This document sets out the policy of Midcity Group relating to the collection, holding, use and disclosure of personal information, as well as the way in which Midcity Group responds to requests for access to information and for correction, and to complaints about its privacy practices. OCS is committed to complying with the Privacy Act 1988.
This policy relates to OCS Building Maintenance Pty Ltd t/as Midcity and each of its related body corporates.
3. What is personal information
"Personal information" is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not. To put it more simply, if the information or opinion reasonably allows someone to be identified, this would be considered personal information. For example, an individual's name, address or e-mail address, together with records about Midcity's dealings with that individual.
Personal information also includes "sensitive information" which includes more delicate categories of information about an individual, such as health information, racial and ethnic origin, and religious or philosophical affiliations or beliefs.
4. Collection of personal information
Midcity only collects personal information if it is reasonably necessary for its business operations and other related purposes.
Midcity collects personal information a number of ways including when it:
Provides goods and services and related information to customers, and administers customer accounts;
Engages with suppliers, contractors, professional advisors and other business associates;
Engages with and assesses prospective employees; and
Conducts trade promotions.
Midcity, where reasonable and practicable to do so, only collects personal information from the individual after it has informed that individual that the information will be or is being collected. This does not apply where the individual has consented to collection of the information by Midcity from someone else, or Midcity is required or authorised by law to collect the information from someone else.
The kind of personal information collected and held by Midcity includes:
Applications for employment, and deliberations about applications, including work and criminal records checks where necessary;
Contact details of suppliers, contractors, professional advisors and other business associates, and other information relevant to the business relationship;
Where necessary to provide a service to individual clients of a business customer of Midcity, details about those clients.
5. Midcity's purposes for handling personal information
The purposes for Midcity collecting, holding, using or disclosure of personal information include:
Processing of applications for employment;
Delivering Midcity's services;
Conducting relationships with Midcity's suppliers, contractors, professional advisors and other business associates; and
Running Midcity's business.
Midcity may disclose personal information to other related companies in the OCS Group overseas, including New Zealand and the United Kingdom who will only use the information for the same purpose for which the Midcity disclosing company was authorised to use it. Midcity may also use overseas cloud storage platforms to store, access, process and modify personal information. It is not possible to identify all such foreign jurisdictions, but they may include the United States of America, Germany, the United Kingdom, and New Zealand.
6. Security of personal information
Personal information is held by Midcity in a number of ways, including in electronic databases (including cloud servers), email contact lists, and in paper files held in drawers and cabinets, locked where appropriate. Paper files may also be archived in boxes and stored in an offsite secure facility.
Midcity seeks to:
Ensure that the personal information collected is up to date, accurate and complete;
Ensure that the personal information used and disclosed is accurate, up to date, complete and relevant (having regard for the purpose of use or disclosure);
Protect the personal information held from misuse, interference and loss; and
Protect the personal information held from unauthorised access, modification or disclosure.
7. Accessing and correcting personal information
Personal information can be accessed by an individual by contacting the Privacy Officer as detailed below. Access will be granted subject to some exceptions permitted by law and is provided in the manner requested by an individual subject to it being reasonable and practical for Midcity to do so. Midcity may charge a fee to cover reasonable costs of locating and providing the information.
If an individual believes the information held by Midcity is inaccurate, out of date, or incomplete, the individual can request that the information be corrected by writing to the Privacy Officer. Midcity will take reasonable steps to correct the information to ensure that, having regard for the purpose for which the information is held, that the information is accurate, up to date, complete, relevant and not misleading.
If corrected information was previously disclosed to a third party or overseas related entity, Midcity will take reasonable steps to notify the other party of the correction.
Midcity may in some circumstances refuse to correct personal information and if this is the case Midcity will provide written notice to the individual that details:
The reason for the refusal (except to the extent it would be unreasonable to do so); and
How the individual may make a complaint about the refusal.
In circumstances where Midcity refuses to correct personal information an individual may make a request in writing to the Privacy Officer, for Midcity to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. Midcity will take reasonable steps to ensure it associates the statement in such a way that is apparent to users of the information.
The Midcity Privacy Officer deals with any complaints and will respond to the individual within a reasonable timeframe. Midcity takes all complaints seriously and any further action after the initial response will vary depending on the nature of the complaint.
9. Contact information
Midcity Privacy Officer, P O Box 111, Belmont, WA 6984
P: 1300 723 777