This Privacy Policy sets out the approach which AnServe will take in relation to the treatment of Personal Identifiable Information. It includes information on how AnServe collects, uses, discloses and keeps secure, individuals’ Personal Information. It also covers how AnServe makes the Personal Information it holds available for access to and correction by the individual.
1. Collection
1.1 AnServe will only collect Personal Information where the information is necessary for AnServe to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 AnServe collects Personal Information primarily to supply customers with the services ordered from it. AnServe also collects and uses Personal Information for secondary purposes including:
(i) message taking and delivery
(ii) billing and account management
(iii) business planning and product development
1.3 AnServe will not collect Sensitive Information from individuals except with consent and only where it is necessary for AnServe to collect such information for a Client.
1.4 AnServe will not collect Personal Information secretly or in an underhanded way.
2. Use
2.1 AnServe uses Personal Information primarily for the purposes listed in 1.2 above.
2.2 AnServe will not use Sensitive Information for Direct Marketing.
2.3 AnServe may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.4 AnServe will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
2.5 AnServe will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.
3. Disclosure
3.1 AnServe may disclose Personal Information to third parties for Message delivery if consent has been obtained from the Client.
3.2 AnServe will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
3.3 AnServe may disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.
3.4 AnServe may disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
3.5 AnServe does not sell or share any data with third parties.
4. Information quality
4.1 AnServe will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 AnServe will take steps to destroy or de-identify Personal Information after as short a time as possible with agreement from the Client, unless the law requires otherwise.
5. Information security
5.1 AnServe requires employees to perform their duties in a manner that is consistent with AnServes’ legal responsibilities in relation to privacy.
5.2 AnServe will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within AnServe who have a genuine “need to know” as well as “right to know”.
5.3 AnServe will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6. Access and correction
6.1 AnServe will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 AnServe will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting AnServe Customer Service, as per the details in this document. All requests will need approval of the Client before action is taken.
6.4 AnServe will not charge a fee for processing an access request unless the request is complex or is resource intensive.
7. Anonymous transactions
7.1 AnServe will not make it mandatory for visitors to its web site or services to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. AnServe may however request visitors to provide Personal Information voluntarily to AnServe (for example, as part of a competition or questionnaire).
8. Transferring personal information overseas
8.1 AnServe will take reasonable steps to limit the amount of Personal Information it sends to organisations outside the European Economic Area (EEA).
9. Glossary
AnServe means OCU South Humberside Ltd.
Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.
Reasonable Expectation means a reasonable individual’s expectation that their personal information might be Used or Disclosed for the particular purpose.
Sensitive Information means:
(a) information or an opinion about an individual’s:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual preferences or practices; or
(ix) criminal record;that is also personal information or
(b) Health Information about an individual.
Use means the handling of Personal Information within AnServe.