Last Updated: February 2022
To preserve the confidentiality of all information that individuals provide to Performance
Frontiers (‘PF’), PF has adopted the following policy with respect to privacy (“Privacy
Policy”). In providing its services, PF is bound by the Australian Privacy Principles (“APP”)
under the Privacy Act 1988 (Cth) (“the Privacy Act”) and this Privacy Policy is intended to
accord with those enactments.
The purpose of this policy is to clearly express an up-to-date policy about our management of
personal information. PF may, from time to time, review and update this Privacy Policy to take
account of new laws and technology, changes to PF’s operations and practices and to make sure it
remains appropriate to changes in relevant legislation.
What is personal information?
Under the Privacy Act and APPs, “Personal Information” is information or an opinion about an
identified individual or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
What kinds of Personal Information does PF collect?
PF only collects Personal Information from you that is reasonably necessary for one or more of
PF’s services, functions or activities.
For the purposes of providing its services, functions or activities, examples of some personal
information we might collect are:
- name;
- address;
- contact details (such as telephone numbers, addresses, and email addresses etc.);
- date of birth;
- job title;
- industry/sector; or
- payment details.
Option of Anonymity or use of Pseudonym:
Note that you may choose to deal with PF anonymously or under a pseudonym where lawful and
practicable, provided PF is still able to provide the relevant service or do business with you
without that information. For example, it might not be practical to deal with you anonymously if
PF needs to understand your circumstances in order to provide relevant services.
How does PF collect Your Personal Information?
PF collects Personal Information either directly from you or from your employer. This will
usually be when you or your employer has requested services from PF, as well as through
meetings, assessment forms, agreements, correspondence (including emails), applications through
our website, surveys and through verbal communications.
We use different types of technology to collect your personal information, including tracking
technologies such as cookies.
Surveys:
PF often conducts surveys as part of its service offering to obtain participants thoughts,
opinions, perspectives, experiences and certain Personal Information. Surveys are important part
of planning, development and research. Therefore, PF or a third party that PF has partnered with
or contracted with may from time to time send surveys to you. If you do not wish to receive
surveys from PF (or third party that PF has partnered with or contracted with) or do not wish
your Personal Information to be used for such purposes, you may request exclusion from these
activities by contacting PF’s Privacy Officer using the contact details provided at the end of
this Policy notice.
Receipt of Unsolicited Personal Information:
If PF receives unsolicited Personal Information about you, PF will determine within a reasonable
period after its receipt whether PF could have collected such Personal Information under the
Australian Privacy Principles. If PF determines that it could not have collected such Personal
Information under the Australian Privacy Principles, then PF will as soon as practicable either
destroy the Personal Information or otherwise ensure it is de-identified, if it is lawful to do
so. Otherwise, PF will hold, use and disclose such Personal Information in accordance with this
policy.
How will PF use your Personal Information?
We collect, hold and use your personal information for the purpose of providing our services and
managing our business. We collect your personal information so we can:
- Identify you;
- Provide appropriate support tailored to your needs for the purposes of coaching /
facilitation (other service or product we are providing to you or your employer):- understand your position, desired future, goals and emerging needs;
- understand your tensions, strengths and opportunities.
- Manage complaints and disputes.
We will not use or disclose personal information collected by us for any purpose other than:
- The purposes for which it was provided or a related secondary purpose where you would
reasonably expect us to use or disclose the information; or - Where you have consented to such disclosure; or
- Where required or authorised under law, in circumstances relating to public health and
safety and in connection with certain operations by or on behalf of an enforcement body.
For example, your information may be used, for purposes including:
- To enable PF to assess your needs in order to provide appropriate services;
- Communicate with you about your participation in particular programs / assessments organised
. your employer; - To prepare a Proposal or a Letter of Engagement;
- To enter into a contractual relationship with you;
- To collect Program / Survey information;
- To assist in the facilitation of a program or session;
- For any purpose related to the provision of a service to you (either by PF or a third party)
and carrying out associated services; - For business development and marketing (including our newsletter communications);
- For education and networking events;
- For sales and billing;
- For people & recruitment purposes;
- For operational and scheduling requirements;
- To maintain, facilitate, improve and administer PF’s services to you or your employer.
PF will also use the Personal Information for such other secondary purposes that are related to
the primary purpose of collection (or for sensitive information, directly related) and
reasonably expected by you, or to which you have consented. Secondary purposes include improving
PF’s services, engaging in research, development and business strategy, and internal auditing
and administration and to manage complaints and disputes.
We may use the personal information collected from you for the purpose of providing you with
direct marketing material for other products and services that may be of interest to you,
however you may request not to receive such information and we will give effect to that request.
Please allow two weeks for your request to be actioned.
Who might PF disclose Personal Information to?
When providing our products and services, PF may contract out some functions and rely on third
party suppliers to conduct specialised activities. Whilst Personal Information may be provided
to these contractors and suppliers in order to enable them to perform the agreed tasks, PF will
require all such suppliers/contractors to provide an undertaking by which the
supplier/contractor undertakes to abide by the Privacy Act and Australian Privacy Principles and
use Personal Information only for the specific purpose for which it was disclosed.
We may disclose your personal information:
- to third parties that provide information, services and infrastructure systems to us;
- to anyone, where you have provided us consent;
- where we are required to do so by law.
Sending information overseas:
PF may disclose Personal Information about an individual to overseas recipients, for instance,
when storing Personal information with ‘cloud’ service providers which are situated outside
Australia.
Our primary information management database is hosted through Microsoft Cloud services based
within Australia. Where PF discloses information to an overseas recipient, it will do so in
accordance with the Privacy Act and Australian Privacy Principles.
How does PF Treat Sensitive Information?
Unless we are required or permitted by law to collect sensitive information about you, we will
only do so by obtaining your consent to collect, use and handle your Sensitive Information.
Sensitive information includes information or opinion about your:
- Health;
- Racial or ethnic origin;
- Sexual preferences or practices;
- Membership of a political, professional or trade association (or union);
- Religious beliefs or affiliations; and/or
- Criminal history.
Management and Security of Personal Information
PF’s staff are required to respect the confidentiality of clients’ Personal Information and the
privacy of individuals.
Your personal information is generally held in our computer systems and databases, which may
involve storing data on storage or computer systems provided by third party suppliers.
Where it has been collected from a third party, they may also hold copies of your personal
information. We may combine information we have about you with other information we hold about
you. This includes information received from third parties.
We will at all times seek to ensure that the personal information collected and held by us is
protected from misuse, loss, unauthorised access, modification or disclosure. At all times your
personal information is treated as confidential. PF has in place steps to protect the Personal
Information it holds from misuse, interference and loss, unauthorised access, modification or
disclosure by use of various methods, including password access rights to computerised
records.
PF maintains multifactor authentication to protect against unauthorised access to secure
information. Stored data is backed up through an encrypted online service twice a day. All PF
personal computers have regularly updated virus and malware protection and workstations receive
periodic software patching with security upgrades from Microsoft. PF completes offboarding
procedures with exiting staff which includes ceasing access to any organisational data (through
blocking sign in, resetting passwords and the assigning of any personal mailbox to another
user).
In the event that you cease to have a relationship with PF, any personal information we hold
about you may be maintained on site, online, in computer storage or at a secure off site storage
facility in accordance with legislative and professional requirements.
Access to and Correction of Personal Information
Under the Privacy Act and APPs, you have the right to obtain access to Personal Information which
PF holds about you and to advise PF of any perceived inaccuracy. There are some exceptions to
these rights set out in the applicable legislation.
To make a request to access or update any Personal Information that PF holds about an individual,
that individual should contact PF’s Privacy Officer using the contact details provided at the
end of this Policy notice. PF may require the individual to verify the individual’s identity and
specify what information the individual requires. PF may charge a fee to cover the cost of
verifying the individual’s application and locating, retrieving, reviewing and copying any
material requested. If the information sought is extensive, PF will advise the likely cost in
advance. If PF cannot provide the individual with access to that information, PF will provide
the individual with a written notice explaining the reasons for refusal.
Our response to your request will usually be completed within 30 days of receipt of your
request.
Responding to Data Breaches
If PF has reasonable grounds to believe that it has experienced an eligible data breach, it will
promptly notify individuals and the Commissioner about the breach, unless an exception
applies.
If PF suspects that it may have experienced an eligible data breach, it will quickly assess the
situation to decide whether or not there has been an eligible data breach. PF’s assessment will
be reasonable and expeditious, and PF has developed procedures for assessing a suspected data
breach.
Enquiries and Complaints
If an individual would like further information about the way PF manages the Personal Information
it holds, or wishes to complain that PF has breached the Privacy Act or Australian Privacy
Principles, the individual is asked to contact PF’s Privacy Officer using the contact details
provided at the end of this Policy notice. PF will investigate any complaint and will notify the
individual of the making of a decision in relation to the complaint in a reasonable time after
it has been made.
We will endeavour to respond to your complaint within 30 days to respond unless there are
exceptional circumstances. You may then have an entitlement to complain to the Office of the
Australian Information Commissioner.
Contact Performance Frontiers
Daniela Weatherill
daniela@performancefrontiers.com
+61 7 3870 8433
Performance Frontiers Group Pty Ltd
Suite 1E, First Floor
19 Lang Parade
MILTON QLD 4064
ABN: 15 634 306 362