1.3 This Policy is intended to provide guidance in relation to the handling of personal information of Knightsbridge Canberra customers, contractors, business partners
2. The Privacy Act
2.1 The Privacy Act regulates how APP entities collect, hold, use and disclose personal information, and how individuals can access and seek correction of that information. APP entities are:
- Commonwealth agencies; and
- Private sector organisations which are bound by the Privacy Act.
2.2 "Personal information" is information or opinion in any form that identifies or enables identification of a living person. The complete definition in the Privacy Act is:
information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- (a) whether the information or opinion is true or not; and
- (b) whether the information or opinion is recorded in a material form or not.”
2.3 This Policy sets out how Knightsbridge Canberra manages personal information.
3. Compliance with the Privacy Act
3.1 Knightsbridge Canberra is required to comply with the Privacy Act and, in particular, the thirteen APPs which regulate the collection, storage, use and disclosure of personal information.
4. Knightsbridge's Personal Information Handling Practices
Collection of personal information generally
4.1 Knightsbridge Canberra only collects personal information which it needs in order to perform its functions and activities. Knightsbridge Canberra only collects personal information in a limited range of categories. These categories include:
- personal information collected at the time of making a reservation and information provided by the customer during the stay and any other information provided by the customer to Knightsbridge Canberra in the course of their duties.
- personal information collected by contracted service providers in compliance with contractual measures as required by the Privacy Act; and
4.2 Knightsbridge Canberra collects personal information in accordance with the Privacy Act.
4.3 Knightsbridge Canberra routinely provides a privacy notice as required by APP 5 when it solicits personal information.
4.4 In some circumstances, individuals or organisations provide personal information on an unsolicited basis. Examples of this include correspondence to the Managing Director, Knightsbridge Furnished Apartments Pty Ltd, Manager, Knightsbridge Canberra or to Knightsbridge Canberra generally. Knightsbridge Canberra does not normally give an APP 5 privacy notice in these circumstances because the information is unsolicited.
4.5 In all cases where personal information is received, it is handled according to the particular circumstances and in compliance with the Privacy Act.
4.6 Knightsbridge Canberra collects personal information through a range of different channels including:
- paper-based and electronic forms (including online forms);
- face to face meetings;
- telephone, email, and facsimile communications;
- Knightsbridge Canberra' websites (including online portals); and
- social media websites and accounts.
Kinds of personal information collected and held
4.7 Knightsbridge Canberra collects and holds various kinds of personal information including:
- customers making accommodation reservations, telephone enquiries relating to good and services supplied to Knightsbridge Canberra;
- correspondence, invoices, receipts and other records relating to services provided by Knightsbridge Canberra;
- correspondence, and travel records and other records, including membership lists, relating to Knightsbridge Canberra management;
- distribution and mailing lists relating to the dissemination of Knightsbridge Canberra' publications, reports, newsletters and other information of interest to individuals;
- correspondence and other documents relating to contracts, requests for tenders and other procurement processes;
- correspondence, reports and other records relating to internal and external audits, allegations of fraud and compliance investigations;
- correspondence and other documents relating to complaints and other feedback provided to Knightsbridge Canberra; and
- correspondence and other documents relating to requests for legal advice.
4.8 Where the above kinds of personal information include sensitive information such as:
- information about an individual’s racial or ethnic origin;
- health information such as details of an individual’s medical history, including details of specific medical conditions, disabilities and medication history; or information about an individual’s membership of a professional association, this information is given the higher level of protection required by the APPs, including by restricting access to this type of personal information to certain employees only and filing this information in a more secure fashion.
How Knightsbridge Canberra holds personal information
4.9 Personal information held by Knightsbridge Canberra is stored on an electronic document and records management system and also on paper files.
Purposes for which personal information is collected, held, used and disclosed
4.10 The purpose for which Knightsbridge Canberra collects, holds, uses and discloses personal information will vary depending on the function or activity being undertaken and may include one or more of the following:
- performing personnel functions including work health and safety obligations in relation to Knightsbridge Canberra’ customers, staff and contractors;
- recruiting and engaging staff and contractors;
- contract management; and
- managing and responding to correspondence and enquiries from individuals and organisations.
How to seek access to and correction of personal information
4.11 An individual has a right to access, under the Privacy Act, personal information about themselves held by Knightsbridge Canberra.
4.12 An individual also has a right under the Privacy Act to request Knightsbridge Canberra to correct their personal information. Where an individual wishes to request correction of personal information, they should contact Knightsbridge Canberra at the contact details provided at paragraph 6.1 of this Policy. Knightsbridge Canberra will deal promptly with the request in accordance with the requirements of the APPs.
Disclosure of personal information overseas
4.13 Knightsbridge Canberra does not disclose personal information to overseas recipients except where required by law.
Complaint handling process
5.1 If an individual believes Knightsbridge Canberra has breached their privacy rights, they may contact Knightsbridge Canberra using the contact details set out at paragraph 6.1 of this Policy. Knightsbridge Canberra will treat the complaint seriously and is committed to providing a fair and timely response.
5.2 If an individual wishes to make a privacy complaint against Knightsbridge Canberra, he or she also has the option of complaining directly to the Australian Information Commissioner.
5.3 The Australian Information Commissioner’s details are set out below:
Telephone: 1300 363 992
Post: Australian Information Commissioner
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
6. How to contact Knightsbridge Canberra
6.1 The Manager, Knightsbridge Canberra can be contacted by telephone on 02 61850000 or email: firstname.lastname@example.org.