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Privacy Policy

1. Introduction

Pendragon is committed to providing quality services to our clients; this policy outlines our ongoing obligations with respect to how we manage all individuals’ confidential and personal information.

We are required to comply with the Privacy Act 1988 (Cth) (the Privacy Act), including the Australian Privacy Principles (APPs). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at  http://www.oaic.gov.au/

Pendragon takes its Privacy obligations seriously. Accordingly, all employees, contractors, and any party engaged by Pendragon are expected to comply with this policy at all times. Failure to do so may result in disciplinary action, leading up to and including termination of employment or, alternatively, termination of a contract.

This Privacy Policy applies to online websites operated by Pendragon, which is used to share information about our services and products; and portals, which allow users to provide information and conduct transactions using electronic means; and internal information management of everyone.

By visiting the Pendragon website or otherwise providing us with your personal information, you are accepting the practices of Pendragon with respect to the collection, storage, and use of personal information.

2. Privacy collection statement

Personal information is collected in accordance with the Privacy Act 1988 (Cth) and may be sought from you when you:

  1. apply for an available position
  2. are requested during an interview
  3. completing forms
  4. request information from Pendragon
  5. download certain documents and information
  6. register for an event
  7. sign up or subscribe to a newsletter; or
  8. various forms of business transactions.

Examples of personal information that Pendragon collects include names, addresses, email addresses, phone numbers, emergency contacts, bank details, superannuation, all information related to remuneration, and business entity information from independent contractors.

Pendragon may also collect statistical information regarding the use of the website or the portal. The information collected includes the visitor’s computer Internet Protocol (IP) address, the date and time of the visit, previous site visited and browser type. This information is collected to provide Pendragon with information about the use to help maintain and develop to provide better information to website users.

Pendragon’s website uses cookies for the purposes of session tracking. However, Pendragon does not collect any personal information from the cookies, including any habits when accessing the website.

The personal information collected by Pendragon is for the primary purpose of providing services and product information to individuals, clients, and prospective client contractors. The personal information may also be used for the following purposes:

  1. To discharge any statutory or reporting obligations;
  2. To provide information to you about Pendragon products and/or services;
  3. To contact you and respond to your queries;
  4. To enforce rights and to fulfil obligations under any agreement between Pendragon and its clients;
  5. To enforce rights and to fulfil obligations under any agreement between you and Pendragon;
  6. To record statistical data for marketing analysis; and
  7. Any other purpose which are permitted under any agreement between you and Pendragon.

While Pendragon will endeavour to collect personal information directly from you, Pendragon may collect some of the personal information indirectly from others, such as the clients or prospective clients of Pendragon or your employer.

If at any time you provide personal information about another individual to Pendragon, you must ensure that the individual has read and understood this policy and separately consented to that personal information being used and disclosed by Pendragon for the purpose set out in this policy.

3. Disclosure

PPendragon recognises the trust with you to provide personal information, and such personal information will not be disclosed within Australia or internationally except as follows:

  1. To the clients of Pendragon
  2. On a confidential basis to agents and service providers that Pendragon uses in the ordinary operation of its business
  3. Personal Information that is “Sensitive Information” will not be disclosed without your consent
  4. To third parties where you consent to the use or disclosure or
  5. Where required or authorised by law.

Pendragon may also use this information for secondary purposes closely related to the primary purpose in circumstances where it would be reasonable to expect such use or disclosure.

4. Spam Act

When communicating electronically with individuals and clients, Pendragon will follow three key elements in order to comply with the Spam Act 2003:

a – Consent

Pendragon will only send commercial electronic messages with the addressee’s consent – either express or inferred consent.

b – Identify

Pendragon will include clear and accurate information about the person or business that is responsible for sending the commercial electronic message.

c – Unsubscribe

Pendragon will ensure a functional unsubscribe facility is included in all commercial electronic messages and deal with unsubscribe requests promptly. Individuals are able to unsubscribe from mailing/marketing lists at any time; by advising Pendragon(see ‘Contact Pendragon’ details on page 8 Section 12 of this document), or by following the steps outlined in the email communication.

5. Anonymity

Subject to an agreement to the contrary, you are not required to provide Pendragon with your personal information. However, the services and products offered by Pendragon rely on such information. If you do not provide your personal information, then Pendragon may not be able to engage you or provide services to you.

6. Security of Personal Information

Personal Information is stored in a manner that reasonably protects it from misuse, loss, and unauthorised access, modification, or disclosure.

When personal information is no longer needed for the purpose for which it was obtained, Pendragon takes reasonable steps to destroy or permanently de-identify personal information. However, most personal information is or will be stored in files that Pendragon will keep for a minimum of seven (7) years.

External Service Provider

Pendragon's websites and its electronic mail servers may be managed by a third-party hosting service provider. When you access the websites or portal application, you may be communicating with a third-party server that may be located outside of Australia

Pendragon and links to other websites

The Pendragon website may contain links to other websites. These link sites are not under our control. Pendragon is not responsible for the information handling practices, conduct or the content of those sites.

Unsolicited personal information

IIf Pendragon receives personal information that Pendragon did not solicit, Pendragon will, as soon as possible but only if lawful to do so, destroy the information or ensure that the information is de-identified.

7. Access to Personal Information

Subject to certain exceptions, individuals may access the personal information we hold about them and update and/or correct it.

Pendragon will not charge for lodging a request, but may recover reasonable costs incurred in supplying the information.

To protect personal information, Pendragon will require identification from the individual before releasing the requested information.

8. Freedom of Information Laws

In addition to Privacy Laws, individuals may have rights to access the personal information contained in certain company documents. Details on how to apply for access to these documents are contained in the Freedom of Information Act 1982 (FOI Act).

9. Maintaining the Quality of Personal Information

It is important that personal information is up to date. Pendragon will take reasonable steps to ensure that personal information is accurate, complete and current.

If an individual finds that our information is not up to date or is inaccurate, they should contact us as soon as practicable so we can update our records.

10. Privacy/Data Protection Obligations

Individuals are expected to act in a manner consistent with the matters set out in this policy, where they have responsibility for personal information.

If an Individual suspects or becomes aware of a breach, they also have an obligation to report this immediately to the Pendragon Data Protection Officer. Failure to comply will be subject to disciplinary action and may result in a warning letter, demotion, or termination, depending on the seriousness of the breach.

Please contact the Pendragon Data Protection Officer via email: info@pendragon.net.au