Privacy Policy

Purpose 

Designer Fire Sprinklers ("DFS" or “the Organisation”) is committed to protecting the privacy of the personal information which the organisation collects, holds and administers. 

Scope 

This Policy applies to all DFS external peoples including but limited to:

  • customers;

  • contractors;

  • suppliers;

  • vendors; and

  • fire departments.

This policy applies to any physical or digital location where duties are performed by individuals undertaking activities associated with DFS.

Policy 

DFS collects and administers a range of personal information for the purposes of providing high-quality customer service. The Organisation is committed to protecting the privacy of the individuals whose personal information it collects, holds and administers. 

DFS recognises the essential right of individuals to have their information administered in ways which they would reasonably expect – protected on one hand, and made accessible to them on the other. The Privacy Act 1988 (Privacy Act) regulates the handling, holding, use, access and collection of personal information (including sensitive information) about individuals. DFS takes its obligations under the Privacy Act seriously when handling all sensitive information.

  1. Responsibilities

1.1   Designer Fire Sprinklers’ Responsibilities

  • Designer Fire Sprinklers are responsible for developing, adopting and reviewing this policy, ensuring it aligns with overall strategic direction and the organisation’s vision and goals;

  • overseeing the development, implementation and enforcement of this policy;

  • providing guidance and clarification on this policy to clients when requested and where necessary;

  • ensuring compliance with legal and regulatory standards; and

  • monitoring changes in privacy legislation, and for advising on the need to review or revise this policy when the need arises.

1.2   Client Responsibilities

  • Ensure an understanding of Designer Fire Sprinklers policies which are relevant to their relationship with the Organisation;

  • Seek clarification on this policy when needed;

  • Comply with the standards outlined in this policy; and

  • Report any policy violations or concerns to their contact at Designer Fire Sprinklers.

    2. Privacy Principles

DFS is bound by laws which impose specific obligations when it comes to handling information. The Organisation has adopted the following principles contained as minimum standards in relation to handling personal information.

  • collect only information which the Organisation requires for its primary function;

  • ensure that customers are informed as to why we collect the information and how we administer the information gathered;

  • use and disclose personal information only for our primary functions or a directly related purpose, or for another purpose with the person’s consent;

  • store personal information securely, protecting it from unauthorised access;

  • provide customers with access to their own information, and the right to seek its correction; and

  • take reasonable steps to ensure the information DFS collects is accurate, complete, up to date, and relevant to the functions we perform.

    3. Collection of Information 

DFS will only collect information by lawful and fair means, directly from interactions with the individual whom the personal, sensitive or health information relates to. In some cases, where it is unreasonable or impracticable to obtain personal information directly from an individual, DFS will seek to obtain it from a publicly available source or a third party.  

3.1    Unsolicited Information

When unsolicited information is received, DFS will determine whether the personal information could have been collected in alignment with correct legislative practice, and then if it could have, it will be treated normally. If it could not have been, it must be destroyed, and the person whose personal information has been destroyed will be notified about the receipt and destruction of their personal information. 

3.2    Personal Information 

In addition to only collecting information that is necessary for the needs of DFS’ primary purpose, the Organisation will also: 

  • notify customers about why we collect the information and how it is administered; 

  • collect personal information from the person themselves wherever possible; and

  • if collecting personal information from a third party, be able to advise the person whom the information concerns, from whom their personal information has been collected.

3.3    Sensitive Information 

DFS will collect sensitive information only with the person’s consent or if required by law.

3.4    Health Information 

DFS will collect health information about an individual if the information is collected as required or authorised by or under law and in accordance with rules established by competent health or medical bodies that deal with obligations of professional confidentiality which bind the organisation. 

4. Use and Disclosure 

DFS will only use or disclose information for the primary purpose for which it was collected or a directly related secondary purpose. For other uses, DFS will obtain consent from the affected person.

4.1    Secondary Purpose 

In relation to a secondary purpose, use or disclosure of the personal information will occur only where:

  • there is a direct relation to the primary purpose and the individual would reasonably have expected us to use it for purposes;

  • the person has consented; or

  • certain other legal reasons exist, or disclosure is required to prevent serious and imminent threat to life, health or safety.

4.2    Direct Marketing 

In relation to personal information which has been collected from a person, DFS will use the personal information for direct marketing, where the reasonable person would expect it to be used for this purpose, and DFS has provided an opt out and the opt out has not been taken up.

If personal information has been collected other than from the person themselves, DFS will only use the personal information for direct marketing if the person whose personal information has been collected has consented (and they have not taken up the opt-out).

If the disclosure of sensitive information is necessary for research or the compilation or analysis of statistics relevant to public health or public safety and it is impracticable for DFS to seek the individual’s consent before the use or disclosure and the use or disclosure is conducted in accordance with guidelines approved by the Commissioner under section 95A, the organisation may make such a disclosure.

4.3    Unlawful Activity 

If DFS has sufficient reasons to believe that an unlawful activity has been, is being or may be engaged in, and the disclosure of personal information becomes a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities, the Organisation may make such disclosures.

DFS may further disclose personal information if its disclosure is mandated by an enforcement body or is required for the following:

  • the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;

  • the enforcement of laws relating to the confiscation of the proceeds of crime;

  • the protection of the public revenue;

  • the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or

  • the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal. 

4.4   Storage of Information 

DFS takes reasonable steps to protect information from misuse and loss, and from unauthorised access, modification and disclosure. These steps include but are not limited to: 

  • undertaking training and providing direction to all DFS employees who handle this information; 

  • entering information into a customised, secure database, which is accessed on a ‘need-only basis’ and is handled in a sensitive and secure way;  

  • destroying or de-identifying personal, sensitive or health information when DFS no longer requires the information for business purposes; or

  • archiving financial information in a secure location in accordance with the requirements of the Australian Taxation Office.  

4.5   Data Disposal

The efficient and effective disposal of the private data of our internal stakeholders is a critical component of maintaining their privacy. When their information is no longer needed or required to be retained, it will be disposed of in a way that prevents unauthorised access or recovery. The data disposal practices of DFS include but are not limited to:

  • permanent deletion of all digital data after 7 years of cessation of employment relationship;

  • Regular review of data disposal policies ensuring they remain compliant with current laws and technologies;

  • Physical destruction such as shredding, pulverising or incinerating materials that cannot be reconstructed or retrieved; and

  • Ensuring that third-party services comply with the same standards for data protection as Designer Fire Sprinklers.

    5. Access and Correction 

DFS takes reasonable steps to ensure that the personal information it collects, holds and uses is accurate, up-to-date and complete. DFS understands individuals have a right to seek access to information held about them and to correct it if inaccurate, incomplete, misleading or not up to date. 

Therefore if an individual and DFS disagree about whether the information is accurate, complete and up to date, and the individual asks DFS to associate with the information a statement claiming that the information is not accurate, complete or up to date, DFS will take reasonable steps to do so. 

5.1   Withhold Access of Information 

DFS can withhold the access of an individual to their information if: 

  • providing access would pose a serious and imminent threat to the life or health of any individual;

  • providing access would have an unreasonable impact upon the privacy of other individuals;

  • the request for access is frivolous or vexatious;

  • the information relates to existing or anticipated legal proceedings between the organisation and the individual, and the information would not be accessible by the process of discovery in those proceedings;

  • providing access would reveal the intentions of the organisation in relation to negotiations with the individual in such a way as to prejudice those negotiations;

  • providing access would be unlawful;

  • providing access would be likely to prejudice an investigation of possible unlawful activity; and/or

  • an enforcement body performing a lawful security function asks DFS not to provide access to the information on the basis that providing access would be likely to cause damage to the security of Australia.

Where providing access would reveal evaluative information generated within the Organisation in connection with a commercially sensitive decision making process, DFS may give the individual an explanation for the commercially sensitive decision rather than direct access to the information. DFS will provide to the individual its reasons for denial of access or a refusal to correct personal information. 

6. Summary 

All stakeholders associated with DFS must take their obligations under the Privacy Act seriously. This means handling any and all personal information in accordance with the Privacy Act and this policy. Breaches of this policy are taken seriously and disciplinary action, including but not limited to termination, may be taken for such breaches. 

If you have any questions or concerns about the way in which we have handled your personal information, or if you believe that we have not complied with our obligations under the Privacy Act, please contact privacy@designerfiresprinklers.com 

7. Review

Our Privacy Policy (external) is subject to review every two years. This review assesses the policy's effectiveness, relevance, and compliance with current employment laws and employee feedback. Any necessary changes will be promptly communicated to all staff and external stakeholders. 

Definitions

Health Information: Includes all personal information relating to an individual’s physical or mental health, disability or services provided to them to support them in managing their health.

Personal Information: Includes 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.

Sensitive Information: Includes information or opinion about an individual's racial or ethnic origin, political opinion, religious beliefs, sexual orientation or criminal record, provided the information or opinion otherwise meets the definition of personal information

Unsolicited Information: Includes information that has been received by the organisation where the organisation has taken no active steps to collect the information

References 

Accessibility 

This document can be accessed by: 

Locations 

  • Designer Fire Sprinklers’ website

Associated documents