Skylife understands that privacy and how we collect, use, disclose and protect your information is important to you. We are committed to ensuring the privacy of your information. In doing so, we are bound by the Privacy Act 1988 (Cth) (“Privacy Act”) and guided by the Australian Privacy Principles (Schedule 1, Privacy Act) (“Privacy Principles”). This policy outlines how Skylife manages personal information, including sensitive information, that may be collected from you. Unless Skylife has direct permission to do otherwise, it will only collect and use personal information as outlined in this policy.
In summary, personal information is information or an opinion (whether true or not) about an individual who is identified or reasonably identifiable.
The types of personal information that Skylife may collect, and hold will depend on the nature of your dealings with us. We may collect and hold personal information in relation to:
- Clients, business associates and potential clients and their employees;
- Individuals, which we collect in the course of acting for clients;
- Suppliers and their employees;
- Employees, prospective employees and contractors; and
- Other people who come into contact with a member of the Skylife team.
Where Skylife has collected personal information, it may use it for:
- The purpose that it was collected for and as set out in this policy;
- Related secondary purposes; and
- Where permitted by the Privacy Principles.
Skylife will obtain consent where otherwise required to do so by law.
The personal information we will collect from you may include:
- Your name, current address, date of birth, age or age group, occupation, qualifications/professional membership, bank account numbers or other financial statements or ancillary information (including government related identifiers such as tax file numbers), email address, telephone/mobile phone number, fax number and personal correspondence, which includes emails, and other contact information.
- Information about people’s previous transactions or dealings with us or our clients, including about visits made to our offices, site’s, contractors’ offices or to events with which we are involved.
Please note that we do not collect personal information that we do not need and while we seek to minimise the personal information we collect, if you do not provide us with personal information we request, we may not be able to communicate with you or provide you with the services and other assistance you seek.
If you are one of Skylife’s ‘business contacts’ (e.g. a contact person for one of our suppliers, or in a government agency or company or client with which we deal), we may collect basic business contact information from you (e.g. your name, title and work contact details). Skylife will not ask to collect sensitive information about you (such as details of your racial or ethnic origin, political affiliation, religious beliefs, sexual preferences, criminal convictions or health information) unless it is needed for the purposes of providing legal advice.
When lending to borrowers, Skylife may collect tax returns or financial position statements which contain personal information. To the extent that government related identifiers (as defined in the Privacy Act) are collected, such as a tax file number, use or disclosure of such information will only be in accordance with the Privacy Act and the Privacy Principles.
Applicants for possible employment positions with Skylife may be asked for personal information including qualifications, skills, experience and character and Skylife will conduct screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks).
For more information on the collection, use and disclosure of personal information of job applicants, please refer to Section 12 of this policy.
Skylife may collect some personal information from you directly:
- Through your access and use of our website;
- During conversations between you and our representatives; or
- When you make an enquiry, complete an application or purchase order.
Generally, we endeavour to collect personal information directly from the individuals concerned to the extent it is reasonable and practicable to do so. However, in some circumstances, we may collect an individual’s personal information from third parties, including credit reporting agencies, law enforcement agencies and other Governmental agencies. If so, we will take reasonable steps to ensure that the individuals concerned are made aware of the collection of their information.
Skylife’s policy is only to use personal information collected from business contacts for the business purpose for which it was collected.
Skylife may need to collect personal information for the following reasons:
- To provide our products and services to you;
- To provide customer support such as responding to your enquiries and requests or providing assistance to you;
- To provide marketing communications to you, including updates concerning Skylife and new developments, including advertising new products or services that we offer, to our clients and to those people who have subscribed to our website, alert services or mailing lists;
- To improve our products and services for the benefit of our customers; and
- For legal and administrative purposes such as verifying and processing payment, screening against fraud, screening against money laundering and other criminal or unlawful activities, accounting, billing and audit purposes, developing, maintaining and testing our systems, for complaints handling and for understanding, exercising, enforcing or protecting our legal rights and those of others.
We may also use personal information for marketing and promotional purposes, including:
- Sending or showing you updates on latest news, offers and promotions in connection with our products and services (and the products and services of our group companies and third parties);
- Tailoring and tracking your interactions with internet banner advertisement and links from third party websites to our website. We may also use personal data to analyse our customers’ preferences and market trends and derive insights, which we may use to tailor the types of products and offers that we present to you; and
- Communicating marketing and promotions to you by post, telephone, or online (including by email or through your mobile device or via online banner advertisement) and, as appropriate and where required, we will ask you for your consent, or otherwise provide you with the opportunity to choose not to receive marketing, at the time we collect your data.
We will provide an option to unsubscribe or opt out of further communication on any direct marketing communication sent to you. You may also opt out by contacting us as set out in Section 13 below.
Skylife does not sell, rent or trade personal information about you to or with third parties.
Personal information may be disclosed outside of Skylife in the circumstances described below:
- We may disclose your personal information to our members, employees, agents, consultants and sub-contractors who assist us in running our business, including this website, or provide related services, and who are subject to security and confidentiality obligations;
- We may disclose your contact details on a confidential basis to third parties for the purposes of collecting your feedback on Skylife’s service provision, to help us measure our performance and to improve and promote our services;
- We may disclose your personal information between certain Skylife corporate or trust entities on a confidential basis for our internal administrative, billing and other business purposes, or for the purpose of providing legal services; and
- We will make whatever disclosures of your personal information that the law requires or authorises us to make.
Any disclosure of your personal information will be for the fulfilling of a purpose described in Section 4 of this policy.
Skylife maintains commercially reasonable physical, electronic and procedural safeguards to ensure the security of any personal information that we hold and protect it from misuse, interference and loss and from unauthorised access, alteration and disclosure. Such safeguards are in accordance with the requirements of data protection legislation.
Our security measures include the following:
- Security procedures for access to our business premises;
- Security procedures within our offices;
- IT security procedures including password protection, firewalls, intrusion detection and site monitoring; and
- Mandatory confidentiality guidelines for all staff.
Despite Skylife’s efforts to secure your information, no data transmission over the internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion.
We comply with our security policies and standards when accessing or using this information and restrict access to your personal data to those persons who need to use it for the purpose(s) for which it was collected. You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you of. In particular, where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or mobile applications, we ask you not to share a password with anyone.
Your personal data may be transferred outside the country in which you are located, including to countries with a lower level of data protection than in the country in which you are located.
We will retain your personal data for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where we are required to retain personal data for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information will be retained) or securely destroyed.
Under the Privacy Act, you have the right to:
- Seek access to your personal information handled by Skylife;
- Ask us to update or correct your personal information when it is inaccurate, incomplete or out of date; and
- Opt-out of receiving direct marketing communications from us.
To provide you with access to your personal information held by us on our current records, Skylife can provide you with a copy of the relevant personal information (ordinarily, an electronic print-out or a photocopy). Skylife will not charge you for the cost of providing this type of access to these current records.
For legal and administrative reasons, Skylife may also archive non-current records containing personal information, such as back up data files and offsite storage. Please note that if we do provide access to old records, we may charge you for the cost of providing such access.
If you are of the view that personal information about you is inaccurate or out of date, or if you have any other queries about access and correction, please contact us using the contact details set out below.
Like most website providers, we generate statistics about how many people visit our site and how people use our website. We use web logs and cookies to do this. This enables us to keep our site relevant and useful. However, generally this information will not identify you. We do not link this information back to your identity or other information that you have provided to us. We do not store any information that identifies you inside cookies.
We log IP addresses (that is, the electronic addresses of a computer connected to the internet) to analyse trends, administer the website, track users movements and gather broad demographic information.
10.2 Access to our website
Sometimes Skylife’s website may contain links to other websites operated by third party companies with different privacy practices. When you access a website other than www.skylife.com.au, please understand that Skylife is not responsible for the privacy practices of that site. We have no control over personal data that you submit to or receive from these third parties and we suggest that you review the privacy policies of each site you visit.
If you have any questions about privacy-related issues or wish to complain about a breach of the APPs or the handling of your personal information by Skylife, please contact us using the contact details set out below. We may ask you to lodge your complaint in writing. Any complaint will be investigated, and you will be notified of the making of a decision in relation to your complaint as soon as is practicable after it has been made, usually within 30 days.
Skylife collects personal information about and from individuals who apply for employment. The information we may collect includes the job applicant’s:
- Personal contact details and gender;
- Educational history, relevant qualifications and employment history;
- Eligibility to work in Australia; and
- Referees’ contact details.
We may collect this information directly from the job applicant or indirectly from a third party, including from a recruitment agency.
If necessary, we will also collect information about applicants from referees and from professional social networking sites like LinkedIn. If the applicant proceeds to the interview stage, we will collect information about the applicant’s performance during the interview.
If you do not provide us the information we request, we may not be able to process or assess your job application.
Skylife uses the personal information we collect about job applicants to assess their eligibility and suitability for employment with the business. Generally, our assessment of applicants’ personal information will relate to a particular role.
However, we may also retain and use applicants’ personal information to assess their suitability for other roles within the business.
We do not disclose the personal information we collect from applicants to any other person or entity.
PO BOX 114, Enfield NSW 2136