activities involve industry advocacy, membership services, training, safety and compliance guidance, networking opportunities and industry programs for organisations in the building and construction sector.
We may also collect, use, disclose or store your personal information to undertake activities which are associated with our primary commercial functions, for example marketing of MBAWA, MBAWA’ products and services and products and services of other third party providers, such as MBAWA Insurance Brokers (MBIB).
We will never commercialise or sell your personal information. However, if ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.
How do we collect your personal information?
We will collect your personal information directly from you whenever you interact with us and where information is reasonably necessary for our functions or activities. For example, we may collect this information when you:
- enquire about our membership or other services;
- apply for a membership with us;
- engage with us about goods or services that you offer to us or that we offer to you;
- engage with us regarding our registered group training organisation activities, or if you employ our apprentices;
- participate in our recruitment and selection process;
- access our website or our social media pages.
However, we also collect your personal information from other sources in circumstances where you have consented to such collection or you would reasonably expect your personal information to be collected from another source. For example (without limitation), we may indirectly collect personal information when we engage with:
- third parties to undertake our normal business activities;
- MBIB; or
- MBAWA partners and subsidiaries.
We may collect your sensitive information where you have provided your consent for the collection and the information is directly necessary for our functions or activities. However, there are some limited circumstances under which we may collect your sensitive information without your consent, for example, where the collection is:
- required or authorised by or under an Australian law or court/tribunal order;
- necessary to prevent a serious threat to your life, health or safety or the public health and safety of others;
- necessary for us to enforce action for suspected unlawful activity, serious misconduct or legal proceedings; or
- necessary to establish, exercise or defend a legal or equitable claim.
If you do not provide us with your personal information, we may not be able to provide you with our services, communicate with you or respond to your enquiries.
Upon request, MBAWA will offer you to option of not identifying yourself, or of using a pseudonym, provided it is lawful and practicable to do so.
How do we store and hold personal information?
We store most information about you in computer systems and databases operated by us. Some information about you is recorded in paper files that we store securely.
We implement and maintain processes and security measures to protect personal information, which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.
We use a number of physical, administrative and technical measures to safeguard and protect your personal information including:
- the use of identity and access management technologies to control access to systems on which information is processed and stored;
- requiring all employees to comply with internal information security policies and keep information secure;
- requiring all employees to complete training about information security;
- monitoring and regularly reviewing our practise against our own policies and against industry best practice;
- storing electronic information on a server based in Australia;
- storing hardcopy information on secure premises; and
- limiting access to electronic systems on which information is processed and stored.
We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.
In the event personal information held by us has been accessed, disclosed without authorisation, or is lost, we will take immediate action to contain, assess and remediate the incident.
Who do we disclose your personal information to and why?
We may transfer or disclose your personal information to our related companies.
We may disclose your personal information to external service providers so that they may perform services for us or on our behalf.
We may also disclose your personal information to others outside of our group of companies where:
- We are required or authorised by law to do so;
- You have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
- We are otherwise permitted to disclose the information under the Privacy Act.
If the ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.
With your consent, we will disclose personal information (business name, first and last name, phone number, email address, builder type, ABN and physical address) to the MBIB so that they may market their tailored insurance products to you.
With your consent, we will disclose personal information (business name, phone number, email address, builder type, and physical address) publicly through the Master Builder Association’s Find a Member Portal so that consumers may search our database to find your details.
Do we disclose personal information to overseas recipients?
We do not disclose your personal information to recipients that are located outside Australia.
Do we use your personal information for marketing?
We may use or disclose personal information for marketing and promotional information in relation to the goods and services we may offer provided:
- we collected the information directly from you;
- you have consented to, or would reasonably expect us to, use or disclose the information for that purpose; and
- you have not opt-out in receiving marketing communications from us by following the opt-out instructions provided in the communication.
Our direct marketing communications may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).
Access to and correction of your personal information
You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. Requests for access to personal information should be made in writing via email where possible.
Please include the following information in your written request:
- your name and your contact details;
- a clear description of your request; and
- any supporting material.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date, complete, relevant and not misleading.
We will only refuse to correct personal information in accordance with our obligations under privacy law. If we refuse to correct personal information in accordance with privacy law, we will provide a written notice to the requestor setting out:
- the reasons for the refusal (except where it would be unreasonable to provide the reasons);
- the mechanisms available to make a complaint about the refusal;
- any other matter prescribed by the regulations; and
- offer to insert a statement into the relevant record identify the requestor’s statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.
Complaints
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.
In making a complaint, we request that you provide us with the following information:
- your name and your contact details;
- a clear description of your complaint/concerns; and
- any supporting material.
We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
We may contact you be telephone or in writing to:
- seek further information about your complaint; or
- notify you of the outcome of our investigation.
If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent adviser or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action that may be available.
Contact details
If you have any questions, comments, requests or concerns, please contact us at:
- Rochelle McSwain – Head of Membership, Partnership and Events
- rochelle@mbawa.com
- (08) 9476 9800
Changes to this policy
From time to time, we may change our policy on how we handle personal information or the types of personal information that we hold. Any changes to our policy will be published on our website.
You may obtain a copy of our current policy from our website or by contacting us at the contact details above.