Melbourne Building Management Pty Ltd ACN 164 657 381
Date of last amendment: 29 August 2019
To ensure that Melbourne Building Management protects customers and employees private information.
Introduction
Melbourne Building Management Pty Ltd ACN 164 657 381 (“MBM”, “we”, “us”, “our”) is committed to complying with applicable privacy laws in relation to the personal information that we collect in the course of running our business. Where applicable privacy laws provide for exceptions or exemptions, we may rely on those exceptions or exemptions in our information handling practices.
Please take a moment to read our Privacy Policy as it explains how we manage personal information including our obligations and your rights in respect of our dealings with your personal information. This Privacy Policy (other than section 10) explains how we manage personal information about individuals other than employees. Section 10 explains the position of employees.
Key definitions
- “APPs” means the Australian Privacy Principles set out in the Privacy Act;
- “personal information” has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise;
- “Privacy Act” means the Privacy Act 1988 (Cth); and
- “sensitive information” has the meaning set out in the Privacy Act, and includes certain specific types of personal information such as health information, and information about a person’s racial or ethnic origin, sexual orientation, religious beliefs or affiliations and criminal record.
1. How we collect your personal information
We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect the personal information you directly give us through some of the following means:
- when you make an inquiry or order in relation to goods or services, including through our website;
- when you contact us or make requests, comments or enquiries;
- in administering and performing any contracts with building owners, owners corporations and service providers;
- when you contact us via telephone or other means;
- from correspondence (whether in writing or electronically);
- through any mobile applications provided by our organisation;
- while conducting customer satisfaction and market research surveys;
- when administering any of our services; and
- as otherwise required to manage our business.
However, in certain cases we may collect personal information from publicly available sources and third parties, such as suppliers, recruitment agencies, your employers, contractors, our clients, business partners, and from the owners/residents, owners corporations and tenants (including rental property managers) of the buildings to which we deliver services.
If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.
2. Types of personal information we collect
The types of personal information we collect about you depends on the circumstances in which the information is collected. The type of personal information we may collect can include (but is not limited to) your name, postal address, residential address, email address, phone numbers, date of birth, billing information, work contact details and job title.
If you are an individual contractor to us, we may also collect information relevant to your engagement with us including qualifications, length of engagement, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment (e.g. phones, computers and vehicles).
If you are a resident or tenant in a building for which we provide services, we may collect information regarding your vehicle, bicycle, pets, emergency contact details and rental property manager details. If we are retained to prepare evacuation plans for a building, we may also receive health information about you (such as details of a disability) so that we tailor the plan appropriately.
In providing security services to buildings, your image and identifying details may be captured via CCTV cameras in or outside the building. This information may be disclosed to the building operators, police and other enforcement bodies, or as otherwise permitted or required by law.
We only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act. If you do provide sensitive information to us for any reason (for example, if you provide us with information about a disability you have or other health information), you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.
Where you do not wish to provide us with your personal information, we may not be able to provide you with requested goods or services.
3. Our purposes for handling your personal information
As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. We may use or disclose your personal information:
- for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
- for other purposes to which you have consented; and
- as otherwise authorised or required by law.
Some of the specific purposes for which we collect, hold, use and disclose personal information are as follows:
- to access and maintain the buildings to which we deliver services, including providing security, cleaning, general maintenance and repair;
- to provide concierge services to building owners and residents;
- to offer and provide any other goods or services to you or to receive goods or services from you;
- to confirm your identity;
- to operate our website;
- to consider you for a job (whether as an employee or contractor) or other relationships with us;
- to protect the security and integrity of our website and services;
- to develop and improve our website and our goods and services;
- to contact you (directly or through our service providers) to obtain your feedback and to find out your level of satisfaction with our goods and services;
- to comply with our legal and regulatory obligations;
- to address any issues or complaints that we or you have regarding our relationship; and
- to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.
4. Who we disclose your personal information to
We may disclose your personal information to third parties in connection with the purposes described in section 3. This may include disclosing your personal information to the following types of third parties:
- owners and owners corporations of the buildings to which we deliver services;
- tenants within the buildings to which we deliver services;
- contractors that we organise to provide services (such as cleaning, security and maintenance service providers);
- our suppliers, contractors and organisations that provide us with technical and support services;
- our related entities (who may use and disclose the information in the same manner we can);
- our accountants, insurers, lawyers, auditors and other professional advisers;
- any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees); and
- in the unlikely event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors.
We may also disclose your personal information in accordance with any consent you give or where disclosure is authorised, compelled or permitted by law. If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.
5. Protection of personal information
We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas. We use a range of security measures to protect the personal information we hold, including by implementing IT security tools to protect our electronic databases and ensuring that employees and third parties with access to records containing personal information are subject to appropriate information security obligations. We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.
6. Direct marketing
Like most businesses, marketing is important to our continued success. We may provide you with information about products, services and promotions either from us, or from third parties which may be of interest to you, where:
- you have consented to us doing so; or
- it is otherwise permitted by law.
You may opt out at any time if you no longer wish to receive direct marketing messages from us. You can make this request by contacting our Privacy Officer (see section 12).
7. Cookies
A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We use cookies to identify specific machines in order to collect aggregate information on how visitors are experiencing the website. This information will help to better adapt the website to suit personal requirements. While cookies allow a computer to be identified, they do not permit any reference to a specific individual. For information on cookie settings of your internet browser, please refer to your browser’s manual.
We may use third party vendors to show our ads on sites on the Internet and serve these ads based on a user’s prior visits to our website. We may also use analytics data supplied by these vendors to inform and optimise our ad campaigns based on your prior visits to our website.
8. Accessing and correcting your personal information
You may contact our Privacy Officer (see section 12) to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to the personal information we hold about you.
We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing. We will respond to all requests for access to or correction of personal information within a reasonable time.
9. Overseas transfers of personal information
We don’t generally disclose personal information directly to recipients located outside Australia. However, we do utilise third party online applications (such as Microsoft Office 365, OneDrive, BuildingLink) as part of our business that store information we provide to them in the cloud, including potentially on servers outside Australia. In addition, from time to time we may also engage an overseas recipient to provide services to us, such as cloud-based storage solutions.
By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and agree that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.
10. Employees
We collect information in relation to employees as part of their application and during the course of their employment, either from them or in some cases from third parties such as recruitment agencies. Such information may include contact details, qualifications, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment. Under the Privacy Act, personal information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship. We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.
11. Resolving personal information concerns
If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal information, please contact our Privacy Officer (see section 12). When contacting us please provide as much detail as possible in relation to your question, concern or complaint.
We take all complaints seriously, and will respond to your complaint within a reasonable period. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
12. Contact details of Privacy Officer
The contact details for our Privacy Officer are as follows:
Melbourne Building Management Privacy Officer
1216B Toorak Rd, Camberwell VIC 3124
Telephone: 1300 890 512
Email: privacy@melbournebuildingmanagement.com.au
13. Changes
We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you. An up-to-date copy of our Privacy Policy is available on our website.
Last updated: August 2019