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To ensure the employees, contractors (team members), partners and clients of Spring Electrical & Solar are aware of how we collect, use, store, protect and disclose personal information.
This Code of Conduct applies to all Spring Electrical & Solar team members.
This document is aligned with the Privacy Act 1988 and other relevant laws. This document will:
- describe the types of personal information we collect, store, use and disclose
- outline our procedures for handling personal information
- explain what personal information we collect, why it is held by us, how it is used and how it is protected
- outline when and how we may disclose personal information
- provide information about how you can access, and correct if necessary, your personal information
- explain how you can lodge a complaint if you believe your personal information has been wrongly collected or inappropriately handled
The Owner/Director must:
- ensure team members have access to adequate training in order to understand the procedures outlined in this policy and take the necessary action when these are not upheld
- ensure appropriate systems and processes are in place to protect the personal information collected and stored by Spring Electrical & Solar
- take appropriate steps to address any complaints or concerns about Spring Electrical & Solar’s compliance with this policy
All team members must:
- be aware of, have access to and comply with the Privacy and Information Management Policy
- report any actual or suspected breach of the policy to the Owner/Director as soon as is practicable
‘Personal information’ means information (or an opinion) we hold (whether written or not) from which a person’s identity is either clear or can be reasonably determined.
Collection of personal information
Personal information may be collected by a team member of Spring Electrical & Solar or by a contractor acting on our behalf. It may be collected directly from the Client or from other people authorised by the Client, which may include service providers, family, friends etc.
Spring Electrical & Solar will only collect personal information for the purposes directly related to the delivery of our services to our Clients.
Types and purposes of information we collect
We collect and store a broad range of personal information relating to:
- employment and management of personnel matters for our team members and contractors
- performance of our legislative and administrative functions
- Clients accessing our services
- management of audits (both internal and external)
- correspondence from Clients, service providers and other authorised sources
- complaints (including privacy complaints) made and feedback provided to us
- requests made to us to amend or update personal information
- policy development
- quality assurance and service improvement processes
The information collected may include, but is not limited to:
- information about the Client’s contact details e.g. phone number, email address, residential address etc.
- information about the Client’s personal circumstances e.g. occupation, type of accommodation etc.
- information about the Client’s identity e.g. name, driver’s licence details, etc.
How we collects personal information
Spring Electrical & Solar collects personal information in many ways including over the telephone (including text messages), via email, from our website, from correspondence posted to us, during face to face meetings (whether formal or informal) and from surveys administered by us.
Information collected by contractors
Under the Privacy Act, Spring Electrical & Solar is required to take contractual measures to ensure that contracted service providers (including subcontractors) comply with the same privacy requirements applicable to all team members. When Spring Electrical & Solar enters into an agreement with a contracted service provider, we will impose contractual obligations on the contractor to ensure they comply with relevant privacy obligations when collecting, using, disclosing and holding personal information relating to the Client.
Storage and security
Spring Electrical & Solar takes all reasonable steps to protect the personal information held in our records against loss, unauthorised access, use, modification or misuse. Spring Electrical & Solar stores personal information in both paper-based and electronic, including records that may be stored in the cloud. The following outlines the procedures related to storage and security of personal information.
- A Client record may include personal information, notes, investigations, emails, reports, correspondence, photographs, video footage.
- A firewall is used within Spring Electrical & Solar’s computer system, as a means of protecting information stored on the computer. Other security related procedures, such as user access passwords and multi-factorial authentication to assist with the protection of information.
- Paper records are kept in locked cabinets and access to keys is restricted
- Client information is stored for seven years post the date of last exchange.
- Client related information or any papers identifying a participant are destroyed, shredded and deleted from the computer and all databases.
- User access to all computers and mobile devices holding Client information is managed by passwords and automatic inactive logouts.
- Access to personal information held by Spring Electrical & Solar is restricted to authorised team members or contractors on a need to know basis.
Spring Electrical & Solar takes all reasonable steps to ensure that personal information collected is accurate, up to date, complete, relevant and not misleading. Spring Electrical & Solar responds to requests to correct personal information as soon as it is reasonable and appropriate to do so. Internal audits may be conducted from time to time to determine the accuracy and integrity of information which will ensure any quality issues are identified and resolved in a timely manner.
Links to external websites and social networking services
Spring Electrical & Solar’s website may contain links to other websites and social networking platforms. Client are informed that Spring Electrical & Solar is not responsible for the content and privacy practices of these websites. It is recommended that the full terms and conditions of any external websites or social networking platforms are read and understood before proceeding to access them.
There are risks associated with sharing or providing personal information in any form, but particularly over the internet, including email. Functional Assessments WA will inform participants, their family and/or nominees of these risks at the initial planning meeting. To mitigate these risks, participants, their family and/or nominee will be advised they can choose to communicate face to face, by post, phone or text to minimise the risks.
Gaining and using consent provided
Prospective Clients contacting Spring Electrical & Solar with an enquiry are not required to disclose any personal information at the time, however, once a decision has been made to utilise Spring Electrical & Solar’s services, personal and sensitive information will need to be collected to ensure the best outcomes are possible.
Unauthorised access, use or disclosure of personal information
Spring Electrical & Solar takes seriously any unauthorised access, use or disclosure of personal information. If a team member becomes aware of a breach, the Owner/Director must be notified immediately. Spring Electrical & Solar will inform the Clients affected, as soon as is practicable, and inform them of the steps taken to resolve the breach and limit the potential for any future breaches.
Access to and correction of personal information
Under the Privacy Act, all Clients and Prospects have the right to access the personal information about them we hold on file.