This statement outlines Frasers Property's policy on how we manage the personal information we hold. It applies to all divisions and organisations in the Frasers Property group.
It is Frasers Property's policy to respect the confidentiality of information and the privacy of individuals. Frasers Property is bound by the Privacy Act 1988 (Cth) (Privacy Act) including the Australian Privacy Principles ('Principles') and any relevant privacy code registered under the Privacy Act. The Principles are designed to protect the confidentiality of information and the privacy of individuals by regulating the way personal information is managed.
In summary, the Principles define 'personal information' as information or an opinion (whether true or not) relating to an identified individual or which can be used to identify that individual.
What kind of personal information do we collect?
The type of personal information we may collect and hold includes (but is not limited to) names, address, date of birth, age, contact details like phone numbers and email addresses, as well as electronic information from your use of our website (see further below).
The types of individuals we usually collect this information about include:
- customers, clients, tenants and suppliers;
- job applicants, employees, and contractors;
- shareholders; and
- other people who may come into contact with Frasers Property or one of the divisions or organisations in the Frasers Property group.
What methods do we use to collect your personal information?
Personal information may be obtained directly from you, including by way of telephone conversations, Internet enquiries you make or forms you fill out, face-to-face meetings or interviews. There may be some instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect it directly from you. For example, we may obtain a reference from a third party. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
We may ask for other information voluntarily from time to time (for example, through market research or surveys) to enable us to improve our service or consider the wider needs of our customers or potential customers.
In most cases, if you do not provide information about yourself which Frasers Property has requested, Frasers Property may not be able to provide you with the relevant product or service.
Exception in relation to Employee Records: Frasers Property is not bound by the Principles in relation to Frasers Property's treatment of an employee record, if the treatment is directly related to the current or former employment relationship between Frasers Property and the employee.How do we use personal information and to whom may we disclose it?
Frasers Property uses personal information for the primary purpose for which it is collected. In some circumstances, the law may permit or require us to use or disclose personal information for other purposes (for instance where you would reasonably expect us to and the purpose is related to the purpose of collection).
In general, Frasers Property collects personal information for the following purposes:
- to provide products or services that have been requested;
- to help us manage and enhance our products and services, including by analysing future customer needs;
- to facilitate our internal business purposes;
- to communicate with you;
- to assess the suitability of prospective tenants;
- to provide ongoing marketing information about our products and services to people that we believe may be interested;
- to comply with legal obligations;
- to deal with complaints and enquiries; and;
- recruitment of employees and contractors.
Depending on the product or service concerned, personal information may be disclosed to:
- other divisions or organisations within the Frasers Property group;
- joint venture/ alliance partners;
- service providers and specialist advisers to Frasers Property who have been contracted to provide Frasers Property with administrative, financial, research or other services;
- other insurers, courts, tribunals and regulatory authorities as agreed or authorised by law;
- reference agencies or insurance investigators; or
- anyone authorised by an individual, as specified by that individual or the contract.
We require that organisations outside the Frasers Property group who handle or obtain personal information as service providers to Frasers Property acknowledge the confidentiality of this information, undertake to respect any individual's right to privacy and comply with the Australian Privacy Principles and this Policy. We also require that these organisations use this information only for our purposes and otherwise follow our reasonable directions with respect to this information.
Frasers Property uses the personal information it collects about our shareholders to fulfil its legal obligations and to keep our shareholders informed of Frasers Property's progress and the products and services that it provides to our customers. Frasers Property may decide to buy or sell assets which form part of or relate to its business or a division or organisation within the Frasers Property group. In any such transaction, personal information will usually be one of the transferred assets and will be disclosed to the purchaser.Sensitive information is subject to greater restrictions
Some personal information which we collect is 'sensitive'. Sensitive information includes a person's racial or ethnic origin, religion, membership of political bodies or trade unions, sexual preferences or activities, criminal record, state of health and medical history. The way we use tax file numbers is also restricted by law. Sensitive information, specifically health information, may be relevant to applications by prospective employees and while consent will be sought before this is obtained, we may not be able to adequately assess candidates' suitability for some positions without this information. The Principles require that sensitive information is used and disclosed only for the purposes for which it was provided, or a directly related secondary purpose, unless you agree otherwise or for other specific reasons such as if the use or disclosure of this information is required by law (for example, to prevent a crime or serious injury). Documents asking for sensitive information will explain this.Management and security of personal information
We have appointed a National Privacy Compliance Officer to oversee our management of personal information in accordance with this policy and the Privacy Act. Frasers Property trains it employees who handle your information to respect the confidentiality of customer information and your privacy. Frasers Property regards breaches of your privacy very seriously.How do we store personal information?
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by telephone, mail, over the Internet or other electronic media. We hold personal information in a combination of secure computer storage facilities and paper based files and other records and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. The Principles also require us not to store personal information longer than necessary. Where we no longer require any personal information, we will destroy or de-identify it.
We will store your personal information in Australia for the purposes set out above. We may disclose your personal information overseas to China, Hong Kong or Canada.How do we keep personal information accurate and up-to-date?
We endeavour to ensure that the personal information we hold about you is accurate and up-to-date. We realise that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible in order to update any personal information we hold about you. Our contact details are set out below.You have the right to check what personal information about you we hold
Under the Principles, you have the right to request access to any personal information which we hold about you and to advise us if the information should be corrected. The Principles set out the circumstances when we can refuse those requests. If we do refuse a request, we will provide you with a written notice that sets out the reasons (unless it would be unreasonable to provide them).
To make a request to access information we hold about you, please contact us in writing. We will require you to verify your identity and to specify what information you require. We may charge a fee to cover the cost of locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.What if you have a complaint?
You You can contact us about a privacy-related issue by e-mail, phone, facsimile or post:
Attention Janis Wood
Phone (02) 9767 2178
Facsimile (02) 9767 2900
Postal address PO Box 3307, Rhodes NSW 2138
This policy shall be reviewed by Frasers Property’s Board every two years and at any other time considered appropriate by the Board, the Managing Director, General Counsel or the Company Secretary.